- Providers of oil and gas measurement training and Standard Operating Procedures (SOPs) for custody transfer measurement professionals.
In our current political climate of emotional debates and partisan bickering, it’s important to get clarity about what is actually happening with critical issues such as the intersection of environmental policy and industry needs.
Mandy Gunasekara, a D.C. insider who previously served in the Office of Air and Radiation for the U.S. EPA, joins the Pipeliners Podcast to educate pipeliners on actual events happening inside Washington.
Listen for first-hand insight on the environmental policy changes from the Obama to Trump Administrations, how current and proposed environmental policy affects oil & gas and pipeline interests, and how Mandy is educating the public on the work being done beyond the headlines.
Environmental Policy for Pipeliners: Show Notes, Links, and Insider Terms
- Mandy Gunasekara is the founder of the Energy 45 fund. Mandy previously served as the Senior Policy Advisor for the EPA and Principal Deputy Assistant Administrator for the U.S. EPA Office of Air and Radiation. [Connect with Mandy on LinkedIn]
- Energy 45 a non-profit organization designed to educate the public on environmental policy and regulations that affect the general public and industries such as oil and gas, energy, and pipeline.
- EPA (Environmental Protection Agency) is an independent organization within the federal U.S. government designed to take measures to protect people and the environment.
- Andrew Wheeler is the current administrator of the EPA. Scott Pruitt was the previous administrator of the EPA and Bill Wehrum was the assistant administrator.
- The Office of Air and Radiation (OAR) develops national programs, policies, and regulations for controlling air pollution and radiation exposure.
- The Clean Air Act is a joint effort of U.S. states and the EPA to solve air pollution problems through programs based on science and technology.
- The Clean Power Plan was a proposed rule under the Clean Air Act designed to limit carbon emissions from power plants.
- The “Methane Policy” [a/k/a Quad Oa Rule] under the Clean Air Act calls for proposed regulations on the oil and natural gas industry to help combat climate change and reduce air pollution that harms public health. The regulations apply to equipment and activities used for the onshore oil and natural gas industry. [Read Information on the proposed performance standards]
- LDAR (Leak Detection and Repair) regulations require operators to craft a program that specifies the regulatory requirements and facility-specific procedures for recordkeeping certifications, monitoring, and repairs to prevent damage to people and the environment. [Read the EPA Handbook on LDAR Best Practices]
- The U.S. Senate Environment and Public Works Committee oversees issues at the intersection of environmental protection and industrial needs, such as infrastructure development.
- The GPA Midstream Conference is a midstream-focused gathering of international oil & gas professionals that provides opportunities for networking, learning, and shared lessons on issues impacting the midstream industry. This year’s event was held in April in San Antonio, Texas.
- PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- The Pipeline Safety Trust (PST) is a public charity promoting pipeline safety through education and advocacy by increasing access to information, and by building partnerships with residents, safety advocates, government, and industry.
- The Bellingham Pipeline Incident (Olympic Pipeline explosion) occurred on June 10, 1999, when a gas pipeline ruptured near Whatcom Creek in Bellingham, Wash., causing deaths and injuries. Three deaths included 18-year-old Liam Wood and 10-year-olds Stephen Tsiorvas and Wade King.
Environmental Policy for Pipeliners: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 82, sponsored by Gas Certification Institute, providing oil and gas measurement training and standard operating procedures for custody transfer and measurement professionals. Find out more about GCI at gascertification.com.
Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations.
Now you host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time. To show that appreciation, we’re giving away a customized YETI tumbler to one listener each episode. This week, our winner is Duston McElwee with Energy Transfer. Congratulations, Duston, your YETI is on its way. To learn how you can win this signature price, stick around to the end of the episode.
Mandy, welcome to the Pipeliners Podcast.
Mandy Gunsekara: Thank you.
Russel: I want you to tell listeners a little bit about your background and what you do.
Mandy: Yeah, sure. I recently was in the administration. I started out right after former administrator Scott Pruitt was confirmed to be President Trump’s administrator of the Environmental Protection Agency.
