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Vol. 7 No. 11 |
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Members,
In this version of The Standard, we provide several updates including information on important RRC Notices, updates from New Mexican agencies, and a new Recommended Oilfield Security Measures document. Our team has been hard at work advocating for the oil and gas industry in the Permian and your input and participation are highly appreciated.
Below, you will also find information on our Top Hand Award Banquet, the Permian Basin Oil & Gas Compensation Survey, and 2025 Membership Renewals. As always, we also provide details on upcoming PBPA events and other relevant community activities:
Important Updates
Community Events
Regards, Ben Shepperd PBPA President |
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Top Hand Award Banquet |
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On January 16th, 2025, the Permian Basin Petroleum Association will honor Mr. Dennis Johnson of Summit Petroleum, LLC, as the 2024 Top Hand—a prestigious recognition of his outstanding contributions to the oil and gas industry.
We invite you to be part of this special evening filled with elegance, camaraderie, and celebration as we pay tribute to a true leader and pillar of the Permian Basin community.
Tables for eight start at $1,500, with individual tickets also available. Space is limited, so reserve your table soon and don’t miss this chance to network, celebrate, and make lasting memories with industry peers! |
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New Mexico Updates |
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New Mexico State Land Office Updated Contact Info.
The Oil, Gas & Minerals Division (“OGMD”) has set up the following email address just for com submissions: ogmdcoms@nmslo.gov. They ask that all new com submissions (e.g. no need to resubmit applications already emailed in), both preliminary approval and final approval, be sent to this email address. By using one centralized email for coms, OGMD hopes to eliminate any delays in reviewing coms caused by vacations for its employees, better manage workflow, and to easily access all coms submitted to the engineering group. Please note, only coms should be submitted to this email address.
For more information, contact the State Land Office at (505) 982-2568. |
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PFAS Hearing in New Mexico
From Tuesday, November 12, to Friday, November 15, the New Mexico Oil Conservation Commission (OCC) conducted a public hearing on a petition brought by WildEarth Guardians seeking to amend the OCC’s rules to address per- and polyfluoroalkyl substances (PFAS) and to require the full disclosure of all chemicals used by companies in downhole operations. The hearing offered time for public comment, as well as opening statements, presentation of expert testimony, and cross examination of experts from all parties involved in the case.
The OCC and parties involved in the case will now work on scheduling timelines for the submission of post-hearing filings and then the OCC will establish dates to deliberate. |
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Texas Updates |
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Texas Legislative Update
The Texas Legislature will convene at noon on January 14, 2025, at the Texas Capitol in Austin. The current political makeup of the Legislature includes significant Republican majorities: 88 Republicans and 62 Democrats in the 150-member Texas House, and 20 Republicans and 11 Democrats in the 31-member Texas Senate.
Lt. Governor Dan Patrick will continue to serve as the Presiding Officer of the Texas Senate, which, unlike the House, does not reorganize its structure with each session. Therefore, Senate chairmanships and committee memberships are expected to see minimal changes, aside from replacing members who are not returning.
The Texas House will commence its session with the election of the Speaker, scheduled for January 14, after members are sworn in to serve in the 89th Legislature.
The Texas Constitution allows for the pre-filing of legislation before the session begins. As of today, approximately 1,500 bills have been filed in the Texas House and about 400 in the Texas Senate. Additionally, several Constitutional amendments and numerous congratulatory and memorial resolutions—both joint and simple—have been submitted.
PBPA has already begun tracking legislation that will impact oil and gas operators across Texas, with a particular focus on those who live, work, and raise their families in the Permian Basin. This tracking will include priority bills as well as those we may oppose or monitor closely due to concerns.
To stay engaged with these legislative issues, please contact Michael at michael@pbpa.info. |
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Chapter 4 Update
PBPA has provided public comments during the rulemaking process, and we expect the Railroad Commission to include the final rule on its December 17, 2024, agenda. We continue to collaborate with the Commission and its staff to address outstanding issues.
Your input and engagement remain invaluable, and we will keep you informed as we learn more about the rule's direction. If you have any questions or concerns, please contact Michael at michael@pbpa.info. |
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RRC Notice Regarding 2025 Pipeline Mileage Fee
The Railroad Commission of Texas (RRC) has issued this courtesy reminder to help pipeline operators prepare for the 2025 pipeline mileage fee, which is due by April 1, 2025. For details on this fee, please refer to Texas Natural Resource Code §81.071 and 16 Texas Administrative Code §3.70.
This annual fee is based on pipeline permit mapping data provided by operators. Permits are divided into Group A and Group B, with mileage rounded to the nearest mile and totaled for fee calculation.
The mileage recorded as of December 31, 2024, will determine the 2025 fee. Operators can make payments starting January 1, 2025, through the Pipeline Online Permitting System (POPS), with the deadline to avoid late penalties being April 1, 2025.
