Flaring has the attention of RRC, Producers and Stakeholders
Flaring has the attention of the Texas Railroad Commission (RRC), oil and natural gas companies and stakeholders such as royalty owners, investors and environmental groups. Requests for RRC authorization of flaring has been on the increase in the Permian Basin. As a result, a number of interested parties are looking at regulatory changes. Some interested parties voice concern that a valuable resource is being wasted, others state that the definition of natural gas 'waste' is too limited, still others are concerned about methane emissions and some all of the above. Though the interested parties may not always be aligned, there is a general sense that regulatory amendments are needed.
Flaring is the release of natural gas through a combustion device and venting is the release of natural gas directly into the atmosphere. The RRC regulates flaring and venting primarily under Statewide Rule (SWR) 32. [i] RRC first adopted SWR 32 rule in December 1996 and later modified the rule in July 2000 and September 2004. In January 2014, RRC issued a Notice to Operators which states that “[r]eleases of gas resulting from routine oil and gas production operations are necessary in the efficient drilling and operation of oil and gas wells and are authorized subject to the requirements of subsection (e) of SWR 32. [ii] Conditions in the field have changed since the last modification of the rule on multiple levels.
Environmental advocacy groups have long taken the position that stronger regulation of venting and flaring is needed. Many of these groups point to shale plays in Texas as evidence that venting and flaring are used long-term to operate rather than flaring for a short duration as needed for safety reasons or to allow for installation and maintenance. For example, the Environmental Defense Fund (EDF) launched the Permian Methane Campaign to measure methane emissions and flaring efficiency in the Permian Basin and published the first survey results in April 2020. According to EDF, the findings indicate that companies emit at least three times more methane than EPA estimates. (Energy in Depth disputed the findings. [iii] Sierra Club supports the methane reduction efforts and has also called on the RRC to bolster its environmental compliance activities and to work with the Texas Commission on Environmental Quality to begin a new flaring and methane capture rule.
Some say the goal is uniformity and setting a level playing field, citing their position that approaches taken by oil and natural gas companies with regard to flaring cover a wide spectrum. These stakeholders claim that some companies use flaring as a matter of course while others have voluntarily put in place robust proactive site assessment and operational measures and many have made significant investments in technology upgrades. In an effort to focus on industry-led solutions, seven trade associations and over 40 oil and natural gas companies established the Texas Methane and Flaring Coalition (Coalition) in December 2019. The Coalition is voluntary and is focused on the development of quality data and transparent reporting of flared and vented volumes, the development of a matrix that defines why and when venting and flaring may be necessary and the identification and promotion of best practices and promising new technologies.
Other entities have taken notice of data indicating an increase in flaring in the Permian. For instance, the National Academy of Sciences in the Proceedings of the National Academy of Sciences of the United States (PNAS) stated in an opinion published in May 2020 that until recently five countries, Russia, Nigeria, Iran, Iraq and Algeria accounted for half of all flaring. By 2010, the United States was in the mix primarily due to the shale boom. [iv]
As previously reported, RRC established the Blue Ribbon Task Force for Oil Economic Recovery (Blue Ribbon Task Force) at its April 22, 2020, open meeting regarding production cuts. [v] The Blue Ribbon Task Force is made up of eight trade associations including: the Texas Oil & Gas Association (TxOGA), the Texas Alliance of Energy Producers (Alliance), the Texas Independent Producers and Royalty Owners Association (TIPRO), the Permian Basin Petroleum Association (PBPA), the Panhandle Producers and Royalty Owners Association (PPRA), the Texas Pipeline Association, the Texas Royalty Council and the South Texas Energy & Economic Roundtable. RRC again heard discussion surrounding proration at its open meeting on May 5, 2020. [vi] As part of the discussion on proration, several speakers noted the need for the RRC to address natural gas flaring issues. At that meeting, the Commissioners asked the Blue Ribbon Task Force to provide additional recommendations related to the reduction of flaring at the June open meeting.
June 16, 2020, RRC Open Meeting
The RRC held a regular open meeting on June 16, 2020. [vii] The Commissioners invited three panels to speak on the issue of flaring or venting of natural gas “to identify and analyze methods to reduce the amount, instances, and/or ratio of flaring or venting of natural gas in Texas in a manner that eliminates or mitigates any economic harm or difficulty to owners and operators of natural gas well.’ [viii]
The first panel to speak was made up of three environmental groups including: EarthX (Trammel Crow), EDR (Collin Leyden) and Sierra Club (Cyrus Reed). All agreed that flaring must be dramatically reduced. A change in incentives and increased inspections and enforcement were emphasized as well as coordination with TCEQ on air emissions. EarthX in particular focused on incentives. Commissioner Sitton noted that the RRC has historically considered economics in its assessment of waste.
The next panel to speak was made up of three oil and natural gas operators including: Latigo Petroleum, LLC (Kirk Edwards), Parsley Energy, Inc. (Stephanie Reed), and Occidental Petroleum Corporation (Occidental) (Mike Starrett). There was general consensus among the presenters that flaring should be reduced though each company took a somewhat different approach to get there. Occidental noted that in order to improve environmental performance, executive commitment and employee buy-in were necessary components.
