Given its patchwork of regulatory authority over operations in the oil and natural gas industry, the U.S. Environmental Protection Agency (EPA) has adopted a national enforcement initiative to focus its efforts. Through its Energy Extraction Enforcement Initiative, EPA has been steadily targeting the energy industry. A recent settlement provides further insight into EPA’s approach under the Clean Air Act and highlights the type of “beyond compliance” requirements on which industry should focus.

Noble Energy, Inc. Settlement -

On April 22, 2015, Noble Energy, Inc. agreed to a $73 million settlement to resolve claims brought by EPA and the State of Colorado related to emissions of volatile organic compounds (VOCs). The financial costs of the settlement are significant for a Clean Air Act matter in the upstream sector.