Bay Area Air Board emissions plan draws response from Valero

Repost from The Benicia Herald
[Editor: The Benicia Herald is one of very few news outlets to cover the Bay Area Air Quality Management District’s far-reaching  and highly significant December 17 initiative on refinery emissions.  The first Herald article just covered the facts, and oddly, is not posted on the Herald’s website.  As a follow-up to that story, our local newspaper either sought out comments from the Refinery or responded to Valero’s overture, not sure which.  Either way, we were treated on Christmas Eve to a front page Valero Benicia promotion of its wondrous efforts to control its emissions, and the supposedly small part Bay Area refineries play in contributing to greenhouse gases.  Note especially Valero’s resolve to “participate in any new rulemaking to ensure rules are reasonable and cost effective.”   Reasonable rules would surely protect community health and safety, no?  And according to whose costs should regulatory effectiveness be weighed?   For other reports on the Air District initiative, see The Contra Costa Times, and the Oil & Gas Journal. See also primary documents: BAAQMD 12/17 agenda, (p. 73), and  REPORT: Bay Area Refinery Emissions Reduction Strategy (PDF) .  – RS]

Emissions plan draws response from Valero

Refinery official: ‘Proud’ to contribute to better air quality
By Donna Beth Weilenman, December 24, 2014

The Bay Area Air Quality Management District is hoping its new five-component strategy will reduce emissions from refineries in it geographic area.

The district’s Refinery Emissions Reduction Resolution, approved Oct. 15, sets a goal of 20-percent reduction in refinery emissions — or as much as is feasible — during the next five years.

The Bay Area Air Quality Management District is the regional agency responsible for protecting air quality in the nine-county Bay Area.

The announced strategy would show the Air District how to achieve that goal.

“Our new Refinery Emissions Reduction Strategy continues and reaffirms the air district’s commitment to significantly decrease harmful air pollution in our communities,” said Jack Broadbent, the district’s executive officer.

“This strategy will ensure that refineries are taking the strongest steps to cut emissions and minimize their health impacts on neighboring residents and the region as a whole.”

But refineries are just one industry that contributes to the San Francisco Bay Area’s air pollution and greenhouse gas emissions, according to an official at Valero Benicia Refinery.

“By the district’s own data, Bay Area refineries make up only a small segment of overall emissions in the Bay Area air shed,” said Chris Howe, the refinery’s director of health, safety, environment and government affairs.

“These emissions have continued to decline over the last two decades,” Howe said, data which the Air District also acknowledged.

“We are proud of the significant contributions our refinery has made and will continue to make to improve air quality, especially with the installation of our flue gas scrubber in 2011,” Howe said, citing a major component of the Valero Improvement Project.

In addition, he said, “We will continue to participate in any new rulemaking to ensure rules are reasonable and cost effective when weighed against the many options the district has to regulate emissions in our air basin.”

Broadbent said the Air District’s announced strategy sets overall goals of a 20-percent reduction in both criteria pollutants from refineries and in health risks to area communities, both within the next five years. That is the strategy’s first component.

To do this, the Air District plans to investigate significant sources of those pollutants at the refineries themselves, and to examine a variety of additional pollution controls at those sources, he said. That’s the second component.

He said this would be done under the district’s focused Best Available Retrofit Control Technology program.

“Rulemaking is already under way to reduce sulfur dioxide from coke calciners and particulate matter from catalytic cracking units,” Broadbent said.

“Several other rules to reduce refinery emissions will be developed in 2015.”

The strategy’s third component would be the Air District’s approach to reduce health risks from toxic air pollution, Broadbent said.

He said it would begin with requirements to reduce toxic emissions from such refinery sources as cooling towers and coking units.

Site-wide health risks would be assessed, and sources for further emissions controls would be identified, with an eye toward health benefits, he said.

A fourth component would be evaluation of greenhouse gas emissions at the refineries and their reductions as a result of the cap-and-trade system put in place under Assembly Bill 32.

That bill, signed into law Sept. 27, 2006, requires the California Air Resources Board (CARB) to develop regulations and market mechanisms to reduce California’s greenhouse gas emissions to 1990 levels by the year 2020.

CARB adopted a cap-and-trade program Dec. 17, 2010, allowing some emitters to buy credits at quarterly auctions for additional emissions.

