On March 12 2018 the Environmental Protection Agency (EPA) announced amendments to provisions of the 2016 New Source Performance Standards (NSPS) for the oil and natural gas production and distribution sectors. Among other requirements, the NSPS had established a leak detection and repair programme to detect and repair sources of fugitive emissions of volatile organic compounds and methane from various components.

The amendments revise the programme by removing the requirement that oil and gas operators conduct repairs during unscheduled or emergency shutdowns. Owners and operators must still complete repairs during the next scheduled shutdown opportunity or within two years, whichever comes first. In April 2017 the EPA announced its intention to reconsider certain aspects of the 2016 NSPS, a process which is ongoing.

For further information on this topic please contact Samuel B Boxerman or Jim Wedeking at Sidley Austin LLP by telephone (+1 202 736 8000) or email (sboxerman@sidley.com or jwedeking@sidley.com). The Sidley Austin LLP website can be accessed at www.sidley.com.

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