Coming Soon - EPA Information Request Letter to O&G Operators for Methane and VOC Emissions

As you may know, EPA has over recent months taken a keen interest in existing O&G operations.  It seems EPA is looking to push for additional rulemaking to target older O&G operations for methane and VOC emissions.  Many suspect EPA will also pursue additional requirements under Quad Oa New Source Performance Standards.

To bring about these additional requirements, EPA has been working on a Section 114 Clean Air Act madatory information collection request letter ("IRC") to send to owners and operators of oil and gas facilities that emit methane and/or VOCs.  And we aren't talking about just a few letters - EPA estimates 15,000 operators will be required to respond to the IRCs.   Additionally, about 4,000 facilities will have to provide more detailed information that may include a requirement to analyze those emissions.  To make matters worse, EPA is targeting maintenance, venting and low-producing/marginally economic wells for additional regulation. 

While EPA has to get an approval from the Office of Management and Budget ("OMB") to send the letters, such an approval is almost certain.  OMB has 60 days to make its decision to approve or disapprove meaning the letters could go out in early November.  So to our friends in the O&G industry, plan to enjoy your Thanksgiving turkey while answering the initial operator survey as EPA has proposed a 30 day deadline for response.  If you are among the unlucky sampling of O&G facilities that also receive the facility survey, you will have 120 days to answer and will do so through e-GGRT, the electronic greenhouse gas reporting tool which we all love so much.