Under the Air District’s strategy, refinery performance would be compared to third-party standards for best practices, with analysis of potential further opportunities for reductions, Broadbent said.

The fifth component concerns continuous improvement in emission reductions, for which refinery operators would be required on a periodic basis to evaluate the sources of most of their emissions to determine if more controls are needed.

Broadbent said the Air District would develop its package of rules in the coming year, and would be working with members of the public as well as refinery industry representatives to make any modifications in the proposed rules and to use the strategy to reach those stated goals.

In addition, the Air District will prepare its Petroleum Refining Emissions Tracking rule that requires updated health risk assessments, additional fence-line and neighborhood monitoring capacity and the compiling of an annual emissions inventory.

Simultaneously, the Air District will write a companion rule to set emissions thresholds and mitigate potential increases at refineries, Broadbent said.

Those rules are expected to be sent to the Air District’s board for adoption in 2015.

The San Francisco Bay Area’s five major oil refineries, including Valero Benicia Refinery, produce air pollution and greenhouse gases in the region, Broadbent said, and “these are already subject to more than 20 specific Air District regulations and programs, and their overall emissions have been steadily decreasing.”

The Air District’s website is www.baaqmd.gov.

Richard Heinberg report: The Oil Price Crash of 2014

Repost from RichardHeinberg.com

The Oil Price Crash of 2014

Museletter 271, December 23, 2014

Oil prices have fallen by half since late June. This is a significant development for the oil industry and for the global economy, though no one knows exactly how either the industry or the economy will respond in the long run. Since it’s almost the end of the year, perhaps this is a good time to stop and ask: (1) Why is this happening? (2) Who wins and who loses over the short term?, and (3) What will be the impacts on oil production in 2015?

1. Why is this happening?

Euan Mearns does a good job of explaining the oil price crash here. Briefly, demand for oil is softening (notably in China, Japan, and Europe) because economic growth is faltering. Meanwhile, the US is importing less petroleum because domestic supplies are increasing—almost entirely due to the frantic pace of drilling in “tight” oil fields in North Dakota and Texas, using hydrofracturing and horizontal drilling technologies—while demand has leveled off.

Usually when there is a mismatch between supply and demand in the global crude market, it is up to Saudi Arabia—the world’s top exporter—to ramp production up or down in order to stabilize prices. But this time the Saudis have refused to cut back on production and have instead unilaterally cut prices to customers in Asia, evidently because the Arabian royals want prices low. There is speculation that the Saudis wish to punish Russia and Iran for their involvement in Syria and Iraq. Low prices have the added benefit (to Riyadh) of shaking at least some high-cost tight oil, deepwater, and tar sands producers in North America out of the market, thus enhancing Saudi market share.

The media frame this situation as an oil “glut,” but it’s important to recall the bigger picture: world production of conventional oil (excluding natural gas liquids, tar sands, deepwater, and tight oil) stopped growing in 2005, and has actually declined a bit since then. Nearly all supply growth has come from more costly (and more environmentally ruinous) resources such as tight oil and tar sands. Consequently, oil prices have been very high during this period (with the exception of the deepest, darkest months of the Great Recession). Even at their current depressed level of $55 to $60, petroleum prices are still above the International Energy Agency’s high-price scenario for this period contained in forecasts issued a decade ago.

Part of the reason has to do with the fact that costs of exploration and production within the industry have risen dramatically (early this year Steve Kopits of the energy market analytic firm Douglas-Westwood estimated that costs were rising at nearly 11 percent annually).

In short, during this past decade the oil industry has entered a new regime of steeper production costs, slower supply growth, declining resource quality, and higher prices. That all-important context is largely absent from most news stories about the price plunge, but without it recent events are unintelligible. If the current oil market can be characterized as being in a state of  “glut,” that simply means that at this moment, and at this price, there are more willing sellers than buyers; it shouldn’t be taken as a fundamental or long-term indication of resource abundance.

2. Who wins and loses, short-term?

Gail Tverberg does a great job of teasing apart the likely consequences of the oil price slump here. For the US, there will be some tangible benefits from falling gasoline prices: motorists now have more money in their pockets to spend on Christmas gifts. However, there are also perils to the price plunge, and the longer prices remain low, the higher the risk. For the past five years, tight oil and shale gas have been significant drivers of growth in the American economy, adding $300 to 400 billion annually to GDP. States with active shale plays have seen a significant increase of jobs while the rest of the nation has merely sputtered along.

