EPA's Final Methane Rule: Fighting Climate Change Up To January 20, 2017 — And Beyond

Dylan Thomas said "Do not go gentle into that good night."  Obama's EPA is taking that advice to heart, pushing forward aggressively on its climate change agenda, even as January 2017 approaches.  On Thursday, EPA issued its final rule promulgating New Source Performance Standards for methane emissions from oil and gas facilities.  The lengthy and complex rule is too long to summarize here, but you can find the Cliff Notes version in EPA's fact sheet.

What's notable about the final rule is that it is decidedly more stringent than the proposed rule, increasing the frequency of required leak-detection monitoring.  EPA also telegraphed a similarly aggressive posture towards existing facilities.  Together with the final NSPS rule, EPA issued a draft Information Collection Request that would be issued to 22,000 existing facilities.  It seems unlikely that EPA could actually issue the ICR, receive and process the responses, and issue a draft set of standards to regulate