New Methane Regulations Proposed for the Oil and Gas Sector: What You Need to Know
On August 18, 2015, EPA proposed a slate of
rulemakings under the Clean Air Act (the “Act”) directed at the oil and gas industry. Today Vinson & Elkins published an article outlining the key provisions of these rulemakings. These rulemakings would, if promulgated along the lines proposed, achieve the following:
establish New Source Performance Standards (“NSPS”) for methane and volatile organic compound (“VOC”) emissions from the oil and gas sector;
redefine the fundamental term “source” in a way that may add burdensome requirements, extend the time and permitting risks associated with permitting sources, and potentially require additional controls; and
require states to mandate additional pollution controls in states that are non-attainment for ozone, through Controls Technique Guidelines (“CTGs”) that states will be forced to implement.
The changes from the existing regulations under Subpart OOOO are summarized below:
These rules will have widespread application to the oil and gas industry and could have impacts on production, processing, transmission, and storage vessels. Businesses and individuals concerned about this proposed rule or interested in participating in EPA’s decision making process have only 60 days after the proposed rule is published in the federal register to submit comments to the agency.
It is important to note that these changes — once adopted — will apply to any covered source built or modified after the Federal Register proposal date, regardless of when the rule is made final. Accordingly, owners and operators need to begin now to design and build their operations to comply with the performance requirements imposed by these proposed rules. Read the entire article here.