IPANM (Jan. 30, 2023) – Today IPANM filed comprehensive comments on BLM’s proposed Federal Waste Prevention Methane Rule. In its filing, IPANM fully endorses the joint comments filed by Western Energy Alliance (WEA) and the Independent Petroleum Association of America (IPAA). Furthermore, IPANM highlights three areas of major concerns as expressed in our filing:
Duplicative Regulation
The BLM is proposing regulations addressing oil storage controls in Section 3179.203, pneumatic controllers in Section 3179.201 and Section 3179.303 Leak Detection and Repair. These aspects are already addressed by either the EPA or the state air quality agencies. BLM’s regulation of air quality aspects, particularly those which are under the jurisdiction of the EPA or state agencies is duplicative and should not be included in the final rule.
Provisions for Unavoidably Lost
Section 3179.4(b) provides a list of “unavoidably lost” gas. IPANM is concerned that the BLM has thoroughly evaluated the different types of hydraulic fracturing techniques being used by operators. In some cases, during flowback after hydraulic fracturing, depending upon the technique used, some gas may have impurities that make it not salable to the gas gatherer. Such an example would be when nitrogen foam fracs are performed. In these cases the flowback gas will have more nitrogen making it not possible for the gas gatherer to accept it. In these cases, the gas must be flared until it can meet pipeline specifications. For this reason, IPANM suggests an additional category in this subsection (b) which allows “Flaring of gas due to impurities in the gas that make it non-saleable to a pipeline”.
Well Completion and Related Operations
In Section 3179.102 the BLM is proposing that only 10,000 Mcf of gas that reaches the surface may be flared royalty free for new completions. This is far too low a volume. IPANM recommends this volume be doubled to 20,000 Mcf which was in the BLM proposal in which was proposed by BLM in the 2016 rule. This volume threshold is much more equitable and provides the necessary flexibility for higher volume wells.
A copy of IPANM’s full filing can be found below.
IPANM Files Comments on BLM’s Waste Rule
