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Summary of the EPA Proposal and How ESG Certifications May Play a Role for O&G Companies
Insight • Updated December 1, 2021
Overview of the EPA's proposed Subpart OOOOb and OOOOc, discussion on investor/market pressures, and how this may push ESG certifications forward.

Marelyn Serrano

Darcy Partners

Sustainability

The EPA has gone back to the drawing board and released a new (proposed) set of guidelines and performance standards to reduce emissions for oil & gas Made in the U.S.A. This proposed set of solutions is intended to fill the gaps that Subparts OOOO and OOOOa left in 2016, including a set of guidelines for states and tribes to reduce emissions on existing sources, requiring a baseline for many sites and increasing the frequency of OGI surveys.

Below you can find a table put together by CleanClonnect.ai summarizing the EPA's proposed standard and guidelines for new and existing emissions sources (OOOOb/c), comparing it to the existing OOOOa and Colorado's state rules. The full table can be viewed here and video explanation is included at the end of this blog.

Table 1: EPA Proposal for Oil & Gas Emissions Reduction Image

Source: CleanConnect.ai

This is one of many regulatory proposals up and coming in the world, but as our friends at Capterio mentioned in their recent article - more can be done. Specifically for Europe's regulatory environment, more can be done, especially around emissions related to imports and exports which accounts for 80% of consumed gas and 95% of consumed oil according Capterio.

In the U.S., many oil & gas companies, particularly the smaller private equity backed companies like Triple Crown Resources, have taken a more proactive approach to emissions detection and reduction. According to ~30% of attendees at the TCR and LongPath events, responding to investor/market demands is a key point of motivation for E&Ps utilizing methane detection solutions not already approved by the EPA.

On the energy tech side, what we've found particularly interesting is this movement on 3rd party ESG Certifications that's emerged - likely addressing investor/market pressures and this idea of a carbon tax on production. Although some are skeptical and may see these efforts as "Green Washing", aren't these certification companies simply the free market's response to slow governments? After all, what better strategy to reduce emissions than one that may result in a premium….What are your thoughts and reactions on the EPA's proposed policies? Is ESG Certification moving the needle or is this just another profitable "ORGANIC" movement? Let us know in the comments!!

We'd like to thank CleanConnect.AI for supplying the table of the EPA proposed regulations. The full view including notes and subscripts can be viewed here. If you're a visual, a video description of the EPA proposal can be found below.

Sources:

  • https://www.pillsburylaw.com/en/news-and-insights/epa-expands-requirements-for-reducing-methane-emissions.html
  • https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/epa-proposes-new-source-performance
  • https://cleanconnect.ai/ep43-epa-emissions-update-oooob-c/
  • https://flareintel.com/insights/why-the-eu-should-enact-methane-regulation-for-imported-oil-and-gas
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