EPA and PHMSA Propose New Regulations for Oil and Gas Facilities, Onshore Pipelines

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On Nov. 2, 2021, the Environmental Protection Agency (EPA) announced its proposed rule to update and expand regulation of methane and volatile organic compound (VOC) emissions for new, modified and reconstructed oil and gas sources, and to develop emissions guidelines for existing sources. 

Also on Nov. 2, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced its final rule to require operators of all onshore gas gathering pipelines to report incidents and file annual reports with PHMSA under 40 CFR § 191; and establishing a new category of regulated onshore gathering lines to cover higher-pressure, larger-diameter lines in rural areas. 

Both rules present potential impacts to our oil & gas clients, specifically gas producers and midstream companies operating gas gathering systems. Both rulemaking actions will be subject to public comment following publication in the Federal Register (yet to occur as of the date of this advisory).

 

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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