Operators can access the preliminary mileage chart showing permits subject to fees by visiting the RRC website and selecting “Preliminary Mileage Chart - 2025” under “Helpful Links” at RRC website.
If discrepancies are found in the mileage chart, operators should promptly submit permit amendments to the RRC. Amendments submitted by December 1, 2024, will be reviewed and corrected before the final chart is published on December 31, 2024.
Future notices will be sent to the email addresses registered in POPS. Operators should ensure their contact information is current to receive all RRC communications.
For further inquiries, contact the RRC at 512-463-6802 or pops@rrc.texas.gov. |
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RRC Notice on Form H-15
Operators must submit Form H-15, Test on an Inactive Well More than 25 Years Old, to the Railroad Commission of Texas (RRC) within 30 days after conducting a Fluid Level (FL) or Mechanical Integrity (MIT) test. Operators are reminded to notify the appropriate RRC Oil and Gas district office at least 72 hours before testing to receive approval. Notification IDs, obtained at this time, must be included in the form.
The online submission of Form H-15 allows operators to include attachments, eliminating the need for duplicate submissions to the district office. After online submission, the RRC Online System generates a PDF version, and reports can be accessed after RRC review.
To use the RRC Online System for Form H-15, the organization’s Security Administrator must grant the External H15 Filer filing right to relevant user accounts. Instructions for setting up these rights can be found at RRC Online Filing Instructions.
Although hard copy submissions are still accepted, online filing is recommended for quicker processing. If filing by mail, operators must send the original report and any attachments to the RRC. For FL tests, mail to the RRC’s Oil and Gas Division in Austin. For MIT tests, mail to the relevant district office. The form is available for download at RRC Oil and Gas Forms.
For guidance on using the online Form H-15, operators can watch an instructional video on the RRC’s YouTube channel at H-15 Instructional Video or refer to the user guide available at H-15 User Guide.
Questions can be directed to the RRC Oil and Gas district office serving the well’s location, or the Field Operations department at OG_FOPS@rrc.texas.gov or 512-463-6838. District office contact details are available at RRC Locations.
The complete notice can be found at RRC Full Notice. |
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RRC Rules Announcement on Chapter 8
At its open meeting on November 19, 2024, the Railroad Commission adopted a rulemaking including amendments to §3.70 and various rules in Chapter 8 relating to Form T-4B procedures and updates to federal requirements.
The adopted rules will be published in the Friday, December 6, 2024, issue of the Texas Register. The PDF versions of the rules are available at the link below.
For more information on this and other rulemakings, or to access the online comment form for any proposed rulemakings, please see the Proposed Rules page. |
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TCEQ OOOOc Implementation Stakeholder Meetings
The Texas Commission on Environmental Quality (TCEQ) has conducted two stakeholder meetings to gather informal comments on the proposed rulemaking to comply with the U.S. Environmental Protection Agency’s (EPA) OOOOc. The first meeting was held on November 6 in Austin and the second was held on November 14 in Arlington. A third meeting is scheduled for tonight, Wednesday, November 20, in Midland. As required by OOOOc, TCEQ’s proposed rulemaking is looking to address applicability, emission standards, monitoring, recordkeeping, testing, and reporting requirements for designated oil and gas facilities. The rules would set emission standards and/or control requirements for emissions of greenhouse gases (primarily methane) from existing facilities.
November 20, 2024, from 6:00 p.m. to 8:00 p.m. This will be an in-person meeting held at:
University of Texas Permian Basin Center for Energy and Economic Diversification, Auditorium 1202 North 1310 FM 1788 Midland, TX 79707
Prior to the meeting, information on the location will be made available at the following webpage: https://www.tceq.texas.gov/permitting/air/rules/2024-ooooc-rulemaking-oilgas-stakeholder
PBPA has formed a working group to determine PBPA’s engagement with this process and any official commenting that we provide. If you are interested in participating in these efforts, please reach out (stephen@pbpa.info) and let us know. |
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Federal Updates |
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Incoming Administration
Along with a new president in Washington, D.C. in 2025 will come a number of new cabinet and agency appointments, many of which have already been announced, although they will still need to be confirmed. Here are just a few appointees of interest in positions that could impact operations in the Permian Basin.
U.S. Environmental Protection Agency Administrator: Lee Zeldin
Mr. Zeldin represented New York’s 1st Congressional District from 2015 to 2023. In his 2022 run for governor of New York, Zeldin received more votes for a Republican candidate than anyone else in the last half century. President-elect Trump wrote about Zeldin, "Lee, with a very strong legal background, has been a true fighter for America First policies. He will ensure fair and swift deregulatory decisions that will be enacted in a way to unleash the power of American businesses, while at the same time maintaining the highest environmental standards, including the cleanest air and water on the planet. He will set new standards on environmental review and maintenance, that will allow the United States to grow in a healthy and well-structured way.”