Finally, four associations from the Blue Ribbon Task Force were asked to speak. They presented a report to the Commissioners entitled Flaring Recommendations and Best Practices prepared by the Coalition. The panel focused on the recommendations in the report. Proactive, voluntary efforts were highlighted. The Coalition recommends new facility designs and technology to improve environmental performance; expansion of pipeline infrastructure to improve air quality and safety while allowing more efficient transport and a robust regulatory framework that includes permitting, compliance and enforcement to assist in shortening the duration and volume of flaring. Specific recommendations include: 1) a flaring matrix which describes when flaring is necessary and recommendations for the application of SWR 32 that will reduce overall flaring through the reduction of timeframes needed for administrative approvals; 2) enhancements to the SWR 32 Data Sheet; 3) the creation of a new report to be known as the Subsequent Report with the goal of providing clear and usable data and; 4) updates to the Production Report Form Instructions to add a code for flaring so operators can account for flared and vented gas dispositions separately. Best practices were also emphasized.
In closing the agenda item, Chairman Christian emphasized the need to bring certainty to the markets. He then directed staff to review the Blue Ribbon Task Force recommendations and report back at the next open meeting to be held August 4, 2020.
Definition of “waste” is critical
RRC has been grappling with issues related to flaring for some time. A crucial element in the discussion of mechanisms to reduce flaring is the definition of waste. RRC has taken the position that flaring of natural gas is not waste if it is authorized under SWR 32. Under SWR 32, an exception may be made “to allow additional releases of gas if the operator of a well or production facility presents information to show the necessity for the release.” [ix] One of the listed situations supporting the release of natural gas in found at 16 TAC 32(f)(2)(E) which provides an exception if “[a] avoiding curtailment of gas production…will result in a reduction of ultimate recovery from a gas well or reservoir.
New Mexico has taken a different approach. In draft rules released on July 20, 2020 regarding methane emissions “[v]enting and flaring of natural gas during drilling, completion or production operations constitutes waste and is prohibited…” Limited exceptions are provided in the rule. [x] Further, commencing January 1, 2022, the draft rule requires operators to “reduce the annual volume of vented and flared natural gas on a statewide basis in order to capture ninety-eight percent of the natural gas produced from its wells no later than December 31, 2026. [xi] At least some of the entities that worked on the New Mexico draft rules are also working on the Texas rule amendments.
The regulatory framework RRC may eventually adopt could take many forms. It remains to be seen what RRC regulatory changes that govern flaring will look like, but there is no question that change is on the horizon.
[i] SWR 32 can be found at 16 Texas Administrative Code (TAC) [ ] 3.32.
[ii] www.rrc.state.tx.us>media>nto_state_disaster_swr_32_og_3-19-2020.pdf
[iii] https://eidclimate.org/four-things-to-know-about-edfs-new-permian-methane-estimates/
[iv] https://www.pnas.org/content/117/23/12503
[v] Link to blog
[vi] Link to blog
[vii] View the archived RRC webcast here. Agenda item 311.
[viii] Open Meeting Notice for Tuesday, June 16,2020
[ix] 16 TAC 32(f)(2)
[x] 19.15.27.8 New Mexico Administrative Code (NMAC)
[xi] 19.15.27.9 NMAC
Search
Recent Posts
Categories
- Agreements
- Air
- Batteries
- California
- Carbon
- Carbon Markets
- CERCLA
- Chemicals
- Climate
- Coal
- Duty to Defend
- Election
- Endangered Species
- Energy Transition
- Enforcement
- Environmental
- Environmental Justice
- Environmental Law
- EPA
- ESG
- General
- General Liability
- Manufacturing
- Mining
- Natural Resources
- Oil & Gas
- PFAS
- Policy
- Renewables
- Trade Agreements
- Utilities
- Waste
- Water
Tags
- 2015 Standards
- 2018 Farm Bill
- 2020
- 2020 Presidential Election
- 2022 Scoping Plan for Achieving Carbon Neutrality
- 316(b)
- 3D Printer
- 3D Printing
- 4(d) Rule
- 404
- 404 permits
- 404(g)
- 45Q
- AB 1200
- AB 2503
- AB 617
- Abeyance
- ABS
- ACE
- Acrylonitrile-Butadiene-Sytrene
- active guidance
- ADAO
- Adaptation
- adjacent
- Administration
- Administrative Agencies
- Administrative Law
- Administrative Procedure Act
- Administrator Pruitt
- Adverse Modification
- Advertizing
- Advisory Opinions
- Affordable Clean Energy
- Aftermarket Parts
- Agency
- Agency Budget
- Agency for Toxic Substances and Disease Registry
- Agency Guidance
- Agency Interpretation
- Agent
- Agriculture Improvement Act of 2018
- Air
- Air Emissions
- Air Permit
- Air Pollution
- Air Quality
- Air Quality Implementation Plan
- Air Quality Management District
- Air Quality Management Plan
- ALARP
- Alexandria Ocasio-Cortez
- Algae
- Allco Finance Unlimited v. Klee
- Allegheny
- Alternative Energy Portfolio