The shale boom seems to have resulted from a combination of high petroleum prices and easy financing: with the Fed keeping interest rates near zero, scores of small oil and gas companies were able to take on enormous amounts of debt so as to pay for the purchase of drilling leases, the rental of rigs, and the expensive process of fracking. This was a tenuous business even in good times, with many companies subsisting on re-sale of leases and creative financing, while failing to show a clear profit on sales of product. Now, if prices remain low, most of these companies will cut back on drilling and some will disappear altogether.

The price rout is hitting Russia quicker and harder than perhaps any other nation. That country is (in most months) the world’s biggest producer, and oil and gas provide its main sources of income. As a result of the price crash and US-imposed economic sanctions, the ruble has cratered. Over the short term, Russia’s oil and gas companies are somewhat cushioned from impact: they earn high-value US dollars from sales of their products while paying their expenses in rubles that have lost roughly half their value (compared to the dollar) in the past five months. But for the average Russian and for the national government, these are tough times.

There is at least a possibility that the oil price crash has important geopolitical significance. The US and Russia are engaged in what can only be called low-level warfare over Ukraine: Moscow resents what it sees as efforts to wrest that country from its orbit and to surround Russia with NATO bases; Washington, meanwhile, would like to alienate Europe from Russia, thereby heading off long-term economic integration across Eurasia (which, if it were to transpire, would undermine America’s “sole superpower” status; see discussion here); Washington also sees Russia’s annexation of Crimea as violating international accords. Some argue that the oil price rout resulted from Washington talking Saudi Arabia into flooding the market so as to hammer Russia’s economy, thereby neutralizing Moscow’s resistance to NATO encirclement (albeit at the price of short-term losses for the US tight oil industry). Russia has recently cemented closer energy and economic ties with China, perhaps partly in response; in view of this latter development, the Saudis’ decision to sell oil to China at a discount could be explained as yet another attempt by Washington (via its OPEC proxy) to avert Eurasian economic integration.

Other oil exporting nations with a high-price break-even point—notably Venezuela and Iran, also on Washington’s enemies list—are likewise experiencing the price crash as economic catastrophe. But the pain is widely spread: Nigeria has had to redraw its government budget for next year, and North Sea oil production is nearing a point of collapse.

Events are unfolding very quickly, and economic and geopolitical pressures are building. Historically, circumstances like these have sometimes led to major open conflicts, though all-out war between the US and Russia remains unthinkable due to the nuclear deterrents that both nations possess.

If there are indeed elements of US-led geopolitical intrigue at work here (and admittedly this is largely speculation), they carry a serious risk of economic blowback: the oil price plunge appears to be bursting the bubble in high-yield, energy-related junk bonds that, along with rising oil production, helped fuel the American economic “recovery,” and it could result not just in layoffs throughout the energy industry but a contagion of fear in the banking sector. Thus the ultimate consequences of the price crash could include a global financial panic (John Michael Greer makes that case persuasively and, as always, quite entertainingly), though it is too soon to consider this as anything more than a possibility.

3. What will be the impacts for oil production?

There’s actually some good news for the oil industry in all of this: costs of production will almost certainly decline during the next few months. Companies will cut expenses wherever they can (watch out, middle-level managers!). As drilling rigs are idled, rental costs for rigs will fall. Since the price of oil is an ingredient in the price of just about everything else, cheaper oil will reduce the costs of logistics and oil transport by rail and tanker. Producers will defer investments. Companies will focus only on the most productive, lowest-cost drilling locations, and this will again lower averaged industry costs. In short order, the industry will be advertising itself to investors as newly lean and mean. But the main underlying reason production costs were rising during the past decade—declining resource quality as older conventional oil reservoirs dry up—hasn’t gone away. And those most productive, lowest-cost drilling locations (also known as “sweet spots”) are limited in size and number.

The industry is putting on a brave face, and for good reason. Companies in the shale patch need to look profitable in order to keep the value of their bonds from evaporating. Major oil companies largely stayed clear of involvement in the tight oil boom; nevertheless, low prices will force them to cut back on upstream investment as well. Drilling will not cease; it will merely contract (the number of new US oil and gas well permits issued in November fell by 40 percent from the previous month). Many companies have no choice but to continue pursuing projects to which they are already financially committed, so we won’t see substantial production declines for several months. Production from Canada’s tar sands will probably continue at its current pace, but will not expand since new projects will require an oil price at or higher than the current level in order to break even.

