Oil and Gas Emission Rule Corrections
Summary
The U.S. Environmental Protection Agency (EPA) is taking interim final action on technical corrections to three regulations recently finalized within "Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review," (hereafter "final rule"), published March 8, 2024. Following publication of the final rule, the EPA identified, through its own internal reassessment of the regulatory text, as well as through communications with stakeholders and the Office of Federal Register, erroneous cross-references and typographical errors within the regulatory text. Through those same processes, the EPA also identified the need for some minor wording changes to clarify erroneous language (or, in some cases, erroneous omissions) in the regulatory text and/or to ensure that the regulatory text aligns with the descriptions of the relevant provisions in the final rule preamble and other parts of the regulation(s). The corrections being made in this action are minor and non-substantive in nature and are being made to address inadvertent errors in the final rule. The EPA is requesting comments on all aspects of this interim final rule.
Compliance Requirements
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Submit comments on this interim final rule must be received on or before [INSERT DATE 30 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]; Judicial review of this final action is available only by filing a petition for review in the United States Court of Appeals for the District of Columbia Circuit by [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]; Do not submit information containing CBI to the EPA through https://www.regulations.gov. Clearly mark the part or all the information that you claim to be CBI; For CBI information on any digital storage media that you mail to the EPA, note the docket ID, mark the outside of the digital storage media as CBI, and identify electronically within the digital storage media the specific information that is claimed as CBI; In addition to one complete version of the comments that includes information claimed as CBI, you must submit a copy of the comments that does not contain the information claimed as CBI directly to the public docket
Deadline: 2024-08-31(30 days after publication in Federal Register)
Market Impacts
Technical corrections to cross-references and typographical errors in NSPS OOOOa, NSPS OOOOb, and EG OOOOc regulations. These corrections ensure regulatory text accuracy but do not change substantive requirements, maintaining existing market conditions without new restrictions or opportunities.
Validated Company Impacts
EOG RESOURCES INC
EOG Resources operates extensively in crude oil and natural gas production in the United States, which is the primary industry targeted by this EPA rule. The company's exploration, development, and production activities directly fall under the jurisdiction of NSPS OOOOa, NSPS OOOOb, and EG OOOOc regulations that this rule corrects, making them subject to all compliance requirements including comment submission and CBI handling procedures. The rule addresses minor technical corrections to existing oil and gas regulations, which does not meaningfully align with the company's identified climate change regulatory risk that focuses on substantive new costs and restrictions. The corrections maintain existing requirements rather than imposing new burdens, making the risk impact negligible.
CNX Resources Corp
CNX Resources Corp operates directly in natural gas production and midstream systems, which are explicitly covered by the EPA's oil and natural gas sector regulations being corrected. The company's core business activities in natural gas development, production, and marketing fall squarely within the scope of NSPS OOOOa, NSPS OOOOb, and EG OOOOc regulations that this rule corrects. The rule addresses minor technical corrections to existing oil and gas regulations, which does not meaningfully align with the company's identified regulatory risk of 'increased compliance costs or operational restrictions.' The corrections are non-substantive and maintain existing requirements, so they do not introduce new compliance burdens or operational impacts that would affect the company's risk profile.
DEVON ENERGY CORP/DE
Devon Energy operates extensively in oil and gas exploration and development across multiple basins, directly aligning with the oil and natural gas sector targeted by this EPA rule. The company's core business activities fall under the jurisdiction of NSPS OOOOa, NSPS OOOOb, and EG OOOOc regulations that this correction addresses, making them subject to the compliance requirements. The rule addresses minor technical corrections to existing oil and gas regulations, which does not align with the company's primary risk factors focused on commodity price volatility, debt levels, and market fluctuations. While the company has regulatory compliance risks identified, this specific correction rule represents minimal substantive impact compared to their broader compliance concerns.
MURPHY OIL CORP
Murphy Oil Corp operates directly in the oil and natural gas production sector, which is explicitly targeted by this EPA rule covering NSPS OOOOa, OOOOb, and EG OOOOc regulations. The company's U.S. operations in crude oil and natural gas production fall squarely under the jurisdiction of these EPA standards, making them subject to the regulatory requirements and compliance obligations. The rule addresses technical corrections to oil and gas emissions regulations, which primarily involve environmental compliance and regulatory processes, while the company's disclosed risks focus entirely on market volatility, financial instruments, and operational dependencies on commodity prices with no mention of environmental or regulatory compliance risks. There is minimal overlap as the rule's procedural requirements for comment submission and judicial review could theoretically affect any regulated entity, but these are not reflected in the company's specific risk profile.
RANGE RESOURCES CORP
Range Resources Corp is directly engaged in natural gas production and exploration, which falls squarely within the oil and natural gas sector targeted by this EPA rule. The company's operations in hydraulic fracturing and natural gas development make it subject to the NSPS OOOOa, NSPS OOOOb, and EG OOOOc regulations that this correction addresses. This rule makes minor technical corrections to existing oil and gas regulations without substantive changes, so it does not introduce new environmental compliance risks or legal exposure. The company's existing environmental and legal risk factors relate to violations and proceedings from current operations, not administrative corrections that maintain the status quo.