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Mar. 23
2023

Spirit’s Carbon Journey, Part 2

Publications

In Part 2 of Spirit’s carbon journey, we discuss how our company pivoted to offset Spirit’s business-related travel and total commuting emissions. To better align with industry best practices, Spirit adopted the use of Renewable Energy Certificates (RECs) to offset our electricity consumption rather than carbon offsets. Finally, in addition to the landfill gas capture credits used to offset 2019 and 2020, Spirit purchased offsets for carbon injected concrete and biochar to address Scope 1 and Scope 3 emissions.

Mar. 20
2023

TCEQ Has Issued CGP Renewal

Regulatory Updates

TCEQ issued the renewal of the CGP with an effective date of March 5, 2023.

Feb. 6
2023

Spirit’s Carbon Journey, Part 1

Publications

Spirit’s journey to carbon offsets started by looking at our major emissions sources, gathering data from our building management on energy consumption, surveying employees to evaluate commuting emissions, and determining which emissions were most material to our business. Once we had a preliminary handle on the numbers, we evaluated several options for offsetting our emissions before settling on a landfill methane gas capture project for 2019 and 2020.

Jan. 30
2023

EPA Publishes Supplemental Oil and Natural Gas Sector Climate Rule

Regulatory Updates

On December 6, 2022, the EPA published a Supplemental Notice of Proposed Rulemaking in the Federal Register. The proposal is intended to significantly reduce emissions of GHGs and other harmful air pollutants from the Crude Oil and Natural Gas source category and affects 40 CFR Part 60 Subparts OOOOb and OOOOc. The EPA comment period is open until February 13, 2023.

Jan. 26
2023

EPA’s PM2.5 NAAQS Reconsideration Rule – Updated Feb. 1, 2023

Regulatory Updates

The EPA’s proposed particulate matter NAAQS Reconsideration Rule was published in the Federal Register on January 27, 2023. The EPA is proposing to lower the primary annual PM2.5 NAAQS, and they are requesting comments on the possibility of lowering the daily (24-hour) standard as well.

Jan. 16
2023

Final WOTUS Rule

Regulatory Updates

On December 30, 2022, the US EPA and the USACE finalized the rule establishing the definition of “waters of the United States”. This definition will go into effect 60 days after publication in the Federal Register.

Jan. 12
2023

Reporting Season Reminder

Publications

There are many different compliance reporting deadlines in Q1 and Q2 of 2023. Be aware that some of these reporting obligations require careful planning and preparation time. SARA Tier II Reporting, Annual Waste Reporting, TRI Reporting, and Annual Training obligations should all be evaluated in January to determine which items may be due in Q1 and Q2.

Jan. 11
2023

Deadline for TCEQ MECT and HECT Program Allowance Trades

Publications

The TCEQ recently released a notice with important discussion points regarding the MECT and HECT Programs. Allowance trades for 2022 compliance under these programs are due by January 30, 2023.

Nov. 30
2022

Compliance Reminder Regarding Annual Sampling

Regulatory Updates

Facilities with an active NOI for the MSGP TXR050000 must conduct annual NEL sampling for stormwater discharges by December 31, 2022.

Nov. 21
2022

TCEQ Releases New Public Involvement Plan Requirements

Regulatory Updates

Starting November 1, 2022, the Texas Commission on Environmental Quality (“TCEQ”) will require that certain Air, Waste, Water, and Water Rights permits, and certain Registrations, complete a Public Involvement Plan (“PIP”) analysis. The agency has posted a preliminary screening document that an applicant can use to help determine the types of public outreach that may be required.

Oct. 19
2022

EPA Publishes Final Ozone Reclassification Rules in the Federal Register

Regulatory Updates

On October 7th, the ozone reclassification final rules for the 2008 and 2015 ozone standards were published in the Federal Register. These rules go into effect on November 7, 2022.

May. 18
2022

Spirit Releases Sustainability Management Plan

Publications

Spirit is proud to announce that in addition to our commitment to offset all our business-related carbon emissions, making us carbon neutral from 2019, we have released a Sustainability Management Plan (SMP) that serves as the foundation of our own internal journey towards integrating sustainability into the core of our business model.

Apr. 21
2022

EPA Proposes Rules for Ozone Nonattainment in Texas

Regulatory Updates

 The EPA published two proposed rules in the Wednesday, April 13th Federal Register regarding ozone nonattainment areas in Texas. 