As analysis by David Hughes of Post Carbon Institute shows, even without the price crash production in the Bakken and Eagle Ford plays would have been expected to peak and begin a sharp decline within the next two or three years. The price crash can only hasten that inevitable inflection point.

How much and how fast will world oil production fall? Euan Mearns offers three scenarios; in the most likely of these (in his opinion) world production capacity will contract by about two million barrels per day over the next two years as a result of the price collapse.

We may be witnessing one of history’s little ironies: the historic commencement of an inevitable, overall, persistent decline of world liquid fuels production may be ushered in not by skyrocketing oil prices such as we saw in the 1970s or in 2008, but by a price crash that at least some pundits are spinning as the death of “peak oil.” Meanwhile, the economic and geopolitical perils of the unfolding oil price rout make expectations of business-as-usual for 2015 ring rather hollow.

Another city says no to hazardous rail tank cars

Repost from The Sacramento Bee
[Editor: Significant quote: “…city officials said Union Pacific has been parking a dozen ethanol train cars at times on side tracks, some near the Ironworks Lofts housing area, where they wait until there is room to shuttle them onto the Buckeye property….City officials say UP frequently moves train cars back and forth across 15th Street at Jefferson Boulevard to make room in its yard.”  Does this sound like something we can expect on nearby rails and street crossings outside of Valero if the City approves crude-by-rail?  – RS]

West Sacramento says no to ethanol trains

By Tony Bizjak, 12/21/2014
A tanker truck is filled from railway cars containing crude oil on railroad tracks in McClellan Park in North Highlands on Wednesday, March 19, 2014. Several crude oil and ethanol trains have been involved in crashes and explosions nationally in recent years, prompting concerns in cities along rail lines.
A tanker truck is filled from railway cars containing crude oil on railroad tracks in McClellan Park in North Highlands on Wednesday, March 19, 2014. Several crude oil and ethanol trains have been involved in crashes and explosions nationally in recent years, prompting concerns in cities along rail lines. | Randall Benton

The city of West Sacramento and a Texas-based gasoline company are battling over whether it’s riskier to ship large amounts of ethanol through city streets on trains or on tanker trucks – a dispute that last week spilled into court.

Every day, six train cars full of the fuel additive arrive at a mixing terminal on West Sacramento’s riverfront south of Highway 50.

Saying the city is uncomfortable with trains, some of which sit unattended with their volatile cargo outside the terminal for days, the West Sacramento City Council refused on Wednesday to renew the company’s rail transport permit. The company, Buckeye Terminals, mixes the ethanol with gasoline at its South River Road plant for sale at Northern California gas stations.

Councilman Bill Kristoff noted that the train cars often park in the city’s Bridge District near a residential area, and that city officials are not allowed to know exactly what the cars carry. “I don’t understand the rail business well enough to know why all of these cars have to stay in our community for as long as they stay, and at the same time we don’t get to know what’s in them,” he said. “That is sort of alarming to me.”

Several crude oil and ethanol trains have been involved in crashes and explosions nationally in recent years, prompting concerns in cities along rail lines.

Buckeye officials quickly fired back, suing the city and contending that the permit denial creates a greater risk to the public because it likely will force the company to quadruple the number of tanker truck deliveries it receives daily at the plant, as a replacement for the rail deliveries.

In the lawsuit, filed Friday in Yolo Superior Court, the company accuses the city of failing to conduct adequate traffic studies in the new development areas along South River Road. Those studies, if done, would show safety risks where ethanol trucks mix with traffic, said Braiden Chadwick, a Buckeye attorney.

“The last thing anyone wants to see is a car vs. tanker truck (crash); that is a bad combo,” Chadwick said. “It is just a recipe for disaster.”

City officials declined to comment on the lawsuit, saying they are reviewing it.

West Sacramento’s decision to stop the ethanol trains represents another step in a decades-long effort by city leaders to transition the old industrial waterfront south of the Raley Field ballpark into modern live-work neighborhoods with condominiums, row houses, offices, hotels, restaurants and entertainment venues. The city previously ushered industrial companies out of the Bridge District around Raley Field and shut down a rail line along the waterfront to clear the site for redevelopment.