I started out as a senior advisor shaping the air and climate agenda, and then I did that for the first nine or so months that I was there, and then switched to become the Principal Deputy Assistant Administrator in the Office of Air and Radiation. I was working with Bill Wehrum, who is the Assistant Administrator, basically, the guy who’s in charge of that particular office.
What I did was again continue what I had started, which was shape the air policy, which was a huge part of President Trump’s deregulatory agenda, because going back a few years in the last administration, EPA was propelled in it as the centerpiece of the last administration’s Climate Action Plan. They had used EPA’s authority under the Clean Air Act to propose the Clean Power Plan, a new source performance standard for oil and gas operations, and some standards for HFCs, which is a refrigerant policy. We don’t have to get into all that, but a lot of the key regulatory actions from the last administration that were somewhat offensive, in a lot of different ways, to this administration’s approach to fulfilling regulatory responsibilities came from our office at EPA.
We were charged with making the decision whether to roll them back, whether to adjust them, or to rescind them completely and move on. We were busy doing that. Now, prior to me being at EPA, I had worked in the U.S. Senate Environment and Public Works Committee.
I worked for Chairman [James] Inhofe, who led the committee in 2015 and 2016, and then I stayed for a couple of months under Chairman Barrasso, who’s a Senator from Wyoming. Then prior to that, I’d worked in the House, and prior to that, in the Senate.
I bounced back and forth between positions in the U.S. House of Representatives, the U.S. Senate, and all of that had started when I did an internship in undergrad for my local Congressman, where I came up to Washington, D.C.
I caught what’s called Potomac Fever, which is essentially an excessive interest in what goes on in Washington, D.C. I knew at that time I wanted to come up and be a part of what was going on in D.C., but I wasn’t quite sure what that would end up.
Through the culmination of where I worked and where I ended up, I ended up focusing on environmental policies, which has brought me to you here today.
Russel: That’s an interesting story. Potomac Fever, it’s interesting, because I actually know what that is. A lot of people — I don’t talk about this very much — right after I got out of the military, I got very involved with Young Republicans.
That brought me to D.C. and got me connected to a lot of programs. There came a point where I had to make a decision. Was I going to try and do the political thing, or was I going to pursue being an engineer and oil and gas guy?
The engineer idea won out, but I understand. I think one of the things that a lot of people don’t understand is, if you have the time and interest, you can have a lot of influence in D.C. I don’t really care what your agenda or background is. If you have the time, and you have the interest, you can have a lot of influence.
Mandy: No, absolutely. It’s interesting, too, because D.C., especially on Capitol Hill — not necessarily at the agencies, but on Capitol Hill — a lot of these major policy decisions are being made by 20-something-year-olds who are really smart and really excited about what they’re working on.
That is typically what brings people to D.C. — some larger interest in public policy and shaping it one way or another. You have relatively young folks with a lot of influence making big decisions.
Russel: Yeah, that’s a very good point. Again, I don’t think a lot of people realize that, is that a lot of the real work in policymaking, particularly on the Hill, is with the staffers. The staffers are generally young.
Mandy: Yeah, absolutely. That’s why if you’re a newly minted attorney, it’s a good place to come out. I graduated from law school in 2010, which was a pretty bad year for attorneys, just across the country. D.C. was a place that I could come, and there was still plenty of opportunity to do the type of work that I was interested in.
Russel: That’s great. That’s a great segue, because what I asked you on to talk about is environmental policy and pipelines. I actually met you at the Gas Processors Association [GPA] meeting earlier this year.
Maybe you could just tell the listeners what you were there to talk about and how does somebody who went to D.C. from Mississippi with their local Congressman become a policy person around environmental and start talking to oil and gas midstream operators.
Mandy: I started talking with GPA, or developed a relationship with the GPA Midstream lobby group because Matt Hite is someone who came in. He is a good ambassador for GPA. He came in and we actually met when I was in Senator Inhofe’s office.
He’s a former Inhofe staffer, so we already had that connection going, but I met him when I was on Capitol Hill. Then, when I went to the administration, obviously, there’s a number of issues pending before the agency’s air office that have an impact on the operational context of pipelines.
Matt and his team would come in a fair amount, and after I left EPA this February, I ended up in a conversation with Matt. He thought it would be a good idea for me to come out to the GPA Midstream Convention, where we met.
