Pub.1 2019-2020 Issue 3

W hen it comes to fixing problems, voluntary compliance is gen- erally the least expensive and the most effective way to go. That is why the EPA created the self-audit provision of the clean air act: it wanted to collaborate with the industries it oversees. In that way, the EPA can help the U.S. move toward cleaner air as fast as possible. The EPA originally designed the self-audit program for new owners of exploration and production facilities in the oil and natural gas industry. The program, and its matter-of-fact, solutions-oriented approach, was so successful at gaining industry cooperation, reducing transaction costs and improving efficiencies that the EPA decided to expand it to include existing owners. When the EPA was designing the new program, representatives talked about the program with stakeholders that included the following: • Environmental NGOs • States • The regulated community • Tribes Upstream oil and natural gas facilities sometimes can have numerous emission violations. By temporarily expanding our self-audit program to existing owners, we expect more facilities to return to environmental compliance. This incentive to identify, correct and self-disclose violations will provide additional public health and environmental protection in the surrounding communities. Susan Bodine, EPA Assistant Administrator for Enforcement and Compliance Assurance continued from page 9 In December 2019, the EPA announced a yearlong sign-up period for an expanded audit program that could now be used by existing owners of oil and natural gas exploration and production facilities. The audit program was designed to accelerate compliance with the Clean Air Act and other rules that are intended to protect public health and the environment. It allows companies to find, disclose and correct their violations. For businesses within the oil and natural gas industry, one of the most significant barriers to compliance is uncertainty about audit terms, up-front expectations for corrective actions, and concerns about penalties. The program stream- lines the problem-solving process so companies can reach agreements faster and mitigate the penalties. More specifically, the EPA won’t impose civil penalties for violations on existing owners that make and follow an agreement with the EPA. The program is specifically designed to address concerns about excess emissions from control systems for tanks and vapor at exploration and production facilities for oil and natural gas. The emissions can be caused by operation and maintenance, or they might be caused by design issues. Thank You to Our Sponsor 10 UP DATE