The city has accelerated those efforts in the Pioneer Bluff area near the Buckeye facility in recent months. A row of unused cement company silos is being torn down on the riverfront. The city has shut its sewer treatment plant. It also is planning to close its corporation yard to open space for waterfront development. The city opened a new bridge this month to connect South River Road to the Southport area, bringing more vehicles past the Buckeye site.

Although the Buckeye facility does not fit West Sacramento’s plans for the area, the permit refusal “is absolutely not intended to try to drive Buckeye out of the district,” Mayor Christopher Cabaldon said. Buckeye is one of several fuel-related industries still operating in the area south of Highway 50.

“The existing Buckeye facility is absolutely welcome to remain and operate at its existing site to the extent that it is complying with the terms of its permits (and) that it is not invading the public right of way,” Cabaldon said.

Buckeye’s attorney disagreed, saying the city’s actions suggest it is trying to squeeze the company out. “The confluence of events lead us to that conclusion,” Chadwick said. “It looks like they are trying to make operations of the Buckeye facility more difficult.”

Buckeye’s rail shipment permit for ethanol expires at the end of this month. The company had sought a permit to continue train deliveries of six cars a day through 2019. The site has been an ethanol station since 2002, when the city agreed to the first of a series of limited permits to allow a previous terminal owner to receive rail shipments of the additive. Buckeye bought the facility a few years ago. The company mixes the ethanol with gasoline that is piped to West Sacramento from the Bay Area.

The dispute is part of a growing national debate over the safety of rail transport of flammable commodities. Federal transportation officials are contemplating additional safety regulations for train transports after several explosive crashes in recent years. The federal focus has been on crude oil shipments to refineries. But safety experts say ethanol trains also should be subject to more requirements, citing crashes that caused explosions and fires.

Testifying this week before the West Sacramento City Council, Fire Chief Rick Martinez expressed a preference for tanker truck ethanol shipments over rail shipments, acknowledging both have risks.

Martinez noted that the city has almost no legal control over rail operations, so it cannot prohibit trains with hazardous commodities from parking overnight next to residential areas. The federal government pre-empts city regulation of rail activities. But, Martinez said, the city can manage the risk of tanker truck shipments, controlling where the trucks drive, and at what speed, and can prohibit those trucks from sitting unattended overnight.

Martinez and other city officials said Union Pacific has been parking a dozen ethanol train cars at times on side tracks, some near the Ironworks Lofts housing area, where they wait until there is room to shuttle them onto the Buckeye property. The parking area runs from Raley Field under the Pioneer Bridge to 15th Street. City officials say UP frequently moves train cars back and forth across 15th Street at Jefferson Boulevard to make room in its yard.

Martinez said his department also has noted ethanol train cars parked along Jefferson Boulevard.

“This practice puts the adjacent residential neighborhood at increased risk from a hazardous materials incident,” Martinez said in a recent memo. “By removing the ethanol rail cars from their current location, the risk potential is significantly reduced.”

Buckeye attorney Chadwick contends that increasing the number of tanker trucks making daily ethanol deliveries is a risky move. He said the trucks would have to make left turns on South River Road to get to the plant, and would have to deal with more traffic as the city turns the Pioneer Bluff area and the Bridge District into populated communities.

Buckeye officials say they currently receive ethanol on two to three tanker trucks a day, in addition to the six rail cars. A city staff report suggests as many as four trucks may arrive on weekdays. The city analysis says Buckeye could bring in nine additional tanker trucks daily to its plant after rail shipments are halted this month.

Chadwick said that number is low, and that his company estimates 15 or more additional tanker trucks would be needed daily. He said he did not know what route the trucks would use to get to West Sacramento, but said they likely would arrive via area freeways.

The lawsuit, he said, maintains the city failed to adequately study how much extra traffic would use South River Road, and how that traffic would mix with daily ethanol trucks trying to make left turns.

“Buckeye views that lives might be at risk here,” Chadwick said. “Help us keep the facility safe, because we are not going anywhere.”