- Alternative Energy Portfolio Standard
- Ambient Air
- Amendments
- America's Water Infrastructure Act
- American Bar Association
- American Jobs Plan
- AMLO
- Anadarko Petroleum
- Andrés Manuel López Obrador
- Annie Kuster
- Anthony Kennedy
- Anti-Backsliding
- Anti-terrorism
- Antibacterial
- Antitrust
- AOC
- APA
- Appropriations
- APS
- AQMP
- Aquaculture
- Arbitration
- Arctice Grayling
- Army Corps of Engineers
- ARPA-E
- Articles
- Artificial Island transmission project
- Asbestos
- Asbestos Disease Awareness Organization
- Assumption
- Atlantic Coast Natural Gas Pipeline
- Audubon Society
- Auer
- Auer Deference
- Auxiliary Emissions Control Devices
- BAAQMD
- Backstop Siting
- BACT
- Bag Ban
- Bald and Golden Eagle Protection Act
- Bankruptcy
- BART
- Baseload
- Batteries
- battery storage
- Bay Area Air Quality Management District
- Beauty products
- Beneficial Use
- Beneficial Use and Reuse
- Bernie Sanders
- Best Available Control Technologies
- Beto O'Rourke
- BGEPA
- Biden Administration
- Bilateral Investment Treaty
- Biological Opinion
- Bipartisan Budget Act
- BIT
- Black-Capped Vireo
- BLM
- Blue Ribbon Task Force
- BOEM
- BOP
- Boston
- Boundary
- Brand Memo
- Brent Spar
- Brett Kavanaugh
- Brownfields
- BSEE
- Budget Proposal
- Bureau of Land Management
- Bureau of Ocean Energy Management
- CAA
- CAISO
- Cal-OSHA
- CalEPA
- California
- California Air Resources Board
- California Coastal Act
- California Consumer Protection Act of 2018
- California Department of Public Health
- California Department of Toxic Substances
- California Environmental Protection Agency (CalEPA)
- California Environmental Public Health and Workers Defense Act of 2019
- California Environmental Quality Act
- California Legislature
- California Mining
- California Ocean Protection Council
- California OEHHA
- California Proposition 13
- California Proposition 65
- California Regional Water Quality Control Boards
- California State Lands Commission
- California State Water Resources Control Board
- California Superior Courts
- California Title 8
- California Water Code section 13304
- California's Safe Drinking Water and Toxic Enforcement Act
- California-China Clean Technology Partnership
- Cannabis
- Cap In Place
- Cap-and-Trade
- Capital Asset Pricing Model
- CAPP
- CARB
- Carbon Capture
- Carbon Capture and Sequestration
- Carbon Capture Demonstration Projects Program
- Carbon Capture Large-Scale Pilot Projects
- Carbon Capture Utilization and Storage
- Carbon Credits
- Carbon Dioxide
- carbon dioxide removal
- Carbon Intensity
- Carbon Markets
- Carbon Nanotubes
- Carbon Utilization
- CASAC
- Categorical Exclusion
- CBD
- CBI
- CCPA
- CCPS
- CCR
- CCR Rule
- CCS
- CCS Alliance
- CCUS
- CDP
- CDR
- CECP
- CEJST
- Center for Chemical Process Safety
- Centralized Waste Treatment
- CEQ
- CEQA
- CERCLA
- Certificate of Public Convenience and Necessity
- Certification
- Certified Unified Program Agencies
- CESER
- CFATS
- CFCs
- CFE
- CGL
- Chambers USA
- Chapter 91
- Chemical Data Reporting
- Chemical Exposure
- Chemical Risk Assessment
- Chemical Safety Board
- Chemicals
- Cheryl LaFleur
- Chevron Deference
- Cheyenne River Sioux
- Chloroflourocarbons
- Chlorpyrifos
- Chrysotile Asbestos
- CIP
- Circular Economy
- CITES
- Citizen Petition
- Citizen Suit
- Civil Penalties
- Civiletti
- Claims-Made
- Class VI
- Class VI Primacy
- Class VI Underground Injection Control
- Clean Air Act
- Clean Development Mechanism
- Clean Energy
- Clean Energy Standard
- Clean Hydrogen
- Clean Peak Energy Certificates
- Clean Power Plan
- Clean Water Act
- Clean Water Act Section 401
- Clean Water Act Section 404
- Cleaning Products
- Cleanup
- Climate
- Climate Change
- Climate Disclosure
- Closure by Removal
- CNTs
- CO2
- CO2 Emissions
- Coakley Order
- Coal
- Coal Ash
- Coal Ash Basins
- Coal Combustion Residuals
- Coal Leasing Moratorium
- Coal Mine Health and Safety Act
- Coalition for Competitive Electricity v. Zibelman
- Coastal
- Coastal Zone Management Act
- Comisión Federal de Electricidad
- Commercial General Liability
- Commercial Information
- Common Law
- Community Air Protection Program
- Compliance
- Comprehensive Environmental Response Compensation and Liability Act
- concurrent-remedies doctrine
- Confidential Business Information
- Congress
- Congressional Research Service
- Congressional Review Act
- Consent Decree
- Conservation Easement
- Considerations
- Constitutional Law
- Consultation
- Consumer Data
- Consumer Product Exposure Warnings
- Consumer Products
- Consumer Products Safety Commission
- Contaminated Sites
- Contribution Threshold
- Controlled Substances Act of 1970
- Cook Inlet
- Cookware
- Cooling Water Intake Structures
- Cooperative Federalism
- COP26
- COP28
- COP28 Agreement
- Coronavirus/COVID-19
- Corporate Governance
- Corporate Social Responsibility
- Corporate Sustainability
- Corporate Sustainability Reporting Directive
- Corporate Sustainability Reporting Directive (CSRD)
- Corporate Valuation
- Corps
- Cosmetics
- Cost of regulation
- Council on Environmental Quality
- County of Maui
- COVID-19
- CPCN
- CPECs
- CPP
- CPS
- CPSC
- CPUC
- CRA
- Criminal Enforcement