I gave a little talk about my new organization, which is Energy 45, and a little bit about why I left the administration, where I was in this deep policy/counsel role to where I am now, which is this communications, educational role.
I basically walked through that, and a lot of it has to do with the fact that I think as Republicans in general, but in this administration especially, it’s really hard to talk about the work that we do and to get any sort of positive feedback from it.
The cards, so to speak, are somewhat stacked against us. That’s not to be political or divisive anyway, that’s just matter of fact, in a lot of ways. Especially the work I was doing in the Office of Air and Radiation.
If you were to go and look up everything I worked on, and you focused on the reports from the Washington Post or the New York Times, you would think that I have destroyed the earth and killed a lot of children.
That couldn’t be further from the truth in terms of what we were working on and how we approached our day-to-day work. I was motivated, being on the inside looking out, to leave and be a part of the communications world to try and be a sound voice of substance that could talk about these issues in a meaningful way.
To let folks know, no, we’re not doing these horrible things that capture your attention through a pithy headline. We’re actually being very thoughtful, deliberative, and meaningful in the way we approach an important responsibility, which is to protect public health and the environment.
We do it a little bit differently, and that doesn’t have to be such a divisive issue that keeps people in political entrenchments. That has been a big problem in terms of advancing the ball in the environment, the climate, and the air space.
Russel: You just said a whole lot, but I think, as pipeliners, we can relate to that. One of the things I often say about the pipelining business is the only way…It’s like being an offensive lineman in football. The only way you get your number called is you screw up, right?
Mandy: Yeah. [laughs]
Russel: I think that there’s a lot of similarity. I think this need to you’re addressing to communicate rationally, in-depth, and thoughtfully around policy decisions, how they’re being made, and the impacts they have is important.
I actually think there’s a hunger for that kind of deeper substantial conversation. It’s one of the reasons I started the podcast. It’s a format that gives you an opportunity to have a more meaningful conversation. A lot of what I do is kind of goofy and fairly technical, but it’s also serious, right?
Russel: Tell me, what is going on right now, related to environmental policy and pipelines in midstream. What’s the key subjects that people are interested in, and what’s going on around that policymaking?
Mandy: There’s a lot. I would split it up into two categories. There is the political element that you’re seeing permeate from Capitol Hill, and all the presidential contenders. I’m going to sideline that for a second, and what you’ll probably care more about is what the agency is considering, the EPA.
One of the biggest policies that EPA has been working on that is soon to be coming out is what we call the “Methane Policy.” You can’t see me, but I’m air quoting. That was just a shortened phrase to talk about the new source performance standard for oil and gas standards that was set in the last administration.
Many people refer to it as the Quad Oa Rule. Then the response from this administration has been twofold. One was a technical package that we put out last year to fix some problems with the rule that was final in the last administration, Quad Oa Rule, that just didn’t work.
When I first came in in early 2017, so March of 2017, I got meeting requests with a ton of oil and gas entities. They were very concerned with reporting requirements that were coming down the pike for, I think it was June 2nd or June 3rd.
LDAR was essentially coming down, and folks said that there were a lot of problems in terms of reporting requirements. It was duplicative, in some instances. It didn’t account for some engineering differences that on the ground, you would understand, but looking at EPA and trying to assess the complex data comes in, it just wasn’t going to work.
One of the first things I ended up working on was initiating what we call the stay, which is essentially a regulatory tool that you have to buy yourself more time. Early on, we tried to get a stay on the effectiveness and implementation requirements of the Quad Oa rule to defer deadlines for the regulatory community to give us time to figure out, how do we fix this? Number one.
Then the bigger question is, do we think Quad Oa is needed as a wholly separate regulatory body? Which is issue number two. We have the technical policy package that we put out last year. The second step of what we’re working on is the policy package itself.
The policy package is asking this larger question. When it comes to Quad Oa, I’m sure you and your listeners are intimately familiar with, before there was Quad Oa, there was just Quad O. In 2012, the Obama Administration proposed and finalized a rule that controlled volatile organic compounds, more traditional pollutants from oil and gas operations.
