Proposed Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector

Texas House Bill 2726
October 17, 2019
On November 2, 2021, the EPA proposed Standards of Performance for New, Reconstructed, and Modified Sources (NSPS) as well as Emissions Guidelines (EG) for Existing Sources for the Oil and Natural Gas Sector. These standards and guidelines are targeted at reducing greenhouse gases (GHGs) and volatile organic compounds (VOCs) from O&G sources. The proposal was published in the federal register on 11/15/21.

Depending on comments, the final version of the NSPS and EG could change significantly. However, we wanted to provide a summary of the proposal for clients to review in case they would like to provide comments.

The proposed updates, NSPS, and Emission Guidelines would potentially affect the following sources:
• NSPS OOOO: New, modified, or reconstructed sources after 8/23/11 and on or before 9/18/15
• NSPS OOOOa: New, modified, or reconstructed sources after 9/18/15 and on or before 11/15/21
• NSPS OOOOb: New, modified, or reconstructed sources after 11/15/21
• EG OOOOc: Existing sources on or before 11/15/21

Emissions Guidelines establish procedures for states to follow as they develop plans that establish, implement and enforce performance standards for “designated facilities”. Once the Emissions Guidelines are final, states must submit plans that establish standards that generally are as stringent as the presumptive standards.

Comments are due Jan 14, 2022 - How to comment

States and various groups have mentioned they would like to have additional time to review given the time of the year and the breadth of the proposals. They have also expressed concerns regarding interpretation issues, as well as equipment availability and reliability.

Additional information, and the proposal itself, can be found here:
EPA's Oil and Gas website
Rulemaking Docket
Slides and recordings from EPA’s training that took place on November 16-18, 2021
EPA's Public Hearing Information

Please reach out to Waid Environmental at 512-255-9999 if you have any questions or need assistance with commenting, compliance, or permitting.