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  • Web Exclusive: Analysis of EPA's proposed clean air restrictions on oil and gas operations


    Richard H. Osa and Todd E. Palmer

    Critics have claimed that natural gas extracted from hydraulic fracturing has a greenhouse gas (GHG) production footprint comparable to that from coal combustion,1 and that the oil and gas production sector as a whole accounts for 40% of all methane emissions in the US. On July 28, 2011, the US EPA proposed its first comprehensive suite of Clean Air Act (CAA) rules to regulate air emissions from oil and gas production, gas-gathering and processing facilities, storage vessels and transmission pipelines2 (Fig. 1). The rules, as drafted, would impact over 1 million oil and gas producing wells, 3,000 processing plants and 1.5 million miles of pipeline. This article explains the legal framework EPA is using to support the proposed rules, provides a technical analysis of the emission limitations and discusses notable issues associated with the proposal.

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