- Critical Electric Infrastructure Information
- critical habitat
- Critical Habitat Designation
- Critical Infrastructure
- Critical Infrastructure Protection
- Cross-State Air Pollution Rule
- CSA
- CSAG
- CSAPR
- CSB
- CSR
- CSR reports
- CSR Standards
- CSR- and ESG-related risks
- Cultural Resources
- CWA
- CWA Citizen Suit
- CWA section 401
- CWA Section 404
- Cyber-Related Risks
- Cybersecurity
- D&O
- D&O Insurance
- Dakota Access Pipeline
- DAPL
- DARTIC
- Data Security
- DC Circuit
- DC Circuit Court of Appeals
- DCH
- Deadline Suits
- Deadlines
- Decarbonization
- Decommissioning
- Deep-Well Injection
- Deepwater Horizon
- Defeat Devices
- Defense Costs
- Deference
- Deidre G. Duncan
- Delisting
- Democratic Debate
- DEP
- Department of Energy
- Department of Homeland Security
- Department of Justice
- Department of Labor
- Department of the Interior
- Department of Transportation
- Designations
- Development
- Device
- Diligent Prosecution
- Dioxane
- Directors & Officers
- Director’s Order
- Discharge
- Diversity and Inclusion
- DJSI
- DOD
- DOE
- DOER
- DOI
- DOJ
- DOJ ENRD
- Domestic Energy Policy
- Domestic Terrorism
- DOSH
- Dow Jones Sustainability Index
- DPR
- DPU
- Draft
- Draft EA
- Draft Environmental Assessment
- drinking water
- Drought
- DTSC
- Due Diligence
- Duke Energy
- Duty to Defend
- Dynamic Scoring
- E&P Wastes
- EA
- eagle
- Eagle Take Permit
- Earth Day
- Economic Impact
- Economic Impacts
- Effluent
- Effluent Guidelines
- Effluent Limitations
- EHSS
- EIS
- EJSCREEN
- Election 2020
- Electric Ratepayers
- Electric Transmission
- Electric Vehicles
- Electricity
- Electricity Markets
- ELG
- ELGs
- Elizabeth E. Aldridge
- Elizabeth Warren
- Emergency Planning and Community Right-to-Know Act
- Emergency Response
- Emergency Support Functions
- Emerging Contaminants
- Emission Caps
- Emission Control Requirements
- Emission Reduction Credits
- Emissions
- Emissions Caps
- emissions reporting
- Emphasis List
- Endangered Species
- Endangered Species Act
- Energy
- Energy Industry
- Energy Infrastructure
- Energy Package Insurance
- Energy Reforms
- Energy Storage
- Energy Transition
- Enforcement
- Enforcement Discretion
- Enforcement statistics
- Engine Certification
- Enhanced Oil Recovery
- ENRD
- Environment
- Environment and Natural Resources Division
- Environmental
- Environmental and Social Governance
- Environmental Appeals Board
- Environmental Assessment
- Environmental Bar
- Environmental Compliance
- Environmental Crimes
- Environmental Defense Fund
- Environmental Disclosure
- Environmental Due Diligence
- Environmental Enforcement
- Environmental Groups
- Environmental Impact Statement
- Environmental Justice
- Environmental Justice and Equity Board
- Environmental Law
- Environmental Law Institute
- Environmental Markets
- Environmental Permitting
- Environmental Protection Agency
- Environmental Rights
- Environmental Social and Corporate Governance
- Environmental Social and Governance
- Environmental Social Governance
- Environmental Social Justice
- Environmental Transactions
- EO 13891
- EOR
- EP3
- EP4
- EPA
- EPA audit policy
- EPR
- EPR Laws
- Equator Principles
- Equator Principles Association
- ERC
- ESA
- ESA consultation
- ESA section 7 consultation
- ESG
- ESG Diligence
- ETP
- EU
- European Climate Law
- European Green Deal
- European Sustainability Reporting Standards
- European Union
- Evaluation of Regionalization for Potential New Wastewater Systems
- EVs
- Exceptional Events
- Exceptional Events Rule
- Excess Insurance
- Excess Liability
- Exchange Act
- Executive Compensation
- Executive Memorandum
- Executive Office for United States Attorneys
- Executive Order
- Executive Order 13777
- Executive Order 14008
- Executive Order N-8-23
- Executive Orders
- Extended producer Responsibility
- Fair and Equitable Treatment
- Fair Labor Standards Act
- FAST Act
- Fathead Minnow
- Fatmucket Mussel
- FDA
- FECM
- Federal Action
- Federal Agencies
- Federal Agency Action
- Federal Budget
- Federal Energy Regulatory Commission
- Federal Lands
- Federal Permit
- Federal Power Act
- Federal Preemption
- Federal Register
- Federal Rule 20
- Federal Rule 71.1
- Federalism
- Fees
- FERC
- FET
- Fiduciary Liability
- FIFRA
- Fifth Circuit
- Final Rule
- Financial Information
- Fireworks
- First Amendment
- Fishing Industry
- Flaring
- Flint
- FloaTEC LLC
- Flood Infrastructure Funding
- Flood Mitigation
- Florida
- FLSA
- FOIA
- Food
- Food and Drug Administration
- Food and Drug Administration (FDA)
- Food Loss and Waste
- Food Marketing Institute
- Food Marketing Institute v. Argus Leader Media
- Food Waste
- Food Waste Reduction Alliance
- Fossil Fuels
- Fourth Circuit
- Fourth of July
- FPA
- FPA Preemption
- FPA section 202(c)
- FPOS
- Fracking
- Framework
- Framework Rule
- Fraud
- Free Trade Agreement
- Freedom of Information Act
- Freeport
- FSLA
- FTA
- Funding for Environmental Protection
- Funding Mechanism
- FUTURE Act
- FWS
- FY2017 budget
- FY2018
- GAO
- Gas
- GDPR
- Gender Equality
- General Data Protection Regulation
- General Industrial Stormwater Permit
- General Permit
- GenX
- George Clemon Freeman Jr.
