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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…
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”) process and, instead, effectively obtain a permit-by-rule, if they meet certain rule-based “criteria, emission limitations, conditions for operation and [record-keeping…
Financial institutions’ lawyers working in Ohio (and their clients) should take note of an important development regarding the law of attorney-client privilege. On December 20, 2012, Governor John Kasich signed into law Amended Substitute House Bill 461, which makes important changes to Ohio’s attorney-client privilege statute, R.C. 2317.02(A)(1).  Until recently, Ohio’s attorney-client privilege statute stated that the attorney-client privilege would prevent an attorney from testifying in deposition or at trial except “by express consent…
As we reported in the Oil & Gas Law Report on August 29, the U.S. Environmental Protection Agency issued new air regulations for the oil and gas industry on April 17, 2012.  As summarized by the EPA: The newly established NSPS for the Crude Oil and Natural Gas Production source category regulate volatile organic compound (VOC) emissions from gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage vessels and leaking components at onshore…