They had that in place, and then after, starting in 2015 and then finalized in 2016, they started Quad Oa, which was a separate regulatory body that was solely focused on controlling methane which is a greenhouse gas, a less traditional pollutant.
What that rule also did is, it expand the jurisdictional authority and reach of EPA beyond what they had historically been responsible for establishing some measure of oversight. Step one, technical package, fix the existing rule.
Step two is, do we still need Quad Oa when we already had Quad O? A lot of what the agency is trying to do, which was reduce pollutants affiliated with this entire process, a lot of those pollutants are already captured under the auspices of Quad O.
This policy package, to that latter point, which is going to be dependent on a lot of legal analyses and nuance under the Clean Air Act, all of that is coming out later this summer. That’s a really big deal in terms of how it affects oil and gas operations on its face.
Then, also, how it affects the ability of this administration or future administrations to set greenhouse gas standards across the board.
Russel: Man, again, that’s a mouthful.
Mandy: I know.
Russel: It’s interesting. Mandy, a lot of times, I’ll have somebody on, and it’s a topic that I’m fairly intimate with. I have to say, I’m fairly ignorant of…I understand what the EPA is and how agency stuff works, but in terms of the details of the policy and technical rulemaking that’s going on on these subjects, I know very, very little.
What are the key elements in the new policy package that’s coming out? What are the key things that an operator would want to know about?
Mandy: I would say it like this. First, let me caveat everything with, the rule is still in development. Nothing is final until it’s final. We’re just talking. We’re just talking. I think the most important elements for folks in the field, what they would be interested in is whether or not there will be a Quad O or a Quad Oa in the future, which is the potential impact of this policy package, the question we’re asking.
I’m going to get a little legally technical, but not too crazy. Bear with me. Under the Clean Air Act, there is Title I, Title II, and on.
Title I is what we’re all focusing on, because that is the authority that Congress gave the agencies to set regulations for stationary sources. In oil and gas operations, because they don’t really, typically speaking, have wheels on them, they are a stationary source. They fall under Title I.
Now, the pertinent provisions are in Section 111b and Section 111d. In Title I, there is a requisite. Before EPA can go out and regulate a stationary source, they have to meet a threshold of endangering the public welfare, and then contributing on some level that means they are a significant contributor.
Now, what’s different in Title I, compared to all the other parts of the Clean Air Act, is this word “significance.” Significance is only a threshold requirement for actions under Title I. A lot of this methane policy package will be focusing on and parsing out.
Congress didn’t just throw words into laws because it felt good or it sounded good. There was a lot of thought and meaning behind that. Prior to us in this administration thinking about that, no one has really parsed that out in a technical way.
What they’ll be teeing up, and the administrative process — just to go back a little bit — the way that it works is, EPA puts out a proposed rule. Everyone reads that. By everyone, I mean regulated entities, NGOs [non-government organizations], anyone who has interest in what the overall outcome of that action is.
They then submit comments to the agency. These can be legal comments, technical comments, or just generally how they feel about it comments. All that information is then received by the agency. Our technical team of engineers and specialists go through it, and then they use that information to inform the final rule.
A lot of what you’ll see in the proposed methane policy package that will be coming out this summer is teeing up at least the initial parsing out of what does significance mean in the context of Title I of the Clean Air Act?
Then when you apply that to oil and gas operations, the big question is, oil and gas operations are already regulated under Quad O. The focus is volatile organic compounds. Quad Oa, which focused on trying to control methane, does the remaining pollutants that are still being emitted, does that meet this threshold of significance?
Then how we get there and what it actually means will determine whether or not Quad Oa continues to exist in the future.
Russel: To me, this kind of thing is fascinating. I guess that makes me a nerd. I understand how the…Typically, I’m tracking what’s going on with PHMSA, so the pipeline regulatory authority.
I think more people are interested in environmental policy than are necessarily interested in pipeline policy. Would you say that’s true? Obviously, there’s an overlap there, but would you say that’s true?
Mandy: Yeah, I think so. I’m just speculating, because I haven’t thought too deeply about it. I, like you, am a nerd in this bubble of environmental interests and the interaction between energy and environment.
Environmental policy affects everything. People are very interested in how a new facility, whether it’s an oil and gas pipeline operation, some other piece of it, or a manufacturing facility, they’re really interested in, this new entity is coming in, or this existing entity is being expanded.