- GHG
- GHG Emissions
- GHG Emissions Renewable Portfolio Standard
- Gilbert & Sullivan
- Global Carbon Markets
- Global Climate Negotiations
- Global Reporting Initiative
- Global Warming Solutions Act
- Glyphosate
- GOM
- Good Neighbor Obligation
- Good Neighbor Provision
- Government Investigations
- Grand River Dam Authority
- Grassroots Activisim
- Green Admendment
- Green Communities Act
- Green Deal
- Green New Deal
- Green New Deal; Climate Change
- Greenhouse Gas
- Greenhouse Gas Emissions
- Greenhouse Gas Protocol
- Greenhouse Gas Protocol Initiative
- Greenhouse Gases
- Grid
- grid reliability
- grid study
- Grocery Manufacturers Association
- Groundwater
- Guam
- Guidance
- Guidance Portal
- Gulf of Mexico
- Habitat
- Hardrock Mining Rule
- Harmful Algal Blooms
- Hawaii
- Hawkes
- Hazardous Air Pollutants
- Hazardous Materials Regulations
- Hazardous Waste
- HBCD
- HCFCs
- Health
- Health Advisories
- health advisory
- Health and Safety
- HECT
- Hemp
- HFCs
- high-density polyethylene (HDPE)
- Highly Reactive Volatile Organic Compound Emissions Cap and Trade
- Historical Matter
- HMR
- Holder
- Homeland Security
- Hoopa Valley Tribe
- House
- House of Representatives
- Houston Casualty
- Human Health Toxicity Values
- Human Rights
- Hurricane Harvey
- Hydraulic Fracturing
- Hydroelectric Relicensing
- Hydrofluorocarbons
- Hydrofluorocarbons (HFCs)
- Hydrogen
- Hydrogen Energy Earthshot
- Hydrological Connection Theory
- Hydropower
- ICMM
- ICSID
- IFC Performance Standards
- IGP
- IIA
- IIJA
- Impaired Waterbodies
- Impaired Waters
- Impairment
- Incident Response
- Incidental Take
- incidental take statement
- Indian Lands
- Indigenous Traditional Ecological Knowledge
- Indonesia
- Industrial Accidents
- Industrial Hemp
- Infectious Disease Preparedness and Response Plan
- Inflaction Reduction Act
- Infrastructure
- Infrastructure Development
- Infrastructure Investment and Jobs Act (IIJA)
- infrastructure security
- Initial & Boundary
- Innovation
- Inside Look
- Inspections
- Insurance
- Insurance Recovery
- Integrated Science Assessment
- Interagency Review
- Intergovernmental Panel on Climate Change
- Interior
- International Arbitration
- International Centre for Settlement of Investment Disputes
- International Council on Mining and Metals
- International Energy Agency
- International Environmental Law
- International Investment Agreements
- International Petroleum Industry Environmental Conservation Association
- Interstate Transport
- Intervention
- Investment Risk Assessment
- IPCC
- IRIS
- IRIS Review
- IRS
- ISO-NE
- ITEK
- Jay Inslee
- Jewell
- Joe Biden
- John Hickenlooper
- Joint Venture Provision
- Judicial Review
- Judiciary
- Jurisdiction
- Jurisdictional Determination
- Justice40
- Kamala Harris
- Kavanaugh
- Kenk’s amphipod
- Kevin McIntyre
- Keystone XL
- Kigali Amendment
- Kisor
- Kisor Deference
- Kyoto Protocol
- Lake Erie
- Lake Powell Pipeline Project
- Lampsilis Siliquoidea
- Land Use
- Late Notice
- Lautenberg Act
- Law360
- LCPFAC SNUR
- LDC
- LDNR
- Lead
- Lead and Copper Rule
- Lease Sale
- Legislation
- Lesser Prairie Chicken
- Li-ion
- Liability
- Liability Insured
- Linear
- Liquefied Natural Gas
- Lithium-ion batteries
- Litigation
- Lloyds
- Lloyd’s of London
- LNG
- London Protocol
- Long-Form Warning
- Look-back period
- Louisiana Department of Natural Resources
- Low Carbon Fuel Standard
- MA DOER
- Maine Department of Environmental Protection
- Maintenance Fees
- Malaysia
- Manufactured Products
- Manufacturing
- Marijuana
- Maritime
- Markets
- Masias
- Mass Emissions Cap and Trade
- Massachusetts
- Massachusetts AG
- Massachusetts Clean Energy Center
- Massachusetts Climate Act
- Massachusetts Department of Energy Resources
- Massachusetts Global Warming Solutions Act
- MassCEC
- MATS
- Maximum Contaminant Levels
- MBTA
- MBTA; Wind Energy; Renewable Energy; protected species; natural resources; USFWS
- McGraw-Edison
- McIntyre
- MCL
- MCLG
- MCLs
- McNamee
- MEA
- MECT
- Mergers & Acquisitions
- Methane
- methane emissions
- Methane Repeal Rule
- Methylene Chloride
- Michigan
- microplastics
- Midnight Rule
- Midstream
- Migratory Bird Treaty Act
- Migratory Birds Treaty Act
- Millennium Pipeline
- Mineral Leasing Act
- Mining
- Mining Claims
- Minnesota Pollution Control Agency (MPCA)
- Misbranding
- Mitigation
- Mitigation Rule
- MLP
- Modification
- Monitoring
- Monsanto
- Montana
- Montreal Protocol
- Moratorium
- MOU
- Mountain Valley Pipeline
- MSGP
- Multi-Sector General Permit
- Multiyear Plan for Energy Sector Cybersecurity
- Mulvaney
- Murray
- Murray Energy
