Grandfather Legislation: Update

I attended a TXOGA pipeline committee meeting yesterday and the Grandfather
legislation was discussed in detail. The following information is in addition
to the previous message on this legislation:

Several members could not agree on whether the option being offered by TNRCC
of using old standard exemptions to "authorize" grandfathered emission
sources would be pulled off the table on September 1, 2001. The general
consensus is that companies should complete the process of using the old
exemptions by September 1 in case TNRCC does not allow this option anymore;

Although the legislation allows 0 to 20% reductions on pipeline engines in
West Texas, TNRCC has indicated that they will not require reductions in West
Texas, except for "huge emitters". No one knows what they mean by huge
emitters;

TNRCC is required to reduce compressor engine NOx emissions by 50% in East
Texas, but MAY require 50% VOC reductions in East Texas. No one has heard
whether TNRCC will require VOC reductions. VOC reductions on a 2-cycle
engine, especially on a Cooper engine with good combustion characteristics,
could be problematic;

The TXOGA Pipeline committee will take the lead on responding to the
regulations that are developed due to this legislation. I will certainly
participate in this process.

Marc