Recently, our colleagues Matt Morrison and Brendan Hennessey published their Client Alert titled A New Path to Managing Risks from Upstream Oil and Gas Transactions, EPA incentivizes new owners to conduct compliance audits by offering penalty forgiveness for violations found. Takeaways include:
- The Environmental Protection Agency’s (EPA) newest enforcement proposal offers companies in the oil and gas production sector a valuable opportunity to reduce compliance risks inherent in the purchase of facilities
- EPA remains focused on ensuring storage tanks and associated equipment are properly sized and designed to prevent emission leaks
- EPA’s draft agreement recognizes that the timing of audits and corrective action should depend on the number of acquired facilities and the scope of the audit