- MVP
- NAAQS
- NAFTA
- NAIOP
- NALs
- Nancy Pelosi
- NATA
- National Ambient Air Quality Standards
- National Compliance Initiatives
- National Cybersecurity and Communications Integration Center
- National Defense Authorization Act
- National Determined Contributions
- National Emergency
- National Enforcement and Compliance Initiatives
- National Enforcement Initiatives
- National Environmental Policy Act
- National Historic Preservation Act
- National Hydro Association
- National Marine Fisheries Service
- National Oceanic Atmospheric Administration
- National Parks and Conservation Ass’n v. Morton
- National Petroleum Council
- National Pollutant Discharge Elimination System
- National Pollutant Discharge Elimination System (NPDES)
- National Pollution Discharge Elimination System
- National Primary Drinking Water Regulation
- National Priorities List
- National Recycling Strategy
- National Register of Historic Places
- National Restaurant Association
- National Security
- Nationwide Permit
- Native American Law
- Natural Gas
- Natural Gas Act
- Natural Gas Leak Abatement Program
- Natural Gas Pipeline Certification
- Natural Gas Pipelines
- Natural Resource Damages
- Natural Resources
- Navigable waters
- NCCIC
- NCI
- NEC
- NECIs
- NEI
- Neil Chatterjee
- NELs
- NEPA
- NEPA Policy
- NEPA Review
- NERC
- NESCOE
- Net-Zero Emissions
- Net-Zero Greenhouse Gas Emissions
- New Chemicals Review Program
- New Rule
- New Source Review
- New York
- New York Department of Environmental Conservation
- New York State Department of Taxation and Finance
- NGA
- NGO
- NHPA
- NHTSA
- NIETC
- nitrogen dioxide
- NMFS
- No Exposure Certification Identification Number
- No-Action Letter
- NOAA
- NOI
- NONA
- Nonapplicability Identification Number
- Nonattainment
- Nonpoint Source
- North American Electric Reliability Corporation
- North Dakota
- Notice
- Notice of Proposed Rulemaking
- NPDES
- NPDES Delegation
- NPDWR
- NPL
- NSPS
- NSR
- nuclear
- nuclear energy
- NWP
- NY PSC
- Obama
- Occupational Safety and Health Act
- Occupational Safety and Health Administration
- OCE
- OECA
- OEHHA
- OEJECR
- Office of Civil Enforcement
- Office of Cybersecurity Energy Security and Emergency Response
- Office of Electricity Delivery & Energy Reliability
- Office of Enforcement and Compliance Assurance
- Office of Enforcement and Compliance Assurance (OECA)
- Office of Environmental Justice and External Civil Rights
- Office of Federal Register
- Office of Information and Regulatory Affairs
- Office of Management and Budget
- Office of Natural Resources
- Office of Water
- Offshore Energy
- Offshore Platforms
- Offshore Wind
- Offshore wind energy
- Ohio
- Oil
- Oil & Gas
- Oil and Gas
- Oil and Gas Production
- Oil and Gas Wastewater
- Oil Pipelines
- Oil Pollution Act
- OIRA
- Oklahoma
- OMB
- One Federal Decision
- One Federal Plan
- OPA
- OSHA
- Outer Continental Shelf
- OW
- Ozone
- Pacific OCS Region
- Packaging
- Paperwork Reduction Act
- Paris Agreement
- Paris Climate Accord
- Paris Climate Agreement
- Particulate Matter
- Partido Revolucionario Institucional
- Passaic River
- PATH Act
- PBT
- PCBs
- PEMEX
- Penalties
- Penalty
- PennEast Pipeline
- Pennsylvania
- Perfluoroalkyl
- Permian Basin
- Permitting
- Pesticide Devices
- Pesticides
- Pete Buttigieg
- Petition
- Petition for Rulemaking
- Petitions for Objection
- PetraNova
- Petrochemical Regulation
- Petróleos Mexicanos
- Petroleum Products
- PFAS
- PFAS Action Plan
- PFAS in Products State Law Tracker
- PFAS Reporting Rule
- PFAS Strategic Roadmap
- PFBA
- PFBS
- PFNA
- PFOA
- PFOS
- PHMSA
- Physicians for Social Responsibility
- Pimphales Promelas
- PIP
- Pipe Manufacturing
- Pipeline
- Pipeline and Hazardous Materials Safety Administration
- Pipeline Attacks
- Pipeline Construction
- Pipeline Safety
- Pipelines
- PIPES
- Plastic
- Plastic Carryout bag
- PNAS
- POCSR
- Point Source
- Point Source Discharge
- Policy
- Policy Statement
- Pollution
- Pollution Exclusion
- Pollution Liability
- Pollution Prevention for Healthy People and Puget Sound Act
- Polyalkyl
- Polyfluoroalkyl
- Port of Los Angeles
- Porter-Cologne Water Quality Control Act
- Potentially Responsible Party
- POTW
- PRA
- Practical Law
- Precedent
- Preconstruction Authorizations
- Preemption
- Prejudice
- Preliminary Injunction
- President Biden
- President Trump
- Presidential Transition
- PRGs
- PRI
- Priebus
- Principal
- Principles for Responsible Investments
- Priority Pollutants
- Privacy
- Process Safety Management
- Produced Water
- Product Safety
- Production Cuts
- Production Sharing Contract
