On August 18, 2015, the U.S. Environmental Protection Agency (EPA) proposed rules to limit emissions of methane, a potent greenhouse gas (GHG), from certain new and modified facilities in the oil and natural gas industry. The proposed rules represent the latest of several major EPA initiatives to address GHGs and climate change, and the first proposed GHG controls specifically for the oil and gas industry. The proposal stems from President Obama’s goal of cutting methane emissions from the oil and gas sector to 40 to 45 percent below 2012 levels by 2025.

The proposed rules add methane to the emissions subject to the New Source Performance Standards (NSPS) that EPA adopted in 2012 to address nonmethane volatile organic compound (VOC) emissions from certain oil and gas facilities. According to EPA, sources already subject to the 2012 NSPS requirements for VOCs, such as hydraulically fractured (fracked) gas well completions and equipment leaks at gas processing plants, will not need to install additional controls to comply with the new methane standards. However, the proposed rules also extend both methane and VOC standards to facilities not currently covered under the NSPS, including fracked oil well completions and equipment leaks and other “fugitive” emissions at well sites as well as downstream compressors and other equipment.