The Department of Interior, Bureau of Land Management (BLM), published the final rule regarding “Waste Prevention, Production Subject to Royalties, and Resource Conservation” in the Federal Register on November 18, 2016. Trihydro has reviewed the rule and prepared a document outlining the environmental issues that have garnered the greatest interest, which are the subject of this regulation’s more commonly used name: the “BLM Venting and Flaring Rule."

Following review of the rule, Trihydro believes the most important issues of concern to the industry are that the rule:

• Is applicable to oil and gas production operations on Federal (BLM) and tribal lands (other than Osage Tribe).
• Applies to both existing and new production operations.
• Requires submission of a Waste Minimization Plan with Applications for Permit to Drill (APD) submitted after January 17, 2017. This plan is intended to address practices to reduce flaring, including timing for pipeline/sales connections.
• Establishes broad monitoring requirements similar to EPA’s NSPS OOOOa.
• Is effective January 17, 2017.

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