Oil & Gas Producer
Individuals, business entities and associations engaged in the exploration and production of natural gas and/orcrude oil in Pennsylvania.
Oil & Gas Industry Service Provider
Individuals, business entities and associations that offer products and services such as drilling, leasing, marketing of natural gas or crude oil, pipeline construction, well management and service, logging, and similar goods or services related to the exploration and production of Pennsylvania natural gas or crude oil.
Individuals, business entities and organizations that provide significant engineering, consulting, legal services, accountants and other such support to the crude oil and natural gas exploration and production industry.
Individuals who do not fall into any of the categories above. Also, not-for-profit entities.
By Arthur Stewart, Secretary In July, 2016, the EPA issued a new rule preventing produced water from being treated at municipally owned sewage treatment plants. Each year Pennsylvania’s conventional oil and gas industry sends millions of gallons of produced water to municipal plants, including plants in Reynoldsville, Ridgway and Brockway. The EPA Water Rule came as a shock, because the EPA’s draft version of the rule applied only to produced water from unconventional wells. PGCC monitored the rule as it made its way from draft to final stage, and when the final rule included conventional well formations, PGCC immediately reacted by contacting legal counsel and by reaching out to Federal Representatives GT Thompson and Mike Kelly. The EPA’s documents justifying the rule talk about the history of the Marcellus shale, how shale operators initially used municipal treatment plans, and how shale operators later voluntarily agreed to stop using municipal plants. The EPA’s documents claim the EPA did research and made site visits to plants and determined that no produced water from unconventional shale operations was being sent to municipal plants. Therefore, the EPA stated: “EPA does not project the proposed rule will impose any costs or lead to pollutant removals, but will ensure that such current industry best practice is maintained over time.” Of course, this statement blatantly ignores that produced water from conventional operations is sent to the treatment plants. PGCC, as well as Representatives Thompson and Kelly, sent letters to the EPA telling EPA it had made a huge mistake by overlooking the water sent to municipal plants from conventional operations and asking that the definition of unconventional operations be changed so that it excluded conventional well formations. The EPA admitted its mistake, writing in the fall of 2016 that the treatment of produced water from conventional operations was “new information to the EPA.” The relief offered by the EPA was to exempt conventional operations from the new rule for three years. But after that conventional operators would also be barred from using the municipal plants! Keeping the option of the municipal plants is vital to our industry because our disposal options are so limited. The Warren treatment plant closed a few months ago due to crushing effluent limits imposed by the DEP under pressure from US Fish and Wildlife. Other plants are under similar pressures. PGCC filed suit against the EPA asserting that the new rule is illegal because the EPA didn’t have the proper facts. PGCC’s legal counsel is currently discussing the case with the federal lawyers in Washington, DC. PGCC Board members David Clark, Bruce Grindle, and Arthur Stewart traveled to Washington DC March 8 through the 10th to meet with several members of Congress to make them aware of the EPA’s actions and to ask for a roll back of the new EPA rule. The members of Congress included GT Thompson, Barletta, Murphy, Perry, and several others, and all were sympathetic and pledged help. PGCC will continue fighting this issue on both the litigation and political fronts. PGCC Board Members recent trip to Washington DC to fight the EPA Municipal Treatment Plant and other rules. (From left to right: Bruce Grindle, Christine Clark, David Clark and Arthur Stewart)