Upstream Air Permitting and the New EPA Audit Program for Oil and Gas: Avoiding Mishaps and Penalties in Exploration and Production

Correcting Clean Air Act Noncompliance, Mitigating Civil Penalties for Qualified New Owners of Upstream Oil and Natural Gas

A live 90-minute CLE webinar with interactive Q&A


Thursday, September 5, 2019

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, August 9, 2019

or call 1-800-926-7926

This CLE webinar will provide oil and gas counsel an in-depth analysis of the new EPA New Owner Audit Program and correcting Clean Air Act noncompliance for facilities. The panel will discuss the applicability of the new audit program to new owners of upstream oil and gas exploration and production, key terms and provisions of the new audit program agreement, and the processes involved upon entering the new audit program, as well as offer methods to avoid mishaps and penalties for new owners of facilities.

Description

On Mar. 29, 2019, the EPA issued its final Oil & Natural Gas Exploration and Production Facilities New Owner Audit Program Agreement. It allows owners of newly acquired facilities to self-audit and correct deficiencies to avoid or minimize civil penalties for noncompliance. Counsel must have a complete understanding of the requirements and processes under the new audit program to assist clients with ensuring compliance with the Clean Air Act and other regulations.

In the negotiation and drafting of purchase agreements for facilities, new owners focus on a variety of terms and provisions aimed at limiting risks and potential liability. Civil penalties against new owners typically stem from prior infrastructure issues leading to noncompliance with federal and state laws and regulations. Upon the acquisition of oil and gas exploration and production facilities, new owners must assess potential risks and implement corrective measures to comply with federal and state regulatory standards.

The new EPA audit program is open to all new owners of upstream oil and gas exploration and production facilities so long as they satisfy certain requirements. If the newly owned facility meets the conditions and enters the new audit program, the facility must complete specific actions to absolve the owners of civil liability for any violations identified during the audit.

Listen as our panel discusses key terms and provisions to consider in the purchase or investment in oil and gas facilities, applicability and processes of the new EPA audit program, and methods to avoid mishaps and penalties for new owners of facilities.

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Outline

  1. Risk mitigation techniques in the negotiation and purchase of facilities
  2. Compliance pitfalls for owners of newly acquired facilities and managing audits
  3. New EPA audit program and correcting Clean Air Act noncompliance
    1. Key terms and provisions
    2. Applicability
    3. Processes involved upon entering the audit program
  4. Best practices to avoid mishaps and penalties for new owners of facilities

Benefits

The panel will review these and other key issues:

  • What terms and provisions must be considered to limit risks during the negotiation and purchase of facilities?
  • What are the compliance pitfalls typically faced by new owners of facilities and methods to avoid them?
  • How can the new EPA audit program assist new owners in maintaining Clean Air Act compliance?
  • What are the key terms and provisions of the new EPA audit program?
  • What are the processes involved upon entering the new EPA audit program to ensure the avoidance of civil penalties?

Faculty

Colville, Christopher
Christopher J. Colville, P.E.

Partner
EDGE Engineering & Science

Since 2000 when he joined the environmental field, Mr. Colville has consulted with both private- and public-sector...  |  Read More

Pels, Gerald
Gerald J. Pels

Partner
Locke Lord

Mr. Pels, Chair of the Firm-wide Environmental Section - Energy and Industrial, has been one of the leaders of the...  |  Read More

Salinger, Jeff
Jeffrey L. Salinger

Partner
DLA Piper

For the last 20 years, Mr. Salinger has advised clients on environmental risks and opportunities arising in mergers and...  |  Read More

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