- Prohibition on Sale
- Project Development
- Prop. 65
- Proposition 65
- Protected Species
- Protecting Our Conserved Lands Act of 2019
- PRP
- Pruitt
- Pruitt Task Force
- PSC
- PSD
- PSH
- PSM
- Public Comment
- Public Lands
- Public Utilities
- Publicly Owned Treatment Works
- Pumped Storage Hydropower
- PURPA
- Quality Assurance Plan
- R-Project Transmission Line
- Racing Vehicles
- RAGAGEP
- Railroad Commission
- Railroad Commission of Texas
- Railroad Commission of Texas (RRC)
- Rapanos
- RBI
- RCRA
- RCRA Subtitle D
- REACH
- Reasonable Progress Plans
- RECLAIM
- Reconsideration
- RECs
- Redevelopment
- Refinery
- Reform
- Reforma Energética
- Regional Clean Air Incentives Market
- Regional Clean Hydrogen Hubs
- Regional Greenhouse Gas Initiative (RGGI)
- Regional Haze
- Regional Water Quality Control Boards
- Registration Evaluation Authorization and Restriction of Chemicals
- Regulation
- Regulation S-K
- Regulation S-X
- Regulations
- Regulatory
- Regulatory Agenda
- Regulatory Freeze
- Regulatory Guidance
- Regulatory Programs
- Regulatory Reform
- Regulatory Review
- Reliability
- Reliability Safety Valve
- Remediation
- Removal Action
- Renewable
- Renewable Energy
- Renewable Energy Certificates
- Renewable Energy Portfolio
- Renewable Fuel Standards
- Renewable Portfolio Standard
- Renewables
- Renewals
- Reporting
- Request for Information
- ReRED
- Rescind
- Resilience of the Bulk Power System
- Resource Conservation and Recovery Act
- Responsible Business Initiative
- Restoration
- Restriction of Hazardous Substances
- Retail
- Retailers
- Retained
- Retroactivity
- Return on Equity
- RFS
- RHA
- Richard Glick
- Rigs to Reefs
- RIN
- Ripeness
- Risk and Technology Review
- Risk Assessment
- Risk Evaluation
- Risk Management
- Risk Management Plan
- Risk Management Program
- Risk Management Regulations
- Rivers and Harbors Act
- RMP
- Roadmap Release
- Roanoke River Basin Association
- Robert Powelson
- ROE
- ROEs
- RoHS
- Roundtable on Sustainable Palm Oil
- Roundup
- Royalties
- RPS
- RRBA
- RRC
- RTR
- Rule 14a-8(i)(7)
- Rule 65(c)
- Rulemaking
- Russia
- SAB
- Sacred Sites
- SAFE
- Safe Drinking Water Act
- Safe Harbor
- Safe Harbor Regulation
- Safe Harbor Warning
- Safer Consumer Products
- SAFETY Act
- Safety Management System
- San Francisco Bay Regional Water Quality Control Board
- SASB
- SaskPower’s Boundary Dam Unit 3
- SB 1371
- SCAQMD
- Science
- Science Advisory Board
- Science Advisory Board (SAB)
- Scope
- Scope 1
- Scope 2
- Scope 3
- Scott Pruitt
- SCOTUS
- SDWA
- SEC
- Section 10
- Section 104 Request
- Section 114 Request
- Section 179B(b)
- Section 208 Request
- Section 308 Request
- Section 4
- Section 401
- Section 404
- Section 408
- Section 45Q
- Section 5
- Section 6(b)
- Securities Act
- Securities and Exchange Commission
- Securities and Exchange Commission (SEC)
- Securities Law
- Seismicity
- Seminole Rock
- Senate
- Senate Energy and Natural Resources Committee
- Senator Lamar Alexander
- SEP
- SEPs
- Services
- Settlements
- Sewage
- Shareholder Lawsuits
- Shutdown
- Sierra Club
- Significant Figures
- Significant Guidance
- Significant New Use Rule
- SIP
- Smelter
- SNUR
- Social
- Social Media
- Solar
- Solid Waste
- South China Sea
- South Coast Air Quality Management District
- SPCC
- Species
- Spill Prevention Control and Countermeasure Rule
- SSB 5135
- SSM SIP Call
- Stabilization Clause
- Standing
- Standing Rock Sioux
- Stare Decisis
- State
- State Administrative Appeals
- State Air Pollution Control Board
- State Constitutions
- State Environmental Quality Review Act
- State Implementation Plan
- State Law
- State Water Resources Control Board
- States
- Statute of Limitations
- Statutory Authority
- Statutory Interpretation
- Stormwater
- Strategic
- Straw Proposal
- Subrogation
- sulfur dioxide
- Sunset Review
- Superfund
- Supplemental Environmental Projects
- Supply Chain
- Supreme Court
- Supreme Court of Texas
- Supreme Court of the United States
- Surface Mining Act
- Surface Water Discharge
- Susan Bodine
- Sustainability
- Sustainability Accounting Standards Board
- Sustainable Development Goals
- Sustainable Investing
- SWDA
- Switzerland
- SWRCB
- Tailings Storage Facility
- Take
- Take Prohibition
- Takings
- Task Force on Climate-Related Financial Disclosures (TCFD)
- Tax
- Tax Credits
- Tax Cuts and Jobs Act
- Tax Reform
- Taxonomy Regulation
- TCEQ
- TCI
- Temporary Policy
- TERP
- Texas Alliance of Energy Producers
- Texas Commission on Environmental Quality
- Texas Legislature
- Texas Railroad Commission
- Texas Water Development Board
- Thailand
