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Climate Change Hero

Climate Change Blog

  • 23
  • February
  • 2016


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Aggregation Spells Trouble For Pennsylvania Oil And Gas Companies

V&E partner George Hopkins and V&E counsel Andrew Stewart recently wrote an article published by Law360 on a ruling in Pennsylvania that could require more strict permitting requirements for oil and gas sources. The decision allowed the state’s environmental agency to combine the operations from one upstream well pad with the operations of a nearby midstream compressor station operated by a separate entity for air permitting purposes. This decision could result in additional costs and delays for oil and gas companies doing business in the state:

Many individual activities in the upstream and midstream oil and gas industry create only small amounts of air emissions, below the thresholds to trigger certain air permit requirements. However, a recent ruling by the Pennsylvania Environmental Hearing Board, National Fuel Gas Midstream Corp. v. Pennsylvania Department of Environmental Protection (NFG), incorrectly applied in every respect an accepted test for determining whether multiple sources should be considered a single source under the Clean Air Act, leading to the aggregation of well pad and midstream operations. As a result, oil and gas sources in Pennsylvania may face major source permitting requirements under a great many previously unexpected circumstances. To read the entire article, click this link

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George C. Hopkins

George C. Hopkins Partner