New Methane Regulations for the Oil and Gas Sector

Vol. 30 No. 3

By

Ms. Gladd is an associate in the Washington, D.C., office of Beveridge & Diamond, P.C., and a member of the editorial board of Natural Resources & Environment. She may be reached at kgladd@bdlaw.com.

On August 18, 2015, the U.S. Environmental Protection Agency (EPA) proposed a suite of regulations aimed at reducing emissions of methane and volatile organic compounds (VOCs) and clarifying air permitting rules for the oil and natural gas sector. The package consists of four proposed rules/guidelines: (1) New Source Performance Standards (www.federalregister.gov/articles/2015/09/18/2015-21023/oil-and-natural-gas-sector-emission-standards-for-new-and-modified-sources) (NSPS) for methane and VOCs, 80 Fed. Reg. 56,593 (Sept. 18, 2015); (2) draft Control Techniques Guidelines (www3.epa.gov/airquality/oilandgas/pdfs/og_ctg_draft_081815.pdf), Notice of Availability, 80 Fed. Reg. 56,577 (Sept. 18, 2015), for reducing VOC emissions; (3) a Source Determination Rule (www.federalregister.gov/articles/2015/09/18/2015-21026/source-determination-for-certain-emission-units-in-the-oil-and-natural-gas-sector), 80 Fed. Reg. 56,579 (Sept. 18, 2015); and (4) a Federal Implementation Plan (www.federalregister.gov/articles/2015/09/18/2015-21025/review-of-new-sources-and-modifications-in-indian-country-federal-implementation-plan-for-managing) (FIP), 80 Fed. Reg. 56,554 (Sept. 18, 2015), for Indian Country. I provide an overview of each rule below, followed by a discussion of the implications for affected sources.

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