1. Joshua B. Epel, Esq. Duke Energy Field Services, LP August 25, 2005
The Private Sector: How we are currently involved with the States and Tribes
Joshua B. Epel, Esq.
Duke Energy Field Services, LP
August 25, 2005

2. DEFS Midstream Operations
Legend #
DEFS Plants
DEFS Gathering Area

3. DEFS Profile DEFS operates in 3 WRAP states and 4 non-WRAP states.
DEFS fleet deploys 2.1MM horsepower at 850 facilities (2,500 engines).
DEFS utilizes 41 amine units in 6 states to remove impurities, including CO2.
DEFS manages about 58,000 miles of pipelines, all containing methane.

4. DEFS interacts with Multiple State Agencies
8 separate state agencies on air permitting issues (and compliance with EPA regulations)
11 Agencies on emergency venting and flaring
(OCD, TRRC, etc.)
6 Departments and the OPS on pipeline compliance

5. DEFS must address compliance obligations consistently
Title V Permitting
Since 2001, DEFS has reduced the number of Title V facilities from 330 to 150—primarily through installation of catalytic converters on hundreds of engines.
DEFS has controlled or is managing “flash” emissions at all of its facilities.
DEFS is working with all state agencies to ensure the accuracy of its LDAR program.
3rd bullet-VOCs

6. Compliance obligations, cont’d
Meeting these obligations requires training hundreds of employees in programs and processes.
Meeting compliance obligations requires the evaluation and re-engineering at hundreds of facilities.

7. Innovative Approaches-CO2 Sequestration
DEFS installed an acid gas injection well at its Artesia facility - with mixed results.
DEFS is permitting another acid gas injection
well - requiring interaction with multiple state agencies.

8. A Cooperative Model
A State, Regional, or Federal program should promote innovation—either through direct incentives or removing regulatory barriers.
Identify CO2 injection formations and develop a CO2 reduction permit where facilities can use the formation when siting facilities.
State financial incentives to promote geological sequestration opportunities.

9. Conclusion
Assume few of you have sympathy for big oil talking about fiscal constraint in this environment.
Remember very 1st slide, DEFS operates in 3 WRAP and r non-WRAP states.
Each strategy must be tailored for mid-stream industry-may be methane CO2.
How do we proceed without being punished?
DEFS reduces now, simply get a lower baseline
DEFS complies with non-uniform regulations-do our competitors get an advantage?