- THC
- The European Commission
- The Mikado
- The Treasury Department
- The Water Infrastructure Improvements Act
- the WIIN Act
- Third Circuit
- Threatened Species
- Title V
- TMDL
- TMDLs
- TNALs
- Toledo
- Tolling Order
- Total Maximum Daily Load
- Toxic Chemicals
- Toxic Substances Control Act
- Toxic Substances Control Act (TSCA)
- Toxics
- Toxics Release Inventory
- Transcos
- Transition
- Transmission
- Transparency
- Transport
- Treasury
- Treaty Rights
- Trends
- TRI
- Tribal Rights
- Tribes
- Trump
- Trump Administration
- TSA
- TSCA
- TSF
- TWDB
- U.S. Army Corps of Engineers
- Ultimate Net Loss
- UNCLOS
- Underground Injection Wells
- Underground Storage Tank
- UNFCCC
- Unified Agenda
- United Airlines
- United Nations
- United Nations Framework Convention on Climate Change
- Urgenda
- US Army Corps of Engineers
- US Chemical Safety Board
- US Climate Alliance
- US Court of Appeals for the Ninth Circuit
- US Customs and Border Protection
- US Department of Agriculture
- US Department of Justice (DOJ)
- US Environmental Protection Agency
- US Fish and Wildlife Service
- US FWS
- US SAFETY Act
- US Securities and Exchange Commission
- US Securities and Exchange Commission (SEC)
- US Supreme Court
- USACE
- USDA
- USDOT
- USFWS
- USMCA
- Utilities
- utility
- vapor intrusion
- Vapor Recovery Units
- VCP
- venting
- Veto
- Village of Old Mill Creek. v. Star
- Vineyard Wind
- Virginia Clean Economy Act
- Virginia Community Flood Preparedness Fund
- Virginia Department of Environmental Quality
- Virginia State Corporation Commission
- vision of Corporation Finance
- VOCs
- Volatile Organic Compounds
- Voluntary Cleanup Program
- Voluntary Remediation
- Waiver
- Waiver Period
- Warnings
- Washington
- Waste
- Waste Discharge Identification Number
- Waste Electrical and Electric Equipment
- Waste Permitting
- Wasted Food
- Wastewater
- Wastewater Treatment
- Water
- Water Quality Certification
- Water Quality Criteria
- Water Regulation
- Water Reuse
- Water Supply and Management
- Water Systems
- Waterfront
- Waters
- Waters of the United States
- WDID
- WEA
- WEEE
- Well Blowout
- Well Control Rule
- WET Tests
- Wetlands
- Whole Effluent Testing
- Wholesale Electricity
- WildEarth Guardians
- Wildfire
- Wind
- Wind Energy
- Wind Energy Area
- wind farms
- Winning on Reducing Food Waste Initiative
- Winter v. NRDC
- Withdrawal or Reinstatement
- World Bank Group Equator Principles
- Worst-Case Discharge
- WOTUS
- WQBELs
- WQC
- Wyoming
- Zero Emissions
- Zero-Emissions Vehicle Initiative
- Zinke
Authors
- Yaniel Abreu
- Elizabeth E. Aldridge
- Walter J. Andrews
- John J. Beardsworth, Jr.
- Nancy B. Beck, PhD, DABT
- Jordan L. Bernstein
- Timothy E. Biller
- George Borovas
- Lawrence J. Bracken II
- Shannon S. Broome
- Karma B. Brown
- Samuel L. Brown
- F. William Brownell
- Courtney Cochran Butler
- Julia J. Casciotti
- Michelle G. Chan
- E. Carter Chandler Clements
- Abigail Contreras
- Benjamin Y. Cooper IV
- Christopher J. Cunio
- Alexandra B. Cunningham
- Andrea DeField
- Meredith Doswell
- Douglas L. Dua
- Deidre G. Duncan
- Frederick R. Eames
- Clare Ellis
- Latosha M. Ellis
- Susan S. Failla
- Geoffrey B. Fehling
- Andrea Field
- Hannah Flint
- Steven C. Friend
- Kevin E. Gaunt
- Andrew G. Geyer
- Erin Grisby
- Elisabeth R. Gunther
- Steven M. Haas
- Alexandra Hamilton
- Patrick Jamieson
- Kevin W. Jones
- Dan J. Jordanger
- Ryan T. Ketchum
- Sami M. Khan
- Jonathan H. Kim
- Scott H. Kimpel
- Charles H. Knauss
- Garrett Kral
- J. Pierce Lamberson
- Lucinda Minton Langworthy
- Jaclyn E. Lee
- Matthew Z. Leopold
- Charlotte Leszinske
- Brian R. Levey
- Michael S. Levine
- Elbert Lin
- Eric R. Link
- Nash E. Long
- David S. Lowman, Jr.
- Phyllis H. Marcus
- Jeffrey N. Martin
- Lorelie S. Masters
- Patrick M. McDermott
- Kerry L. McGrath
- Robert J. McNamara
- Michael J. Messonnier, Jr.
- Jennifer MikoLevine
- Todd S. Mikolop
- Angela Morrison
- Michael J. Mueller
- Eric J. Murdock
- Ted J. Murphy
- William L. Newton
- Henry V. Nickel
- Paul T. Nyffeler, PhD
- Peter K. O’Brien
- G. Michael O’Leary
- Evangeline C. Paschal
- Kate Perkins
- Shemin V. Proctor
- Shawn Patrick Regan
- Myles F. Reynolds
- Doris Rodríguez
- Brent A. Rosser
- Christian Rudloff
- Rachel Saltzman
- Arthur E. Schmalz
- Penny A. Shamblin
- Michael R. Shebelskie
- George P. Sibley, III
- Joseph C. Stanko
- Martin P. Stratte
- Javaneh S. Tarter
- Thomas W. Taylor
- Patricia Tiller
- Linda Trees
- Andrew J. Turner
- Emily Burkhardt Vicente
- Gregory R. Wall
- Thomas R. Waskom
- Malcolm C. Weiss
- Michelle-Ann C. Williams
- Susan F. Wiltsie