Editor & Publisher, Marcellus Drilling News (MDN)
Andrew Cuomo, acting through the hack leadership at his DEC and spurred on by the NRDC gang is attacking what’s left of New York’s Oil & Gas Industry.
Does the oil and gas industry in New York State even matter anymore? Well, yes, it does! It employs a number of people and produces oil and gas to feed our economy. Although Andrew Cuomo has single-handedly sentenced upstate residents to generational poverty by denying them the opportunity to allow shale drilling, there is a rich history of conventional drilling for oil and gas in the state.
But now, even the conventional industry is under assault and attack by Cuomo and his lackeys at the Dept. of Environmental Conservation (DEC). How? The DEC has unveiled what IOGA of NY calls “devastating proposed air regulations”–regulations that will shut down many o&g operators in the Empire State. IOGA calls it a “regulatory assault.” We call New York State the Empire Crumbling State.
The Independent Oil and Gas Association of New York (IOGA of NY) sent out the following Regulatory Alert email last Friday:
Dear IOGANY member,
I write to inform you of devastating proposed air regulations being drafted by the NYSDEC Division of Air Resources. I cannot overstate the negative economic impact that these regs, if adopted as written, will have on your business. Please take the time to read this email and consider your involvement and support.
As we heard at our annual meeting, and in prior meetings with the DEC, New York is adopting, in some cases, more stringent methane and VOC testing requirements than what the EPA had proposed in 2016. This means producers will be required to test every well at least four times a year for air emissions and the cost of the optical gas imaging testing equipment can cost as much as $100,000 or more. In addition, training is required at $5,000 per person and that person must be recertified every 5 years. Leaks must be repaired and re-surveyed. DEC is also considering implementing leak detection and repair procedures at meter and regulating stations.
Compressors will have to be retrofit with vapor recovery systems and these regs will require full capture with no venting to atmosphere for pipeline and compressor blowdowns. Storage vessels with a potential to emit 6 tons per year or more may not vent to the atmosphere and this may include brine and produced water tanks. Pneumatic controllers and pumps will have new natural gas bleed rates imposed with possible requirements for onsite control systems with a 95% emission control rate.
These onerous proposed regulations will have a devastating impact on every single sector of the oil and natural gas industry in New York. Whether you are a natural gas or oil producer, pipeline operator, gas marketer, utility, storage operator, or an oil patch contractor… the ripple effect will impact you!
We just learned the final details of these proposed regs last week. The DEC is seeking input from numerous stakeholders including the opposition groups we fought during the sGEIS battle. DEC has informed us that our comments, “if substantial,” will far outweigh voluminous, emotion-based comments from non-industry groups. However, we have a very short fuse to review these regs and generate industry comments as they must be submitted no later than December 31, 2018.
Accordingly, IOGANY has decided to retain the services of ALL Consulting to assist us in this work. ALL is a very well-respected engineering firm and is familiar with New York’s regulatory climate. The cost for generating these comments are expected to approach $80,000 to $100,000. IOGANY does not have the funds to cover this expense, but because we understand the critical importance of our response and the timing to the DEC, we have authorized ALL Consulting to get started immediately.
We plan to make the case that our New York production falls under the “stripper well” or “marginal well” category and these regulations need to be modified to account for this class of conventional wells. However, we still must include a specific proposal on how to adjust these proposed regs to protect the economics of marginal producing gas wells and stripper oil wells.
I ask that you follow this link to the DEC website to see the DEC’s latest revised stakeholder regulation outline. As you read this, consider the ripple effect and devastating economic impact these regulations, as written, will have upon your livelihood. Then please contribute alongside your fellow members to IOGANY to help us fund these industry comments that will help protect your business. If we cannot raise enough financial support, we will commit what we have raised and modify our comments and response document to address certain critical areas, but this may leave other areas vulnerable to attack from the opposition groups. So please understand… if ever there was a time that we need your support, to be your voice to the DEC, and fight for more common-sense regulations… it is right now!
You can send a donation in the form of a check payable to IOGANY and earmarked “DEC air regs” or call the office at 716-575-4107 and Michelle will assist you with a credit card payment specifically designated for this cause.
Thank you for your anticipated expedient response and generous support to help us combat this New York State regulatory assault!
Very best regards,
Independent Oil and Gas Association of New York*
Clearly, Cuomo is trying to bankrupt and force out the few remaining conventional drillers in the state. He was just reelected for another four disastrous years. If not for family and good friends, we would have exited NY long ago.
Editor’s Note: Yes, New York has an oil and gas industry. Indeed, the natural gas industry started in the crumbling Empire State, in Western New York in the early 19th Century. It also has many thousands of producing wells across the that part of the state, as well as the Southern Tier, the Finger Lakes and Central New York. These wells continue to produce energy New York needs, are completely unobtrusive, support jobs and provide ancillary income for farmers across the state, so, naturally, Andrew Cuomo wants to kill what’s left to appease the wealthy members of the NRDC gang who reside in the trendiest part of Manhattan. It’s shameless—absolutely shameless.
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