Manage the Risk. Reap the Rewards.
This "Update" is being instituted as a service to our clients and the general public so that industry stake-holders can keep a finger on the excruciatingly slow pulse of Texas, and federal environmental/oil and gas regulation. This "Update" will not be about global warming, ethanol, or other "cool" and "sexy" topics that are discussed ad nauseum. Rather, we will focus on practical changes and proposals that would affect permitting, the regulatory process, and other delightful things that drive far too many in our industries to the verge of madness. This is not to say that we will not from time to time post whatever catches our eye, but we will endeavor to become your source for environmental regulatory news. So sit back, relax, enjoy the show, and, when you feel the urge, do not fear to email a comment or suggestion.
Comments about the "Update" itself can be emailed to J. B. Bleckley.
Thanks!
Jeb Bleckley
You can find the TX Railroad Commission's webapps.rrc.state.tx.us/ newest feature, pay online with a credit card. A 3% convenience fee is applied, and you can only purchase things that are currently non-refundable, although this covers a surprisingly long list of mundanities, from LPG card renewal (and late renewal), to various classes. A comprehensive walkthrough is provided for those who have never used such a system. In reality, the help system should not be needed by too many, as it is self-explanatory, and this is the sort of system that has been in place in private enterprises for about 10 years. It is nice to see that our government is catching up after being 10 years behind the private sector.
The RRC has expanded their website https://webapps.rrc.state.tx.us/ to find assigned lease IDs. You can search by field, operator, date range, drilling permit number, API number, district or county. They may not yet have the entire database searchable as of yet, but they should soon, and then it will be a quick and easy tool for whenever you need to find Lease IDs.
This bill is moving through the House Environmental Regulation committee. If it gets to a vote, it will probably pass under the radar and get approval because a) legislators do not care and b) it has the aura of a "feel good" bill. The bill directs the TCEQ to alter (lower) filing fees for those who file online, "to encourage electronic reporting and the use of the Commission's electronic document receiving system." The one issue with this bill is that it may not get out of committee because it seems like nobody cares about it.
Another bill trying to claw its way out of the Environmental Regulatory Committee, this bill qualifies an earlier provision in the law that required only those permits that were financially and technically feasible. With this bill, should it pass, all permits regarding certain air pollutants in certain higher risk areas are mandatory where the permit would cause the certain air pollutants to be generated. Further, all preconstruction permits required to bring the site into compliance with local, state, and federal air regulations are required. These newly required permits are exempt from the previous condition of "economically reasonable and technically practicable considering the age of the facility and the effect of its emissions on the surrounding area."
In the TX House Environmental Regulatory Committee, a bill is being considered to add another layer of approvals necessary to acquire pollution permits. In large counties (population 1.3million or more), the TCEQ may not grant final approval to any permit that may degrade the quality of the air or water without the approval of the county. This, however, only applies to the unincorporated areas of that county, and therefore only permit requests outside of any city or township within that large county will require that extra layer of approval. I believe that this bill is a response to certain large cities who are requiring permit seekers inside city limits to jump through extra hoops, while those outside the city lines are getting away with fewer required approvals.
With April 17 right around the corner, make sure to follow these few simple tips to help you through this tax season! http://www.irs.gov/newsroom/content/0,,id=104608,00.html