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Trans Energy Settlement Shows Need for E&P Wetlands Compliance Strategy

The Energy Law

The Trans Energy settlement shows that exploration and production (E&P) companies need a rigorous compliance strategy for wetlands permit requirements. On the other hand, the legal commentary has virtually ignored the importance of Nationwide Permits (NWPs) 12 and 39 to E&P activities. See 77 Fed. 10184 (Feb.

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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

By Lesley Foxhall Pietras On August 7, 2012, in a 2-1 decision in Summit Petroleum Corp. Specifically at issue was EPA’s finding that the plant and the wells were “adjacent” based on their operationally interdependent relationship. In light of this determination, the court applied no deference to EPA’s interpretation of the term.

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New Air Standards for Oil & Gas Industry May Force HAP Area Sources into Major Source Status

The Energy Law

By Robert E. Moreno On August 16, 2012, EPA published a new rule that revises the NESHAP Subpart HH standards for the oil and gas industry. The Final Rule wassigned on April 17, 2012, but publication in the Federal Register did not occur until August 16, 2012, making the rule effective on October 15, 2012.

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