On November 2, 2021, the U.S. Environmental Protection Agency (EPA) announced a proposed rule involving three separate actions aimed at establishing a comprehensive and more stringent regulatory regime to reduce emissions from oil and gas operations across the United States (the Proposed Rules). The Proposed Rules seek to reverse the Trump Administration’s relaxation of methane standards for new, modified, or reconstructed sources, regulate so-called midstream (transportation and storage) sectors, and impose more stringent new source rules for methane and volatile organic compounds (VOC) (more stringent even than rules under the Obama Administration). We have previously covered the various iterations of methane regulation here, here, here, and here. Under the Proposed Rules, EPA also proposes to regulate existing oil and gas for the first time. Further information on each of these points is provided below.
Continue Reading EPA Proposes Sweeping Rule to Regulate Methane Emissions

As part of its Climate Action Plan, the Obama Administration issued a “Strategy to Reduce Methane Emissions” (the Methane Strategy) at the end of March 2014.  According to the Methane Strategy, methane emissions currently account for almost nine percent of all domestic greenhouse gas emissions (GHGs) in the United States.  While methane emissions have decreased since 1990, they are expected to increase over the next 15 years if no additional action is taken.  The Obama Administration’s Methane Strategy focuses on reducing methane emissions from landfills, coal mines, and the agriculture and oil and gas sectors.  Building on and updating existing programs is key to the strategy.  The key proposals for reducing methane emissions from these areas are outlined by sector below:
Continue Reading Obama Administration Issues Strategy to Reduce Methane Emissions