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Keeping you in-the-know on environmental, social and governance developments

On Saturday, EPA announced the finalization of new source performance standards (NSPS) regulating greenhouse gases and volatile organic compounds (VOCs) emissions for the Crude Oil and Natural Gas source category. The PDF is just shy of 1700 pages! That is forgivable, given that the EPA claims to have received over 1 million individual comments on the two proposals. Given the size of the proposal, it will take awhile for various expert analyses to be developed and published. We will monitor for this, but we’ll start with a few key points taken from the rule preamble, rule language itself and EPA’s accompanying Fact Sheet.

Rule Coverage

For those familiar with EPA rules, this is a new set of New Source Performance Standards (NSPS) that are specific for defined emissions sources in the oil and gas industry. The designations are NSPS OOOO, OOOOa, OOOOb and OOOOc (although technically, OOOOc are Emissions Guidelines for states in the development, submittal, and implementation of state plans to establish performance standards to reduce emissions of GHGs from designated facilities that are existing sources on or before December 6, 2022). The rule regulates GHG in the form of methane. Depending on the situation, the rules apply to facilities at which construction, modification, or reconstruction commenced

  • after August 23, 2011 and on or before September 18, 2015; or
  • after September 18, 2015, and on or before December 6, 2022; or
  • after December 6, 2022.


The final rule imposes pollution reduction standards for the largest sources of methane and other pollutants at oil and gas facilities, including methane that leaks or is vented from equipment and processes. Among other things, the final rule:

  • phases in the elimination of routine flaring of natural gas from new oil wells. Routine flaring will continued to be allowed for existing wells with documented methane of 40 tons per year (tpy) or less.
  • requires comprehensive monitoring for leaks of methane from well sites and compressor stations, while giving companies flexibility to use low-cost and innovative methane monitoring technologies [e.g., remote sensing or optical gas imaging].
  • establishes standards that require reductions in emissions from high-emitting equipment like controllers, pumps, and storage tanks. 
  • clarifies how states can use their existing air regulatory programs in plans for limiting methane emissions from existing sources and gives states two years to submit their plans for EPA approval.

The final rule includes a Super Emitter Program that will utilize third-party expertise in remote sensing to detect large methane releases or leaks known as “super emitters” (a super-emitter event is one that has a quantified emission rate of 100 kg/hr of methane or greater). While third parties may monitor sites, they can only submit their findings to EPA who will assess the data and will notify the company. Third parties are not allowed to notify companies directly.

See more about some of the rule’s technical details – that could apply to other industries were EPA to expand GHG emissions standards – in the next blog.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile