Looking Ahead — Implementation Of EPA's New Methane Rule

On March 8, 2024, the Environmental Protection Agency (EPA) published landmark final new rules under Clean Air Act section 111 to regulate methane emissions from the oil and gas industry (the OOOO rules). The OOOO rules set new standards for new or modified sources and emissions guidelines for states to implement similar standards for existing sources. The rule covers sources across the onshore production and processing sector, as well as the natural gas transmission and storage sector. Among other things, the rule limits routine flaring, implements stringent standards for process controllers, creates a new program for addressing large emissions events (i.e., super-emitters), and has major implications for the way fugitive emissions are addressed through leak monitoring, detection, and repair. The rule goes into effect on May 7, 2024. From then on, new and modified sources are required to comply with the federal requirements. States have up to two years