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OOGA Methane Regulatory Guide

In December of 2023, the U.S. EPA finalized their Clean Air Act rule establishing methane emission standards for facilities in the oil and gas sector. These regulations will have devastating impacts on Ohio’s oil and gas industry. The rule consisting of changes to both OOOOb and OOOOc began taking effect last spring, for new or reworked operations from December of 2022.

In December of 2024, the Waste Emissions Charge rule was finalized and applies to waste emissions from oil and gas facilities and was included originally in the Inflation Reduction Act. Oil and gas operators must report their 2024 emissions and pay a charge on anything over 25,000 metric tons of carbon dioxide equivalent.

This site is designed to help members understand the rules and help with deadlines, information and compliance. It also outlines the legal, regulatory, and legislative avenues OOGA has used in order to shape, blunt, and rescind these rules and laws.

LATEST UPDATES

Trump Blocks WEC Rule

U.S. EPA Announces Rollback of 31 Regulations Including OOOOb/c

Ohio EPA Releases OOOOb Air Permit for Comments

OOGA COMMENTS

OOGA's Comments on the Methane Supplemental

Producer Associations Comments on the Methane Supplemental

OOGA's Waste Emissions Charge Comments

OOGA Comments on the US EPAs Methane Emissions Reduction Program

OOGA Comments on the US EPAs Proposed Methane Rule

OOGA Comments to Ohio EPA on Early Stakeholder Outreach for OOOOc

OOGA Comments to US EPA on the "Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems” (i.e., subpart W)

  

  

 

 

OOGA LEGAL ACTION

Starting in 2024 OOGA along with national allies began filing lawsuits and legal challenges in the courts and at the agency level to stop the methane rules from being implemented.

Below you can review all the legal action OOGA has been party to:

April 2024 – OOGA Filed a Petition for Review with the Court of Appeals for District of Columbia challenging the new OOOOb and OOOOc rules.

May 2024 – OOGA Filed a Motion to Stay in the Court of Appeals for the District of Columbia to stay the effectiveness of OOOOb and OOOOc while litigation occurs.

May 2024 – OOGA Filed its Statement of issues in the Court of Appeals for the District of Columbia outlining its areas of concern with OOOOb and OOOOc. 

July 2024 – OOGA Filed a Petition for Review with the Court of Appeals for the District of Columbia challenging the new Subpart W rule.

August 2024 – OOGA Filed its Statement of Issues with the Court of Appeals for the District of Columbia outlining its areas of concern with the new Subpart W rule.

August 2024 – OOGA Filed a Request for Reconsideration with the U.S. EPA requesting reconsideration of the OOOOb and OOOOc rules.

August 2024 – OOGA Filed a Motion to Stay in the Supreme Court of the United States to stay the effectiveness of OOOOb and OOOOc while litigation occurs. 

October 2024 – OOGA Filed a Request for Reconsideration in the Supreme Court of the United States asking for reconsideration of our Motion to Stay. 

Methane and Waste Emission Charge Legislative Repeal Efforts

U.S. House of Representatives – Natural Gas Tax Repeal Act

U.S. Senate – Natural Gas Tax Repeal Act

U.S. House of Representatives – Waste Emissions Charge CRA

U.S. Senate – Waste Emissions Charge CRA

 

RESOURCES

Partner Association Methane Resources

IPAA: https://www.ipaa.org/methane/

AXPC: https://axpc.org/axpc-position-on-methane-regulations/

API:  https://www.api.org/news-policy-and-issues/methane

U.S. EPA Methane Rule and Waste Emission Charge Resources

Methane Rule Website

Waste Emission Charge Website

Ohio EPA Methane Resources

Ohio EPA Methane Website

OOGA Guide to Acquire Air Permits from Ohio EPA for OOOOb:

Air Permit Instructions Tier 1 - Minor Source Conventional Wellpads

Air Permit Instructions Tier 2 - Minor Source Conventional Wellpads

Air Permit Instructions Tier 3 - Minor Source Conventional Wellpads (also for some larger operations)

OOGA Member Resources

OOGA Methane Rule Compliance Presentation

OOGA Methane Compliance White Paper

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