Exploration and Production

TXOGA submitted comments to the Railroad Commission of Texas in late July on the Commission's revised proposal to amend the financial assurance requirements of its Rules 14 and 78 (with conforming changes to other rules). Bob Sandilos (ChevronTexaco) chaired the workgroup that did the bulk of the TXOGA Regulatory Practices Committee analysis of the Commission's proposal.  More Comments TXOGA's Production Environmental Committee covered a full agenda at its third quarterly meeting recently. Over twelve substantive industry issues were reviewed when it met July 22, 2004 at the Association's offices. More TXOGA's Regulatory Practices Committee met in Austin on July 21, 2004. In addition to finalizing Association comments to the Railroad Commission on Rule 14 and 78 amendments (see separate article), the Committee discussed One-Call legislation, Rule 9 & Rule 46 UIC permit streamlining, Rule 11 requirements, the RRC oil & gas data migration/electronic permitting project, RRC-TDH NORM regulation seminars, TXOGA recommendations to the Texas Energy Planning Council, as well, as other E&P issues. More TXOGA's Regulatory Practices Committee (RPC) is reviewing a 50-page draft report and a 350-page draft BMP guide issued by the State's Water Conservation Implementation Task Force. The draft report and the draft BMP guide are being offered for public comment for 3 weeks (comments due August 23). Any suggested comments should be sent to TXOGA by August 17 at gene_montgomery@oxy.com. More The Texas and Southwestern Cattle Raisers Association recently published an editorial entitled "On a Collision Course" which should be of interest to all those who are involved in the oil & gas industry in Texas. We publish it here because the issue involved will surely arise in the next regular session of the Texas Legislature. More

Pipeline

The Gas Gathering Coalition, chaired by TXOGA member Lindsey Sander (Enbridge Energy), and supported by TXOGA's Pipeline and Regulatory Practices Committees, is currently working on a cost analysis of several safety regulatory options for gas gathering. More Representatives of TXOGA Pipeline and Regulatory Practices Committee are participating in a Texas One-Call Oil and Gas Industry Workgroup, chaired by Elizabeth Bush-Ivie (Houston Pipeline) to develop integrated oil and gas industry positions on various issues associated with proposals to amend the Texas One Call Program statute. More  Legislative Planning for One Call

Legislative

TXOGA held its second quarterly Legislative and Regulatory Planning Meeting on June 13-15 at South Padre Island, Texas. The chairs of TXOGA's numerous standing committees reported on the activities of their respective committees and provided updates on the status of pertinent regulatory developments under their jurisdiction.  In addition, many legislative issues were discussed and plans initiated for the next regular legislative session beginning in January. More

Refining

On July 15th TXOGA's Refinery Environmental Committee met with a large contingent of high-level Texas Commission on Environmental Quality (TCEQ) officials for the sole purpose of requesting approval for increased operational flexibility for TCEQ flexible permit holders. A position paper was given to the officials by the Committee so that it could be used to provide the basis for developing a guidance document. The TCEQ officials present requested that the Chief Engineer, David Schanbacher, draft a document that would give clear guidance to both the permitting and enforcement groups of the TCEQ on this issue. Cindy Morphew, TXOGA's vice president for environmental affairs, will follow-up with the TCEQ's Chief Engineer's office in mid-August to determine the status of this request. The next meeting of the Committee is scheduled for Thursday, September 16, 2004.

Marketing

At TXOGA's Legislative Planning Retreat on 6/14/04, the Fuels Committee Chair offered the attached presentation as a prelude to discussion. It is the same presentation used with the TCEQ Commissioners in April.  The Fuels Committee chair asked the legislative group for help in advocating their efforts later this year and in the 2005 legislative session. Discussion was positive, but many echoed the frustration we have all seen trying to get the state to listen to supply side concerns while they face air quality pressures from the ozone SIP. Presentation:  "Texas Diesel - What Should Texas Do" TXOGA's Fuels Committee met on 6/24/04 to cover the more detailed issues of developing support for advocacy efforts outside of TCEQ and trying to work out some of the details on potential compliance with the rule that those submitting alternative plans are stumbling over. Click for the agenda. The Texas Commission on Environmental Quality (TCEQ) has proposed a new general permit for hydrostatic discharges. The new TXG670000 permit requires very low limits on the effluent. The TXOGA Bulk Fuels Terminals Committee met with the Commission in February 2004 to discuss raising the BTEX and chlorine limits. The TCEQ has since forwarded to EPA Region VI for comments. TXOGA's Bulk Fuels Terminals Committee is tracking proposed changes to the BFT Discharge General Permit.  The TCEQ is renewing the permit and is proposing to relax the storm water pollution prevention plan requirements. The TCEQ has forwarded the proposed changes to the TXG340000 permit to EPA Region VI for comments. The  Bulk Fuels Terminals Committee submitted comments to EPA and TCEQ in January 2004 supporting the proposed solid waste rules that encourage recycling. The Committee is tracking the rule.