The Petroleum Alliance is working to ensure our members have the information and resources they need to survive and thrive this challenging economic environment. Below are information and resources from our staff and allied trades that we hope will be useful to you and your company. If you need any additional information on any of these programs and initiatives, please contact Jon Bargas (jon@okpetro.com).

• Petroleum Alliance Urges Care Act Funds to Plug Wells 
• Information on federal legislation related to COVID-19
  • White House Coronavirus Task Force
  • Centers for Disease Control (CDC)
  • Environmental Protection Agency
  • CISA Essential Critical Infrastructure Guidance
  • U.S. Chamber of Commerce Path Forward Initiative: Navigating the Return to Work
  • U.S. Chamber of Commerce COVID-19 Small Business Guide
  • IRS FAQ on COVID-19-Related Tax Credits for Required Paid Leave Provided by Small and Midsize Businesses
  • OSHA Workplace Guidance and Resources
  • CDC Workplace Guidance
  • API
  • AFPM

Additionally, the Alliance is working closely with our state and federal officials to provide all possible support for our industry. The following government entities have offered some form of relief the oil and natural gas industry during the COVID -19 pandemic:

The State of Oklahoma – The Alliance staff worked with the Governor’s staff to adopt the presidential guidance on essential critical infrastructure and workforce, and to temporarily suspend public safety licensing and testing requirements. These actions allowed workers in critical infrastructure jobs to continue without disruptions. The Governor then issued Oklahoma Executive Order 2020-07, requiring all non-essential businesses in the state of Oklahoma to close while exempting oil and natural gas companies and workers.

The passage of Senate Bill 661 in 2019 was very serendipitous since it changed the Administrative Procedures Act, allowing agencies to meet by teleconference or videoconference. This allows the agencies to be more flexible while still protecting the health and safety of its employees and the public.

Oklahoma Corporation Commission– the OCC closed their offices to the public and implemented remote work for most of their employees, which required processes be established very quickly to continue the work in a remote fashion. All OCC services can now be conducted online, via telephone, email and regular mail, and will continue until further notice.

The Commission meetings have continued to occur as scheduled, and the public is able to watch the live stream or listen and participate via conference call.

Administrative courts are being conducted via teleconference and videoconference. Contested cases are allowed to be conducted or can be delayed until in-person meetings resume. Companies and attorneys that conduct business in the courts have received updated instructions on remote participation and remote filing instructions. Pleading submissions can be submitted via email as well as all other filings in established OCC causes, and can be emailed to division-specific OCC attorneys. The cause number and venue-specific file stamp will be electronically affixed to the application and returned to the filer via email. The Commission has also suspended all court clerk filing fees for any applications or applications for emergency orders filed during this time. Additionally, they have suspended all fines.

In addition to the efforts outlined above, the Alliance staff has been working diligently on relief for our members by:

• Identifying and correcting issues related to the OCC’s Oil & Gas Division staff working remotely. There are weekly calls to identify problems and work on solutions such as establishing procedures for registering new operators.
• Raising the issue of excess electricity demand charges with the Public Utility Division, which has led to further discussions between the oil & natural gas companies and electric providers.
• Requesting Secretary of Energy & Environment Wagner to submit a RVP waiver for Oklahoma Refineries to the EPA which he submitted on March 26, 2020.
• Encouraging the OCC to submit a request into the Governor’s Coronavirus Aid, Relief, and Economic Security (CARES) Team for funds to plug orphaned wells abandoned by companies financially disrupted due to the impacts of COVID-19.

Oklahoma Department of Environmental Quality – The ODEQ has closed all of their offices to the public and business of the agency continues with email and virtual meetings. The Alliance staff worked with the ODEQ on implementing concerns of the oil and natural gas industry on facility inspections, enforcement discretion, stack testing, and identifying critical industries. The ODEQ implemented an Enforcement Discretion  policy related to compliance with some environmental requirements. The ODEQ still encourages self-disclosure when a non-compliant issue is identified. The ODEQ State Laboratory has remained open with limited services.

The Environmental Protection Agency – The EPA has published a policy concerning enforcement and compliance during the Covid-19 pandemic. The EPA will exercise enforcement discretion specified below for noncompliance covered by this temporary policy and resulting from the COVID-19 pandemic. The policy will apply retroactively beginning on March 13, 2020. The enforcement discretion described in this temporary policy do not apply to any criminal violations or conditions of probation in criminal sentences.

Federal Energy Regulatory Commission –  FERC issued a policy statement, that provides guidance regarding the Commission’s response to the effects of the national emergency caused by COVID–19 on oil pipelines.  The guidance addresses the impacts of COVID–19, particularly where such pipelines are encountering regulatory hurdles that may impede or delay attempts to respond to changing market dynamics. FERC has stated that oil pipelines may request temporary waivers of or extensions of time to comply with the following regulations where necessary and appropriate to address the unforeseen circumstances resulting from COVID– 19.

U.S. Department of Labor’s Occupational Safety and Health Administration – OSHA issued an interim enforcement response plan for the coronavirus pandemic. The response plan provides instructions and guidance to OSHA Area Offices and compliance safety and health officers for handling coronavirus-related complaints, referrals, and severe illness reports.  The response plan contains interim procedures that allow flexibility and discretion for field offices to maximize OSHA’s impact in securing safe workplaces in this evolving environment.

For more information on any of the program and initiatives listed above, please contact our Director of Regulatory Affairs Bud Ground (bud@okpetrocom).