Or they’re changing how they get their fuel. How does that impact me, my community, and the people living around this area? I think that people are drawn to that in a lot of different ways and for a lot of different reasons.
Russel: Right. We all live in the environment, so it’s closer to home.
Mandy: Absolutely. Whereas a lot of people see pipelines, but they don’t necessarily think about how that impacts them on a day-to-day basis.
Russel: Right, exactly. I want to explore this a little bit with you, because I’ve actually had a number of people reach out to me, wanting to get on the Pipeliners Podcast for similar communications, where they’re trying to, I would say, advocate on behalf of the pipeline industry in particular.
Tell us a little bit about what is the Energy 45 Fund, and what does it mean to move out of D.C. and focus on communications?
Mandy: First, the Energy 45, from a structural sense, it’s a 501(c)(4), which means it’s a non-profit, but it’s mostly educational. Then it can be political. I haven’t gotten political yet, meaning I could get involved in races one way or another.
I haven’t done that, but I have the flexibility to do so. It’s a non-profit. I like to say it’s a pro-Trump non-profit, because a lot of what I’m doing is trying to explain why the President’s approach to energy, the environment, and how that’s lent itself to the current state of the economy is all very good, and something that we should be proud of and celebrate. Then figure out, how do we continue to move the ball forward in each one of those categories?
It’s a pro-Trump non-profit, where I’m going out and I get on FOX and FOX Business. I write op-eds. I make video shorts over at the Daily Caller. I go on conservative YouTube channels, like One America News Network. Anyone who will listen to me or wants to talk about these issues, I will go on and explain either the regulatory specifics of something, or just defend the administration, in general.
The biggest shift is, I went from being inside the agency having meetings with engineers, scientists, and experts figuring out how to shape these regulatory actions going forward to now, I am going around to different news stations, studios, and whatnot, having the same type of conversations, but in a way that everyone can understand it.
A much simpler way, but really, just out there, trying to push a positive message. One of the biggest problems to me in the energy and environment space is there’s not a lot of room to be honest about where we really are.
I think for people who constructively want to engage on these issues, and seriously move the ball forward in terms of cleaning up the air and cleaning up the water, beyond where they already are, we have to be honest about the current state, how we got here, and what worked and what didn’t.
I think the only way to get past the political entrenchments that I keep referencing is to have an honest conversation and to recognize good work when it’s good work, whether done by a Republican or a Democrat.
Russel: Whether done by the public, done by an operator, or done by an agency. I think that’s one of the things that’s really difficult. This is difficult even when there’s not political involvement. Really understanding clearly, where are we at? How did we get here? What worked and what didn’t work?
That’s all, quality systems and continuous improvement, are all grounded in those basic ideas. They’re very difficult to get to. It requires a certain culture, a certain relationship, a certain level of trust. It’s hard to get there.
Certainly, I admire your interest in doing something to at least try and create thoughtful communication and thoughtful engagement.
Mandy: Thank you. You actually said something that, it really goes to the heart of one of the ways that we approach…When I say we, the Trump Administration under Pruitt and then Administrator Wheeler, it’s how we approach the regulatory role.
It was this relationship with the people in the field, the regulated community, the operators, the folks who know the ins and outs of all the bolts and compressors, because they are charged with making sure that it works efficiently and safely every single day.
One of the big centerpieces of our approach to this is ensuring we have a robust and good relationship between the agency and the operators in the field. The only way to improve the understanding of the agency is to engage with the people who are in the field actually doing it.
To me, if you ask me, I think that’s 101 of how to be successful in any application, especially policymaking and environmental law, implementing environmental law, but that was such a controversial piece.
We get painted as a shill for industry or having this cozy relationship because of some other nefarious reason. What motivated us, and what continues to motivate the agency, is to ensure that, as we were doing these massive regulatory actions that have costs — they have not only a monetary cost, but time and then structural thought — how do you go to your engineers and tell them to figure out how to make this work without killing or eradicating the whole business, or substantially one way or another?
