Both the upstream and downstream sectors have seen a flurry of activity. Below is a summary of some of the highest priority rulemakings, both federal and state, with a short summary and links where you can find more information. Federal SEC Climate Disclosure Rule — The Securities and Exchange Commission proposed rule amendments requiring a domestic or foreign registrant to include certain climate-related information in its registration statements and periodic reports, including — in some cases — indirect emissions from upstream and downstream activities in a registrant’s value chain (Scope 3). UPA joined with nearly 50 other trades to submit a request for an extension of the comment period given how highly significant and dense this package is. https://www.sec.gov/news/press-release/202246#:~:text=The%20proposed%20rule%20changes%20 would,impact%20on%20its%20business%20and https://www.sec.gov/files/33-11042-fact-sheet.pdf EPA OOOOc Rule — EPA Proposes New Source Performance Standards Updates, Emissions Guidelines to Reduce Methane, VOCs, and Other Harmful Pollution from new and existing sources in the Oil and Natural Gas Industry. The proposal includes controls at well sites and compressor stations, advanced monitoring, elimination venting and more. UPA has previously submitted comments on this notice and plans to comment once the more specific rule language is available. https://www.epa.gov/controlling-airpollution-oil-and-natural-gas-industry/ epa-proposes-new-source-performance https://www.epa.gov/system/files/documents/2021-11/2021-oiland-gas-proposal.-overview-fact-sheet.pdf EPA Proposed U&O FIP — EPA Region 8 proposes to promulgate a Federal Implementation Plan (FIP) specific to the Uintah & Ouray Reservation. In the FIP, the EPA proposes to regulate volatile organic compound (VOC) emissions from certain new, modified, and existing oil and natural gas facilities located on Indian country lands within the U&O Reservation. UPA has previously submitted comments on this rule and the Western Energy Alliance, and we anticipate possible movement on the rule in 2022. https://www.epa.gov/air-quality-implementation-plans/ proposed-fip-oil-and-natural-gas-sources-uintah-and-ourayindian https://www.reginfo.gov/public/do/ eAgendaViewRule?pubId=202110&RIN=2008-AA03 REGULATORY UPDATE 12 UPDATE
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