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EPA’s Methane ‘Super-Emitter’ Proposal: Getting Outside Help

A worker in the oil and gas industry
By David Mandelbaum on January 3, 2023
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Earlier this month, the Environmental Protection Agency (EPA) published a “supplemental notice of proposed rulemaking,” calling for comments on air pollution standards for control of methane emissions from new and existing facilities in the oil and natural gas industry. See 87 Fed. Reg. 74,702 (Dec. 6, 2022). Among those standards are specific rules concerning “super-emitter” events, events with emissions of more than 100 kilograms (about 6,400 cubic feet) of methane per hour.

Continue reading the full article, published but the Legal Intelligencer Dec. 29. Reprinted with permission.

Photo of David Mandelbaum David Mandelbaum

David G. Mandelbaum represents clients facing problems under environmental laws. He regularly represents clients in lawsuits and also has helped clients achieve satisfactory outcomes through regulatory negotiation or private transactions. A Fellow of the American College of Environmental Lawyers, David teaches Superfund, and…

David G. Mandelbaum represents clients facing problems under environmental laws. He regularly represents clients in lawsuits and also has helped clients achieve satisfactory outcomes through regulatory negotiation or private transactions. A Fellow of the American College of Environmental Lawyers, David teaches Superfund, and Oil and Gas Law in rotation at the Temple University Beasley School of Law as well as an environmental litigation course at Suffolk (Boston) Law School.

Since United States v. Atlas Minerals, the first multi-generator Superfund contribution case to go to trial in 1993, Mr. Mandelbaum has been engaged in matters involving allocation of costs among responsible parties, especially under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).  He has tried large cases and resolved others as lead counsel.  He has written, spoken, and taught extensively on the subject.  More recently he also has been engaged to assist lead counsel from this firm and others:

  • to develop cost allocation methodologies;
  • to craft expert testimony in support of a favored methodology (given a definition of “fairness,” why one methodology better tracks it than another);
  • to develop efficient case management approaches; and to assist private allocation as part of the neutral team.

Concentrations

  • Air, water and waste regulation
  • Superfund and contamination
  • Climate change
  • Oil and gas development
  • Water rights
Read more about David MandelbaumEmailDavid's Twitter Profile
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  • Posted in:
    Energy, Environmental
  • Blog:
    E2 Law Blog
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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