Methane in the Midstream
Trends - ABA Section of Environment, Energy, and Resources
January/February 2016

Partner Wayne D’Angelo authored the article “Methane in the Midstream” for Trends, a bi-monthly newsletter published by the American Bar Association’s Section of Environment, Energy, and Resources. The U.S. Environmental Protection Agency’s (EPA) September 18, 2015 proposal to tighten New Source Performance Standards (NSPS) applicable to the oil and gas industry is primarily recognized for its first-ever direct regulation of methane emissions and for its expansion of the existing NSPS (Subpart OOOO) from natural gas wells to both natural gas and oil wells. Wayne notes that this represents, not only the first effort to regulate methane emissions from oil and gas transmission equipment, but the first regulation of air emissions from equipment and facilities in the midstream sector. He provides the regulatory background from both prior to and after the proposal. The article goes on to explain that, “Given the role of methane reductions in the president’s ambitious commitment to reduce domestic greenhouse gas emissions, EPA likely views as one of its top priorities for 2016 the finalization of this rule in substantially the same form as it was proposed.”