For his part, Zeldin has said, "I'm looking forward to serving in President Trump's Cabinet as EPA Administrator. Together, we will restore American energy dominance, revitalize our auto industry to bring back American jobs, make the United States the global leader of Artificial Intelligence advancement, and slash the red tape holding back American workers from upward economic mobility…We will do this all while conserving our environment, protecting access to clean air and water, and keeping the American people healthy. I look forward to contributing to President Trump’s agenda to build a more prosperous future for our nation."
Department of Energy (DOE) Secretary & National Energy Council Member: Chris Wright
Chris Wright is not just known for being the keynote speaker at the 2024 PBPA Annual Meeting, but Wright is also the CEO of Denver based Liberty Energy, which also happens to be a PBPA member. It is possible this is the first PBPA member appointed to a presidential cabinet position since Former Commerce Secretary Don Evans. President-elect Trump said that, “Mr. Wright has been a leading technologist and entrepreneur in Energy. He has worked in Nuclear, Solar, Geothermal, and Oil and Gas. Most significantly, Chris was one of the pioneers who helped launch the American Shale Revolution that fueled American Energy Independence, and transformed the Global Energy Markets and Geopolitics.” And, according to the Congressman August Pfluger, who himself takes over the reins as Chairman of the Republican Study Committee for the 119th Congress, “Mr. Wright deeply understands the undeniable link between energy security and national security, the importance of reliable energy infrastructure, and how overregulation has killed innovation. We look forward to working with Mr. Wright to unleash domestic energy production, advance critical technologies, and restore American dominance on the global stage.”
Dept. of the Interior (DOI) Secretary & National Energy Council Member: Doug Burgum
North Dakota Governor Doug Burgum will take over a department at which PBPA has had many dealings over the years. DOI is a Cabinet-level agency that manages the nation’s natural and cultural resources. The department employs approximately 70,000 employees in 11 technical bureaus: the National Park Service, U.S. Fish and Wildlife Service (perhaps most important to operations in the Permian Basin), U.S. Geological Survey, Office of Surface Mining Reclamation & Enforcement, and the federal bureaus of Indian Affairs, Indian Education, Land Management, Ocean Energy Management, Reclamation, Safety & Environmental Enforcement, and Trust Funds Administration. The department provides access to more than 500 million acres of public lands, 700 million acres of subsurface minerals, and 1.7 billion acres of the Outer Continental Shelf.
“Being selected to lead the U.S. Department of the Interior is an incredible honor and an enormous responsibility, and I’m deeply grateful to President Trump for this opportunity to serve the American people in such a broad capacity,” Governor Burgum said. “Serving as Interior Secretary is an opportunity to redefine and improve upon the federal government’s relationship with tribal nations, landowners, mineral developers, outdoor enthusiasts and others, with a focus on maximizing the responsible use of our natural resources with environmental stewardship for the benefit of the American people.”
The National Energy Council (NEC), on which both Burgum and Wright will sit, is set to consist of all departments and agencies involved in the permitting, production, generation, distribution, regulation and transportation of all forms of American energy. Burgum sees the NEC as fostering, “…an unprecedented level of coordination among federal agencies to advance American energy. By establishing U.S. energy dominance, we can jumpstart our economy, drive down costs for consumers and generate billions in revenue to help reduce our deficit.” Burgum further said that, “focusing on innovation over regulation to solve the nation’s challenges will allow us to smartly expand American energy and make our world cleaner and safer by selling energy to our friends and allies versus them having to buy it from our adversaries.”
Department of Government Efficiency: Elon Musk & Vivek Ramaswamy
Elon Musk and former Republican presidential candidate Vivek Ramaswamy will co-lead a newly created Department of Government Efficiency, an entity President-elect Trump indicated will operate outside the confines of government. Trump said in a statement that Musk and Ramaswamy, "will pave the way for my Administration to dismantle Government Bureaucracy, slash excess regulations, cut wasteful expenditures, and restructure Federal Agencies."
If you have any questions about these appointees or any others that have been announced by the incoming administration, please let us know. |
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Waste Emissions Charge
On November 12, the U.S. Environmental Protection Agency (EPA) announced its final version of the Waste Emissions Charge (WEC) rule. Roughly, the WEC, which PBPA opposed when it was included in the Inflation Reduction Act (IRA), is a fee imposed by EPA on methane emissions from certain facilities, including oil and natural gas producing, gathering, boosting and processing facilities. The WEC applies to facilities that report more than 25,000 metric tons of CO2 equivalent per year under the Greenhouse Gas Reporting Program and is applied to each ton of methane emitted above 0.2% of the natural gas sent to sale from a production facility.
Through increases to emissions factors, calculation changes and added source categories in Subpart W (changes which PBPA also opposed), many operators not previously subject to greenhouse gas reporting will now be subject to not only reporting but to paying the WEC.
