Oil and gas standards resources

Recent data has shown the urgency to reduce emissions of methane, a potent greenhouse gas, and other harmful pollutants from the U.S. oil and natural gas sector. These emissions are also a significant source of energy waste. As a result, various state and federal agencies have moved forward with standards to measure and reduce these emissions.

This page contains comments and other technical and legal documents regarding these various standards.

Legal briefs and comments can be found in the tabs below:

  • Legal briefs regarding BLM's Venting and Flaring Rule (BLM)
  • Legal briefs and resources regarding EPA's New Source Performance Standard (EPA)
  • Regulatory comments and other documents related to oil and gas standards (Comments)


Litigation Challenging EPA Failure to Establish Standards for Existing Sources

Opposition to EPA's request for stay of litigation
Complaint Challenging EPA Failure to Establish Standards for Existing Sources

Notice of intent to sue for failing to adopt emission guidelines for existing sources in the oil and natural gas sector.

Litigation on request for 90-day stay of requirements under EPA's New Source Performance Standards

Order denying rehearing
Petition Opposing En Banc Rehearing
Request for hearing En Banc
Court mandate
Motions to Issue Mandate
Court Order Addressing Mandate
Briefs on July 3rd court order
Reply brief in opposition to a stay
Reply briefs in support of a stay
Motions to intervene in support of EPA
Challenge to EPA stay of NSPS
EPA request for stay of requirements under NSPS
Federal Register notice of stay of provisions of NSPS
  • EPA Grant of Reconsideration and Stay [PDF]

Litigation on Abeyance Motion Under EPA's New Source Performance Standards

Abeyance order

May 18, 2018

Motion to Hold Case in Abeyance

Litigation on EPA's New Source Performance Standards

Motion to Withdraw from the case
Motions to Intervene for EPA


Litigation over Rescission of BLM's Waste Prevention Rule

Merits Litigation in the Northern District of California

Scroll down for older litigation on BLM’s Waste Prevention Rule

Merits briefing

Merits Issues and Briefing Schedule

The Court directed each group to file a letter indicating which issues it intended to brief. The Court approved the briefing schedule consented to by all groups in the Case Management Schedule. The briefing schedule was triggered when BLM filed the Administrative Record on March 8, 2019.

Case Initiation

The states of California and New Mexico (plaintiff states) filed a complaint challenging BLM’s Rescission of the Waste Prevention Rule on September 18, 2018 and EDF, as part of a conservation and tribal group coalition (citizen groups), filed a complaint challenging the Rescission on September 28, 2018. These two cases were consolidated on October 25, 2018 before Judge Yvonne Gonzalez Rogers. The Court also granted motions to intervene in support of BLM for the state of Wyoming and three industry groups – Western Energy Association (WEA), Independent Petroleum Association of America (IPAA), and American Petroleum Institute (API).

Earlier merits litigation
Reply in Support of Motion for Stay Pending Appeal
Responses to Motions to Stay in 10th Circuit
  • Wyoming and Montana [PDF]
  • WEA and IPAA [PDF]
  • Motions for stay of district court order pending appeal in the 10th Circuit
    Motions to Dismiss 10th Circuit Appeal
    Rejection of request for stay of order
    Order staying waste prevention rule
    Requests for Stay
    Order lifting litigation stay
    Requests to lift the litigation stay
    Merits Briefs
    Briefs on second request for Preliminary Injunction
    Motions To Intervene in Support of BLM
    Documents on initial request for Preliminary Injunction
    Challenge to BLM’s compliance date amendment in the Northern District of California
    Order granting Preliminary Injunction and denying transfer
    Replies In Support of Preliminary Injunction
    Response to request for Preliminary Injunction
    Request for Preliminary Injunction
    Venue Transfer Briefing
    Challenge to BLM’s initial stay of the rule in the Northern District of California
    Order Granting Motion for Summary Judgement

    October 4, 2017

    Reply briefs in support of Motion for Summary Judgement
    Amicus briefs in support of Plaintiffs
    Amicus briefs in support of Defendants
    Opposition to Motion for Summary Judgement
    Motion for Summary judgement
    Complaints over stay of requirements of BLM's Venting and Flaring rule
    BLM notice of stay of requirements of Venting and Flaring rule
    Documents on Venue Transfer


    Supplemental Resources

    Supplemental Joint Environmental Comments on EPA's Proposed NSPS Rulemakings

    EDF Comments Opposing EPA's Proposal to Remove Methane Regulation for Oil & Gas

    Comments on EPA’s Reconsideration of New Source Performance Standards

    EPA Comment period on Two-year Stay

    Comments on BLM Venting and Flaring Rule Revision proposal

    Comments on EPA's proposal to rescind the Control Technique Guidelines

    Information Collection Request

    EPA's Information Collection Request (ICR) for use in establishing standards for existing sources

    New Source Performance Standards and related standards

    Finalized by the Environmental Protection Agency (EPA) in May 2016

    Venting and Flaring Rule

    Finalized by the Bureau of Land Management (BLM) in November 2016

    Subpart W Revisions

    Part of EPA's Greenhouse Gas Reporting Program

    Leak detection and repair (LDAR)

    Supplemental documents

    Colorado Regulation 7

    Adopted in February 2014