Coming Soon: EPA’s Supplemental Proposed Methane Rules for the Oil and Gas Sector

Per our earlier update, the EPA’s far-reaching initial proposal in November 2021 included three separate actions under the Clean Air Act that target new and existing air emission sources at oil and natural gas well sites, natural gas gathering and boosting compressor stations, natural gas processing plants, and transmission and storage facilities. We have highlighted some of the initial proposal’s potential shortcomings identified by commenters, including the fact that it did not include the proposed regulatory text. We can expect the EPA’s supplemental proposal to attempt to address many of the issues identified by commenters.

The importance of the EPA’s methane rulemaking has only increased with the passage of the Inflation Reduction Act (“IRA”), which expressly exempts sources from the IRA’s methane emissions fee if the EPA’s methane rulemaking will result in “equivalent or greater emission reductions.”