The first WEC will be due on September 2, 2025, but applies to emissions that occur in 2024. For 2024, the fee will be $900 per metric ton of methane. In 2025, the fee increases to $1,200 per metric ton. And, in 2026 the fee increases to $1,500 per metric ton.
Under the netting provisions of the WEC, emissions from facilities that are below the waste emissions threshold can be used to “net” against, or reduce, the emissions from facilities under common ownership or control that exceed the waste emissions threshold. EPA is finalizing provisions that allow netting at the parent company level, wherein WEC obligated parties with the same parent company may transfer emissions between one another. If a WEC obligated party’s emissions are less than or equal to zero after netting, no WEC is owed.
EPA is also finalizing approaches for implementing the three exemptions created by Congress in the IRA, which may lower a facility’s WEC or exempt the facility entirely from the charge. These exemptions include the following:
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Featured Issue |
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Recommended Oilfield Security Measures
As many, if not all, of you know, oilfield crime has been a major concern in the Permian Basin. While we continue to work on federal and state legislative efforts to help curb, if not eliminate, these activities, we know that there are actions operators can take to help that don’t necessitate legislation. To that end, PBPA has been working with PBPA member VistaOne to develop recommended oilfield security measures. This collection of recommended measures provides a comprehensive approach to combating oilfield crime, incorporating physical, cyber, and operational security measures alongside strategic recommendations for technology deployment and coordination with industry partners. Enhanced reporting protocols and structured training programs further solidify the approach, ensuring that all personnel are equipped and informed to contribute to crime prevention and incident response.
While this is not the end all be all of stopping crime in the oilfield, we hope through the understanding and implementation of these recommendations that the security of your operations is improved and that your assets are better protected. |
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Membership News |
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2025 Membership Renewals
The PBPA has begun the 2025 PBPA membership renewal process. Invoices for the upcoming year have been issued this month, and we encourage all members to renew to continue benefiting from our association’s resources and advocacy. Especially with a new federal administration and both the Texas and New Mexico Legislative Sessions beginning in 2025.
Please note that these renewals pertain to the full 2025 calendar year. Your continued participation is vital, and we deeply appreciate your commitment and support throughout 2024. Your engagement has helped strengthen our collective voice and advance our shared goals. We look forward to another year of collaboration and success with you as valued members of PBPA.
To review your membership informaiton, you may log in to the new online Member Center. Create your login today using the email we have on file to access resources like:
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This year, the Whitney Smith Company is conducted the seventh annual Permian Basin Oil & Gas Compensation Survey, sponsored by the PBPA, to give locally operating businesses data you can use to analyze your pay levels against current market practices.
Even if you did not participate, the reuslts of the 2024 survey are still available for purchase. For more information, or to order the results, visit this webpage.
Benefits of the Survey:
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PBPA Events |
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RECAP: November Membership Luncheon |
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On November 18, PBPA hosted a Membership Luncheon at the Petroleum Club of Midland. Traditionally, we do not hold Membership Luncheons in November. However, we knew providing our members the opportunity to hear from Public Utility Commission of Texas (PUC) Commissioner Lori Cobos on the Permian Basin Reliability Plan, was a must!
Through our Electrical Coalition and our Electric Transmission Initiative, PBPA has been advocating for increased and more reliable electricity delivery throughout the Permian Basin for years. The Texas Legislature’s passage of HB 5066 in 2023 delivered a pathway for the PUC to develop the Permian Basin Reliability Plan. Commissioner Cobos was a key proponent for the plan and we wouldn’t have it today without her commitment and vision. While there is still plenty of work to be done to satisfy the electrical demand in our region, the Permian Basin Reliability Plan sets out the pathway to install and construct much needed local and import transmission projects. With demand in the Texas portion of the Permian Basin alone projected to grow from 16 GW in 2023 to 24 GW by 2030, increased transmission will be vital to meeting the increasing demand.
Along with a presentation from Commissioner Cobos, attendees of the November Luncheon also received an update on PBPA activities, particularly focused on federal agency appointments under the incoming administration and a preview of high priority issues we expect to take center stage this upcoming Legislative Session in Texas and New Mexico.
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Committee Meetings |
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For more information on these or any of our other committees, please contact Stephen Robertson at stephen@pbpa.info or (432) 684-6345. |
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Community Events |
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MC PPDC provides quality training programs designed to keep oil and gas industry professionals current in their areas of expertise by offering the latest industry updates, as well as providing timely and pertinent educational opportunities. Click the link below for upcoming classes being offered by the MC PPDC in the coming months.
Customized Training Available! For more information contact Midland College PPDC at (432) 683-2832 or cepetroleumtraining@midland.edu |
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Permian Basin Petroleum Association | 601 North Marienfeld St., Suite 200, Midland, TX 79701 |