Muddying the Upstream and Midstream Waters

In the last several years, EPA has issued numerous rules impacting the oil and gas industry. While petroleum refineries in the downstream segment face new compliance challenges with the first ever fenceline monitoring requirement for benzene, regulations imposed on the upstream and midstream segments seek to curb emissions of greenhouse gases (GHGs) and volatile organic compounds (VOC). As if these new challenges were not enough, the EPA has strongly signaled through information collection efforts that more regulations on the upstream and midstream segments are forthcoming. Continue reading “Muddying the Upstream and Midstream Waters”

Let’s Just Kick Them While They Are Down

The oil and gas sector is suffering from the recent reduction in prices. Lower prices mean fewer wells being drilled, reduced employment in the sector and a slowly diminishing production rate. However, the problems facing the oil and gas industry have not deterred the Environmental Protection Agency (EPA) from pressing ahead with its climate agenda as it relates to oil and gas production. Continue reading “Let’s Just Kick Them While They Are Down”

New Climate Rules Will Impact Oil and Gas Industry

EPA continues to focus on the oil and gas sector in its relentless quest for reduction of methane and volatile organic compound (VOC) emissions. It now seeks to expand on the standards announced in 2012 for hydraulically fractured natural gas wells by having additional standards on a variety of sources in place by 2016.

Methane accounts for about 9 percent of domestic greenhouse gas emissions. Although methane emissions have decreased since 1990, EPA predicts they will increase through 2030 if action is not taken. As a result, EPA believes new reductions are necessary in order to meet the administration’s goal of reducing greenhouse gas emissions by 17-percent below 2005 levels by 2030. As the oil and gas sector accounts for roughly 28 percent (in 2012) of greenhouse gas emissions, EPA sees it as a fertile ground for action. Continue reading “New Climate Rules Will Impact Oil and Gas Industry”

Environmental Issues Facing Auto Dealers

Automotive dealerships face numerous challenges in the current economic climate.An ongoing challenge, in good times and bad, is ensuring that environmental liability and the associated costs are minimized as much as possible so that capital is are not needlessly expended.The risk of liability may be minimized by taking several pro-active steps.

Limiting Liability for Past Contamination

It should not come as a surprise that the owner of an automotive dealership will be held liable for spills and releases of spent solvents, used oil, gasoline, or other pollutants or contaminants into soil, surface water, or groundwater that occur when the owner is in control of the property.Compliance with the regulations and good housekeeping, discussed in greater detail below, may limit the risk of these spills or releases.Unfortunately, however, environmental practices or controls were not as stringent in the past as they are today.Spills and releases of pollutants that occurred many years ago continue to persist today in soil and groundwater at or under the property. Continue reading “Environmental Issues Facing Auto Dealers”