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Eric handles a variety of complex business and corporate litigation matters involving energy law, environmental law and complex commercial disputes. His practice includes work with chemical and industrial manufacturing entities, as well as energy exploration, production and transmission companies.

In February 2013, we reported that the Ohio Environmental Protection Agency (Ohio EPA) had issued proposed revisions to its Model General Permit for oil and gas well-site production operations. On April 4, Ohio EPA announced that it had finalized those revisions. The revisions bring the Model General Permits up-to-date with changes in the law since Ohio EPA originally issued the permits and make other changes to respond to industry comments. The revisions also include revised leak detection and repair requirements, which have been the subject of much recent discussion.

Ohio law generally requires each new source of air pollution to obtain a pre-construction permit from Ohio EPA’s Division of Air Pollution Control before “begin[ning] actual construction, erect[ing], locat[ing] or affix[ing] [the] air contaminant source.” Ohio law also requires sources of air pollution to obtain operating permits. Larger sources typically obtain permits-to-install (PTIs) and “Title V” operating permits; smaller sources typically obtain combined permits-to-install and operate (PTIOs). Ohio EPA may also develop Model General Permits — model PTIs and PTIOs — for categories of sources. Sources may choose to apply for regular PTIs or PTIOs if they like, but Model General Permits can be obtained more quickly, because, as Ohio EPA has explained, “all the terms and conditions of the permit have been developed in advance.”
Continue Reading Ohio EPA issues revised Model General Permits for oil and gas wells

Ohio law authorizes the Ohio Environmental Protection Agency (Ohio EPA) to “develop a model general permit for any category of air contaminant sources, or specific portions of any category of air contaminant sources,” subject to certain specified conditions. Ohio law also permits certain categories of air pollution sources to avoid the Permit-To-Install and Operate (“PTIO”)

On April 17, 2012, the United States Environmental Protection Agency (EPA) issued final revised New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs) for the oil and natural gas industry.  Four months later, EPA published those rules in the Federal Register.

EPA’s website provides summaries of the new rules’ requirements for natural gas well sites, natural gas gathering and boosting stations, gas processing plants, natural gas transmission compressor stations, and the oil industryIn short, the rules:


Continue Reading EPA’s Clean Air Act New Source Performance Standards for the Oil and Gas Sector Finally Appear in the Federal Register