The purpose of this White Paper is to provide general guidance to transaction participants and practitioners in their consideration of the application of 17 C.F.R. Part 246, adopted jointly by the Securities and Exchange Commission (“SEC”) and five other federal agencies (the “Agencies”) in October of 2014 (the “CRR Rules”) pursuant to Section 15G of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), as added by section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, to a typical issuance of secured notes by a newly formed special purpose vehicle that owns or will own, among other things, a portfolio of proven, developed and producing hydrocarbon wells (a “Structured PDP Well Financing”).
Vinson & Elkins partner John B. Connally served as Contributing Editor to the Chambers 2022 Energy: Oil & Gas Global Practice Guide, which was released on August 9, 2022.
It has been over a year since the Colonial Pipeline cybersecurity incident, and the Department of Homeland Security’s Transportation Security Administration (“TSA”) continues to issue cybersecurity directives to owners and operators of critical pipelines and liquified natural gas facilities.
The Environmental Protection Agency (“EPA”) has recently finalized volumes for compliance years 2020, 2021, and 2022 under the Clean Air Act (“CAA”)’s renewable fuel standard (“RFS”) program and took several other related regulatory actions.
EPA has received more than 300,000 comments on its November 2021 proposal to regulate methane from new and existing sources in the oil and gas production sector.
On November 15, 2021, the Environmental Protection Agency (“EPA”) published a proposed rule that included three separate actions under the Clean Air Act that target new and existing air emission sources at oil and natural gas well sites, natural gas gathering and boosting compressor stations, natural gas processing plants, and transmission and storage facilities.
On December 7, 2021, the U.S. Environmental Protection Agency (“EPA”) proposed the long-awaited and much anticipated renewable fuel targets for 2020, 2021, and 2022 under the federal Clean Air Act’s (“CAA”) Renewable Fuel Standard (“RFS”) (the “Proposed Rule”).