It’s really important for the agency experts to have that working relationship, where they can call up one of the field operators and just ask, “Hey, this is how we’re looking at it. This is how we would apply it. From your perspective, would that work?”
I think that’s critical in any administrative action, but especially in this space of implementing environmental regulations.
Russel: I think that’s right. I think also, one of the things that I think PHMSA does a good job of is they engage all the stakeholders in the process. Some of those stakeholders are organizations that are purely in place to represent the public.
Most notably there is the Pipeline Safety Trust, which is an organization that was founded by the local community in Bellingham, Washington, after a major pipeline incident. Those folks, they’re passionate and they’re thoughtful, but they’re there to represent the public and say, “Hey, the standard ought to be…”
Regardless of what you’re capable of doing, the standard ought to be this, because that’s the standard that makes sense for the public. That’s the other part of this whole thing, is we’re operating in a public trust.
Mandy: That’s exactly right.
Russel: There’s a fiduciary responsibility there, not just for the operators, but also for the agencies, the regulators, and for the public itself. There’s a fiduciary responsibility. I think, if I were going to give Mandy some advice or input, this would be it.
For those that are listening, y’all can all take this with a grain of salt, because I really don’t know a thing about what I’m talking about.
Mandy: That’s always the best advice.
Russel: I do know about my opinion. In fact, I’m an expert on that. What I would say is that, to the extent you can get everybody on the same page about, look, we’re operating in a public trust. It is our responsibility to understand to the best of our ability what’s factually true, and to work to improve things for everyone involved.
Sometimes, in the adversarial nature of the 24/7 news cycle, it’s all about the trash talk, who wins the point of the day, and not necessarily about are we improving the situation for everyone?
Mandy: You’re exactly right. I’ll talk about it here. I haven’t done it yet, but I’m working through Energy 45 on developing — I’m just going to call it a campaign. Not a political campaign, but just a collective body of work.
I’m thinking about, this is patent pending working title, but the “Let’s Be Honest” campaign. To do exactly what you just laid out, which is to take an issue, a thought, or a statement, and make it short and sweet.
People want to understand something in three points or less. Just to have the “Let’s Be Honest” campaign, a trend to move away from extremism, environmental extremism, and have an honest conversation about where we are today, and how we can continue to get better for the future.
To do exactly that, just have three points on, “Let’s be honest about where we are today on clean air,” and then lay out some three key points, and just go from there. I think you’re exactly right. It’s important for us all to understand that we have such a precious resource that we can use to the betterment of society as a whole.
We have a responsibility to ensure that we don’t trade off the ability of future generations to enjoy it in the same way we do. That’s really difficult. It’s a really difficult thing to do in terms of policymaking and how you actually do it from an engineering perspective.
We have to have an honest conversation in order to move the ball forward.
Russel: I think emotionalism in an argument is valuable as long as it’s not the only thing in the argument. The emotion helps you understand where people are at, but ultimately, there’s got to be an intellectual side to it as well.
Mandy: You’re exactly right.
Russel: It requires both. Unfortunately, the emotional side gets more eyeballs onto a TV screen.
Mandy: That’s true, that’s true.
Russel: We probably shouldn’t talk anymore, because then I’ll start talking about my opinion, and we’ll bore everybody. Mandy, this has been awesome. I’m certainly learning a lot. I think I have a better understanding of some of the issues on the environmental side.
I certainly think I have a little bit better sensitivity as to why they’re difficult, why this kind of policy’s challenging to engage and do effectively. I appreciate you taking the time to be with us this morning. Probably I’d have you back, and help us, help me and others get educated a bit more about what’s going on around this whole environmental policy issue.
Mandy: Thank you very much for having me. I’m happy to come on anytime. The one truth of the matter is that these issues will continue to come up in a lot of different applications. I’m always happy to chat, and just thanks again for the opportunity.
Russel: Thanks for joining us, and look forward to talking to you soon.
Russel: I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Mandy Gunasekara. Just a reminder before you go. You should register to win our customized Pipeliners Podcast Yeti tumbler. Simply visit pipelinerspodcast.com/win to enter yourself in the drawing.
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Russel: If you have ideas, questions, or topics you’d be interested in, please let us know on the Contact Us page at pipelinerspodcast.com, or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords