Air Permitting: Sixth Circuit Vacates Single Stationary Source Aggregation Determination for E&P Facilities Due to EPA’s Unreasonable Interpretation of Adjacent
The Energy Law
AUGUST 16, 2012
The question of what is “contiguous or adjacent” has long been vexing for the exploration and production industry. In 2007, in guidance specifically addressing oil and gas activities, EPA stated that “proximity is the most informative factor in making source determinations.” See, e.g., 40 C.F.R. §§ 51.166(b)(6); 71.2.
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