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Here is a little deeper dive into EPA’s new methane emissions rule. Certainly there are many areas of interest in the rule’s 1700 pages, but we picked only a couple that are particularly notable and that could apply to other industries beyond oil and gas should EPA decide to do so. Even if you aren’t in the oil business, you may want to take note.

Remote Sensing

The new rule

“… recognizes and encourages innovation in the field of methane detection technology providing owners and operators the flexibility to use a range of advanced monitoring technologies — including combinations of different technologies —to identify leaks at well sites, centralized production facilities, and compressor stations.

The final rule leverages third-party expertise to find large leaks and releases known as ‘super emitters.’ 

Under the final rule’s super-emitter program, EPA will certify third parties, will receive and evaluate the data the third parties provide, and send notifications to owners and operators… [although] only EPA-approved remote-sensing technologies, such as those used on satellites or in aerial surveys, may be used in the program. The rule does not allow the third parties to enter a well site or other facility.”

Performance and calibration standards for optical gas imaging (OGI) are established Appendix K. At first reading, this sounds like the door is open to NGO/community drone fleets filling the skies above oil and gas operations. Fortunately, EPA put the brakes on that. In the rule’s preamble, EPA said:

“… we acknowledge the desire of certain third-party groups to use OGI as part of this program. However, the current generation of this technology does not have the quantification ability required as part of this rule. More importantly, this technology cannot be operated at a distance and creates more potential for users getting too close to the site and creating risks to themselves or to the site. We recognize that a number of the technology vendors focusing on OGI are developing systems capable of quantification, and as these systems come online, this determination may change if there is a mechanism to ensure that the monitoring is only done at a reasonable and safe distance away from an applicable well site, central tank battery, or compression station.”

State Regulatory Programs

As with other regulatory programs, EPA anticipates that states will have primacy for developing and implementing their own programs that are at least as stringent as EPA requirements:

“EPA’s final rule includes Emissions Guidelines for states to follow as they develop plans that establish, implement, and enforce performance standards for methane emissions from existing sources…

The final rule provides states additional time to submit plans for reducing emissions from existing sources, with plans due 24 months after the effective date of the rule. EPA had proposed to provide states 18 months to submit plans. The final rule generally requires that state plans require compliance by no later than 36 months after the plans are due to EPA. This means that existing sources could have up to 5 years after the effective date of EPA’s final rule before they must comply with requirements in state plans.”

We’ll keep you updated on how this progresses (there is certain to be litigation!) and other analyses as they come in. Stay tuned.

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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