Alerts and Updates

EPA Proposes New Emission Rules Affecting the Oil and Natural Gas Industries

August 19, 2015

The proposed rules call for emission reductions in methane and volatile organic compounds from emitters in the oil and natural gas industries.

On August 18, 2015, the U.S. Environmental Protection Agency (EPA) took another step in its bid to address climate change by issuing proposed rules aimed at reducing methane emissions.[1] By their nature, the proposed rules will predominantly impact the oil and natural gas industries and come on the heels of the Clean Power Plan's regulation of electric generators.[2]

The proposed rules call for emission reductions in methane and volatile organic compounds (VOC) from emitters in the oil and natural gas industries. The source categories named in the action are:

  • Crude Petroleum and Natural Gas Extraction,
  • Natural Gas Liquid Extraction,
  • Natural Gas Distribution,
  • Pipeline Distribution of Crude Oil and
  • Pipeline Transportation of Natural Gas.

A wide range of oil and natural gas activities, processes and equipment will be subject to the proposed standards. They include:

  • Compressors—requiring a 95-percent reduction of methane and VOC emissions from certain wet seal centrifugal compressors and other measures affecting reciprocating compressors;
  • Pneumatic controllers—setting a natural gas bleed rate of six standard cubic feet per hour from individual, continuous bleed and natural gas-driven pneumatic controllers, and a zero natural gas bleed rate for controllers located at natural gas processing plants;
  • Pneumatic pumps—establishing a zero emissions rate for pumps located at natural gas processing plants and a 95-percent reduction in emissions for other locations;
  • Hydraulically fractured oil well completions—requiring, where feasible, the use of reduced emissions completions with a completion combustion device; and
  • Fugitive emissions from well sites and compressor stations—requiring fugitive emissions surveys with optical gas imaging technology for new and modified well sites and compressor stations, which include the transmission and storage segment as well as the gathering and boosting segment.

Comments on the proposed rules may be submitted to the EPA within 60 days of publication of the rule in the Federal Register.

For Further Information

If you have any questions about this Alert, please contact Sheila Slocum Hollis or Dennis J. Hough in the firm's Washington, D.C. office, any of the attorneys in our Energy, Environment and Resources Practice Group or the attorney in the firm with whom you are regularly in contact.


[1] Environmental Protection Agency, Oil and Natural Gas Sector: Emission Standards for New and Modified Sources, Docket No. EPA-HQ-OAR-2010-0505, Aug. 18, 2015, available at:

[2] Environmental Protection Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, Docket No. EPA-HQ-OAR-2013-0602, Aug. 3, 2015, available at:

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