Analysis of States & EPA Oil and Gas Air Emission Control Requirements for Selected Basins in the Western U.S. (PDF: 2 MB) (DOC: 4MB) (1/8/12 Final)

The intent of this analysis is to examine the effect that two new federal air quality actions might have on the air pollution emissions from the oil and natural gas (O&G) industry exploration and production sector. The document also examines the current O&G emission control regulations in place in the western U.S. O&G producing states to determine where the new federal rules might overlap existing State rules and which source types could be affected. The seven O&G producing states in the WRAP region interviewed for this analysis include Alaska, Colorado, Montana, New Mexico, North Dakota, Utah and Wyoming. California is also an O&G producing state, but because control of O&G exploration and production sector sources is handled by local Air Pollution Control Districts in that state rather than by the California Air Resources Board, it was not possible to contact each of these 35 Districts individually to assess their current regulations under the scope of this project. This analysis uses data from the WRAP-Western Energy Alliance Phase III O&G Emission Inventory project (http://www.wrapair2.org/PhaseIII.aspx), which accounts for state O&G rules in place at the time the Phase III inventories were compiled.

The first of the two federal actions is a Federal Implementation Plan (FIP) known as “Review of New Sources and Modifications in Indian Country”, promulgated in final form on June 10, 2011. The second action is a suite of four proposed air regulations for the oil and natural gas industry: 1) a New Source Performance Standard (NSPS) for VOCs; 2) a New Source Performance Standard (NSPS) for sulfur dioxide; 3) a National Emissions Standard for Hazardous Air Pollutants (NESHAP) standard for oil and natural gas production; and 4) a National Emissions Standard for Hazardous Air Pollutants (NESHAP) standard for natural gas transmission and storage. The EPA proposed the rules on July 28, 2011, took comment on the rules through November 30, 2011. A determination is to be made by EPA on the final rules by April 3, 2011.