Energy & Environmental Law Blog : Energy & Environmental Lawyer & Attorney : Vorys, Sater, Seymour and Pease Law Firm : Oil, Gas & Green Technology

Ohio's new industrial activity storm water general permit went into effect January 1, 2012.  If you have an existing industrial activity general permit that is expired, you will need to submit to Ohio EPA a new Notice Of Intent (NOI) application form before March 31, 2012.  Ohio EPA's webpage that provides a Fact Sheet, NOI Forms and other information can be found here.

If you are covered under this permit, be sure to read it carefully as provisions have changed and will require additional compliance obligations. 

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On December 28, 2009, U.S. EPA issued a Notice of Availability of Preliminary 2010 Effluent Guidelines Program Plan (74 Fed. Reg. 68599) (see here) and asked for comments on both its preliminary 2010 Plan and on its 2009 review of existing effluent guidelines and pretreatment standards, including comments on industrial categories not currently regulated by effluent guidelines and pretreatment standards.  See Docket No. EPA-821-R-09-006 at www.regulations.gov.

Comments were submitted by both industry and environmental groups on the appropriateness of effluent guidelines for the oil and gas industry.  Earthjustice, for example, submitted comments urging U.S. EPA to expand its study of CBM operations "to include all techniques that may result in contamination of surface water or groundwater, including hydraulic fracturing in all formations."  See here.  The American Petroleum Institute filed comments, on the other hand, noting that CBM operations should not be subject to national effluent limitations guidelines and objecting to an expansion of U.S. EPA's study of CBM extraction to oil and gas operations more generally.

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The Delaware River Basin Commission has announced that natural gas production from shale formations located within the drainage area of the Basin's Special Protection Waters may not commence without first applying for and obtaining Commission approval.  This, according to the Commission, will impact most of the shale formations in the Basin in which new horizontal drilling and hydraulic fracturing techniques are being used.  More information can be found here.

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Cabot Oil and Gas Company has been charged with violations of Pennsylvania water law in connection with drilling certain natural gas wells in Susquehanna County, according to this report from News Channel 34.  A more detailed report can be found here from the Wayne Independent.

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Concerns over the impact of hydraulic fracturing have been raised with increasing frequency over the last several years.  This article from Scientific American is just one example of the kind of reporting we are seeing, challenging the exemption for frac water contained in the SWDA and a producer's community-right-to-know obligations.

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