PHMSA 22-250507
BREITBURN ENERGY CO2 — Integrity Assurance Notification
START/END POINT DELAY ONSHOREMaverick Natural Resources (Maverick) is an independent energy producer. Maverick’s oil and gas properties are characterized by mature, stable production with proved reserve life indices averaging more than ten years. Many of Maverick’s fields have exceptionally long production histories, and some fields date back to the 1800s. Maverick operates its properties through its wholly owned subsidiaries, Unbridled Resources and Breitburn Operating, and produces hydrocarbons from onshore basins throughout the United States. As a result, the natural gas gathering rule has significant impacts on its operations. Pursuant to 192.8(b)(2), Maverick is contacting the Pipeline Materials and Safety Administration and the State(s) of Texas, Oklahoma, New Mexico, Arkansas, Louisiana, Alabama, Florida, and Wyoming. This notification shall serve as Maverick’s official request for an alternative deadline for the identification of the beginning and end points as required under 192.8(b) for the following reasons: Maverick operates more than 4500-miles of pipelines collecting gas from more than 14,000 wells in 8 states. These production flow and gathering lines are overwhelming rural and have not historically been subject to regulatory jurisdiction or requirements. Maverick is requesting an alternative deadline to complete the requirements of 192.8(b)(2) for three primary reasons. First, the requirement to classify the beginning and endpoints of all gathering lines was not included in the initial rulemaking. This provision alone is a significant requirement that has not been evaluated from a regulatory impact statement. The provision has incredible impacts to every operator, in terms of the financial and personnel resources required, that have not been considered.#