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As EPA Pursues Existing Sources, Could Well and Pipeline Blowdowns Be Next?: EPA’s Plan to Expand Regulations of Greenhouse Gas Emissions from the Oil and Gas Sector

V&E Environmental Law Update E-communication, October 17, 2016

Although the clock will run out on the Obama Administration before it can issue any proposal to regulate additional sources of methane and volatile organic compounds (VOCs), the Administration is putting the building blocks in place for the next EPA to finalize a rule that could compel state regulation of older and, in some cases, marginally profitable well sites and other emission sources. These regulations may also cover maintenance activities, such as well and pipeline blowdowns, equipment malfunctions, and flashing emissions from storage tanks.

This past April, EPA began formulating an Information Collection Request (ICR) that requires companies operating existing oil and gas facilities to provide information that the Agency intends to use to develop comprehensive regulations requiring states to submit plans to reduce methane and VOC emissions from these older facilities. After receiving public comments on its initial draft of the ICR, EPA has published a second draft for additional comments and review by the White House Office of Management and Budget (OMB). EPA may begin sending out these mandatory information requests as soon as November 2016. Owners and operators who receive these letters will be required to complete the surveys within the time periods set by EPA. EPA estimates that 15,000 operators will have to fill out an operator survey, and that the entities representing almost 4,000 facilities will have to complete an additional and more lengthy facility survey that could require sampling and analysis. Read the entire article here.

For more information, please contact Vinson & Elkins lawyers Larry Nettles or Eric Groten. Visit our website to learn more about V&E’s Environmental and Natural Resources or Climate Change practices, or e-mail one of the practice contacts.

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This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.