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Presidential Executive Order Targets NSPS Subpart OOOOa Regulations

Posted: March 31st, 2017

Author: All4 Staff 

UPDATE (4/4/17): U.S. EPA announced that it is initiating the review of Subpart OOOOa as required by the Presidential Executive Order.  The announcement can be found here.

ORIGINAL: In June 2016, we wrote about the arrival of 40 CFR Part 60 Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015 for the oil and gas industry.  As noted in Roy’s blog, a fundamental change implemented in Subpart OOOOa consisted of the addition of greenhouse gases (GHGs), expressed as methane, as a regulated pollutant in addition to VOC and sulfur dioxide (SO2), which has been the subject of considerable industry pushback.  In a newly-issued March 28th Presidential Executive Order Promoting Energy Independence and Economic Growth, U.S. EPA is being required to review Subpart OOOOa to ensure that it is consistent with President Trump’s policy for energy independence and economic growth, as outlined in Section 1 of the Executive Order, and, as appropriate, revise, suspend, or rescind this regulation.

The referenced policy in Section 1 driving the requirement for U.S. EPA’s review of Subpart OOOOa is focused on, as the title of the Executive Order suggests, promoting energy production in relation to economic growth.  The main argument of the policy is that regulations should not prevent energy production from a variety of fuels, cause significant costs for the use of various fuels, or inhibit the creation of jobs in the oil and gas industry.  As such, executive departments and agencies are directed to review regulations deemed to not align with this policy.

Under the Executive Order, U.S. EPA is required to submit a plan for its review Subpart OOOOa within 45 days of the issuance of the Executive Order, and to submit a report detailing whether or not the subpart will be revised, suspended, or rescinded within 120 days of the issuance of the Executive Order.

ALL4 will be closely following the U.S. EPA’s review of Subpart OOOOa, and we will be updating our blog or newsletter as new information becomes available.  Please contact me at 610.933.5246, extension 167, or ahoward@all4inc.com.


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