Industry perspective: BAAQMD advances plan to reduce refinery emissions

Repost from Oil & Gas Journal
[Editor: Good summary of details in the BAAQMD’s Dec. 17 vote.  See also primary documents: BAAQMD 12/17 agenda, (p. 73), and  REPORT: Bay Area Refinery Emissions Reduction Strategy (PDF)  – RS]

California Bay Area advances plan for enhanced refinery regulations

By Robert Brelsford, OGJ Downstream Technology Editor, 12/19/2014

California’s Bay Area Air Quality Management District (BAAQMD), the public agency responsible for regulating stationary sources of air pollution in the nine counties that surround San Francisco Bay, is moving forward with its plan to impose further emissions cuts on area refiners within the next 5 years.

BAAQMD’s board of directors unanimously voted on Dec. 17 to adopt the proposed emissions reduction strategy, which sets a goal of reducing refinery emissions by 20%, or as much as feasible, by 2020.

Adoption of the heightened emissions-control strategy follows BAAQMD’s October resolution (OGJ Online, Oct. 21, 2014) directing its staff to determine the best way to decrease emissions from area refineries by evaluating a range of approaches against a variety of factors such as reductions of “criteria pollutants” (pollutants for which air quality standards have been established), toxics,  and greenhouse gases (GHGs), as well as impacts on neighboring communities, the agency said in a statement.

“Our new refinery emissions reduction strategy continues and reaffirms [BAAQMD’s] commitment to significantly decrease harmful air pollution in our communities,” said Jack Broadbent, BAAQMD’s executive officer.

“This strategy will ensure that refineries are taking the strongest steps to cut emissions and minimize their health impacts on neighboring residents and the region as a whole,” according to Broadbent.

Implementation of the emissions reduction strategy will involve ongoing work with community and industry participants during 2015 to develop and refine a package of proposed associated rules, BAAQMD said.

As part of the approved strategy, the agency said it will continue preparation of its proposed Petroleum Refining Emissions Tracking Rule (PRET), which would require refiners to provide updated health risk assessments (HRAs), install additional fence-line and neighborhood monitoring capacity, and compile annual emission inventories.

Preparation of a “companion rule” to PRET also remains under way, according to BAAQMD.

Earlier billed by the industry as another iteration of the “baseline rule” removed from a previous draft version of PRET amid a series of legal challenges under California law, the proposed “companion rule” would set emissions thresholds as well as mitigate potential emissions increases from area refineries.

The agency plans to present a final set of proposed rules to BAAQMD’s board of directors sometime in 2015.

While Bay Area’s five refiners plan to continue actively collaborating with BAAQMD on its emissions-reduction strategy, the agency’s goals may be a bit too ambitious within the proposed timeframe, according to the Western States Petroleum Association (WSPA).

“The Bay Area refineries will constructively participate in the strategy’s rule making,” Guy Bjerke, WSPA’s Bay Area region manager, told OGJ.

“Our main concern with the strategy is the 20% reduction by 2020 goal which, given historic reductions over the past 10 years, are likely unachievable and impractical in just 5 years,” Bjerke said.

BAAQMD’s proposed strategy

To achieve its overall goal of a 20% emissions reduction from refineries alongside a 20% reduction in health risks to local communities over the next 5 years, the proposed strategy includes the following components:

• Reduction of criteria pollutants. Under a focused best available retrofit control technology (BARCT) program, BAAQMD will investigate  significant sources at refineries and pursue a variety of additional pollution controls at these sources. Rulemaking is already underway to reduce sulfur dioxide from coke calciners and particulate matter from catalytic cracking units. Several other rules to reduce refinery emissions also will be developed in 2015.

• Reduction of health risks from toxic air pollution. This approach will begin with requirements to reduce toxic emissions from key refinery sources such as cooling towers and coking units. The focused toxics approach will also include site-wide HRAs and the identification of sources for further emission controls, using health benefits as an important evaluative tool.

• Evaluation of GHG emissions. Under this approach, BAAQMD would track emission reductions at refineries incurred as a result of the cap-and-trade system under California’s AB 32 climate law, which requires the state to reduce its GHG emissions to 1990 levels by 2020. Refinery performance would be compared to third-party standards for best practices, with analysis of potential further opportunities for reductions.

• Continuous improvement. To ensure continuous improvement in emission reductions, refiners will be required to periodically evaluate the sources of the majority of their emissions in order to determine if additional pollution controls are needed.

BAAQMD previously acknowledged that overall emissions from the region’s five refineries, which already are subject to more than 20 specific agency regulations and programs, have been steadily decreasing.