San Joaquin Valley Oil and Gas Operators Take Note: New Emission Rules and Compliance Deadlines

Stoel Rives - Environmental Law Blog
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In March 2017, the California Air Resources Board (“ARB”) adopted regulations for Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities (“Methane Regulations”), which impose emission controls for oil and gas facilities across the state.  Following the state rulemaking process, ARB and the San Joaquin Valley Air Pollution Control District (“Air District”) – and the Air District’s regulated stakeholders – jointly determined that local administration of the program would provide for more effective and expeditious implementation at a lower cost to businesses in the Air District.  Thus, in December 2017, the Air District adopted a registration program (Air District Rule 2260) to implement ARB’s regulations.

In its most recent Compliance Bulletin (January 2018), the Air District outlined the following upcoming compliance deadlines for oil and gas operators in the San Joaquin Valley:

  • January 1, 2018: Quarterly Leak Detection and Repair (“LDAR”) inspections are required on all subject equipment. Please note that permitted equipment previously subject to LDAR under the existing Air District Rules is exempt from this requirement.
  • March 1, 2018: A registration application for all equipment subject to the state regulation must be submitted. Modifications of operations requiring additional control equipment subject to Air District permitting must go through the permitting application process, even if the modifications are required to comply with the state regulation.
  • July 1, 2018: An inventory of all equipment covered by the state regulation must be submitted.

We will continue to monitor compliance updates, and as well as requirements for the state Methane Regulations and the Air District’s implementing Rule 2260, and will keep our readers informed about this process going forward.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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