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Yesterday, President Trump signed an executive order concerning the controversial Waters of the United States (WOTUS) rule finalized in June of 2015. The order requires the EPA and the Army Corps of Engineers to publish a new rule that either rescinds or revises the 2015 WOTUS rule. The order also suggests that the agencies follow … Continue reading "President Trump Signs Executive Order Concerning “Waters of the United States” Rule"
Responding to EPA’s Oil and Gas Information Collection Request
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Check your mailbox: The US EPA is seeking information about the oil & gas industry that will enable the development of new standards under the Clean Air Act. EPA has issued the Information Collection Request (ICR). Response to the ICR is mandatory; response time depends on the whether a Part 1 “Operator Survey” (60‐day response) … Continue reading "Responding to EPA’s Oil and Gas Information Collection Request"
EPA issues 2nd draft ICR for Oil and Natural Gas Companies
Posted onOn September 23, 2016 EPA issued the second draft of an Information Collection Request (ICR) to require oil and natural gas companies to provide extensive information needed to develop regulations to reduce methane emissions from existing oil and gas sources. EPA clarified that the facility survey will not request detailed information on every well in … Continue reading "EPA issues 2nd draft ICR for Oil and Natural Gas Companies"
Clean Power Plan Developments
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The D.C. Circuit Court will hear arguments on the Clean Power Plan (CPP) en banc next Tuesday, Sept. 27 in Washington. The court has announced that only judge Garland, who is nominated to the Supreme Court, will recuse himself from the hearing. The participation of judge Cornelia Pillard, brings the D.C. Circuit Court’s en banc … Continue reading "Clean Power Plan Developments"
Revisions Proposed for Risk Management Programs
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In response to President Obama’s Executive Order 13650, the Environmental Protection Agency (EPA) has issued a proposed rule to amend the Risk Management Program (RMP) rule aimed at preventing workplace fatalities like the one that occurred in the fertilizer plant explosion in West, Texas in 2013. The RMP rule requires facilities that use, store, manufacture, … Continue reading "Revisions Proposed for Risk Management Programs"
Emergency Engines at Power Plants Lose Operating Exemptions
Posted onReciprocating Internal Combustion Engines (RICE) previously considered “emergency engines” under the EPA NSPS and NESHAP rules (RICE Rules) may now lose their exempt status according to a new Internal Guidance Memorandum issued by the EPA on April 15, 2016. The memorandum, “Guidance on Vacatur of RICE NESHAP and NSPS Provisions for Emergency Engines”, concedes that … Continue reading "Emergency Engines at Power Plants Lose Operating Exemptions"
Clean Power Plan Model Rules: Pathways for Implementation
Posted oneSPARC attended Harvard University Energy Policy Seminar Series Clean Power Plan Model Rules: Pathways for Implementation presented by Ms. Kate Konschnik, Lecturer on Law and Director of the Environmental Policy Initiative at Harvard Law School. During the lecture, Ms. Konschnik analyzed the legal challenges behind the Clean Power Plan following the unexpected stay by a 5-4 vote of … Continue reading "Clean Power Plan Model Rules: Pathways for Implementation"
EPA Targets Methane from Production and Transmission Sites in Latest Round of Proposed Rules
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Continuing what has been a steady march towards tighter air regulations on upstream and midstream facilities, on August 17, the EPA released two proposed rules that address fugitive emissions from oil and gas production and transmission sites as well as a new federal plan for wells in Indian Country. While the new requirements come as … Continue reading "EPA Targets Methane from Production and Transmission Sites in Latest Round of Proposed Rules"
Court Rules CSAPR Emission Limits Excessive but Still Must Be Followed Until EPA Revisions Are Made
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The Cross State Air Pollution Rule (“CSAPR”) has once again survived a legal challenge. However, unlike the 2014 Supreme Court ruling, the latest court decision will require a major restructuring of how the rule is implemented. On July 28, the D.C. Circuit Court found that the EPA was too heavy-handed in setting its SO2 and … Continue reading "Court Rules CSAPR Emission Limits Excessive but Still Must Be Followed Until EPA Revisions Are Made"
Costs Count: Supreme Court Rules EPA Required to Consider Costs in Listing HAP Sources
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eSPARC NOTES: On June 29, the Supreme Court held that the EPA must consider costs when deciding to regulate existing electrical utility steam generating units (EGUs) for hazardous air emissions. The case before the court arose from the EPA’s 2012 Mercury and Air Toxic rule, in which the agency openly omitted costs from its decision … Continue reading "Costs Count: Supreme Court Rules EPA Required to Consider Costs in Listing HAP Sources"