Apr. 21
2022

EPA Proposes Rules for Ozone Nonattainment in Colorado

Regulatory Updates

The EPA published two proposed rules in the Wednesday, April 13th Federal Register regarding ozone nonattainment reclassifications in Colorado. 

Apr. 6
2022

Revisions to Colorado Regulation 22, Part B Affecting Upstream Operations

Regulatory Updates

In December 2021, the Colorado Air Quality Control Commission (AQCC) adopted a broad range of new regulations aimed at reducing emissions of greenhouse gas (GHG) pollutants and ozone precursors, with emission reductions prioritized in disproportionately impacted communities (DIC). The regulations adopted covered several broad topic areas and spanned both Regulation 7 and Regulation 22.

Apr. 6
2022

Revisions to Colorado Regulation 22, Part B Affecting Midstream Operations

Regulatory Updates

In December 2021, the Colorado Air Quality Control Commission (AQCC) adopted a broad range of new regulations aimed at reducing emissions of greenhouse gas (GHG) pollutants and ozone precursors, with emission reductions prioritized in disproportionately impacted communities (DIC). The regulations adopted covered several broad topic areas and spanned both Regulation 7 and Regulation 22.

Feb. 3
2022

Revisions to Colorado Regulation 7, Part D Affecting Both Upstream & Midstream Operations

Regulatory Updates

In December 2021, the Colorado Air Quality Control Commission adopted a broad range of new regulations aimed at reducing emissions of greenhouse gas pollutants and ozone precursors, with emission reductions prioritized in disproportionately impacted communities (DIC). The regulations adopted covered several broad topic areas and spanned both Regulation 7 and Regulation 22.

Feb. 3
2022

Revisions to Colorado Regulation 7, Part D Affecting Midstream Operations

Regulatory Updates

In December 2021, the Colorado Air Quality Control Commission adopted a broad range of new regulations aimed at reducing emissions of greenhouse gas pollutants and ozone precursors, with emission reductions prioritized in disproportionately impacted communities (DIC). The regulations adopted covered several broad topic areas and spanned both Regulation 7 and Regulation 22.

Feb. 3
2022

Revisions to Colorado Regulation 7, Part D Affecting Upstream Operations

Regulatory Updates

In December 2021, the Colorado Air Quality Control Commission adopted a broad range of new regulations aimed at reducing emissions of greenhouse gas pollutants and ozone precursors, with emission reductions prioritized in disproportionately impacted communities (DIC). The regulations adopted covered several broad topic areas and spanned both Regulation 7 and Regulation 22.

Feb. 2
2022

EPA Finalizes the Addition of 1-Bromopropane to the HAP List Under Section 112 of FCAA

Regulatory Updates

On January 5, 2022, the EPA published a Final Rule in the Federal Register which officially adds 1-Bromopropane (1 BP) to the list of hazardous air pollutants (HAPs) regulated under Section 112 of the Federal Clean Air Act (FCAA). This rule goes into effect on February 4, 2022.

Nov. 18
2021

Methane Emissions Intensities: Sorting Through the Options for Oil and Gas

Publications

President Biden highlighted the impact of methane emissions on climate change at the Conference of Parties 26 (“COP26”) talks in October. The effect of methane emissions is further demonstrated by a proliferation of mandatory and voluntary programs to limit methane emissions throughout the oil and natural gas supply chains. Particularly critical for oil and gas operators, “methane intensity” is becoming a preferred approach for communicating methane emissions data and performance throughout the industry.

Nov. 16
2021

Upcoming Reporting Deadlines

Publications

Our team is equipped to assist clients in a wide range of industries to accomplish their reporting needs whether it be required by the state, the EPA, or even your stakeholders for CSR/ESG Reporting. Spirit’s experts are prepared to work with clients to develop complete and accurate reports, implement facility objectives, and provide necessary trainings and education on regulatory compliance.

Oct. 14
2021

Final Rule Published on Phasedown of HFCs

On October 5, 2021, the EPA published a Final Rule in the Federal Register: “Phasedown of Hydrofluorocarbons (HFCs): Establishing the Allowance Allocation and Program under the American Innovation and Manufacturing Act” (AIM Act). The AIM Act directs the EPA to phasedown production and consumption of HFCs in the United States by 85% over the next 15 years. The effective date of this final rule is November 4, 2021.

Oct. 12
2021

Expanded and New Ozone Nonattainment areas in Colorado and Texas

Regulatory Updates

Did you know the EPA is considering revisions to air quality designations under the 2015 ozone NAAQS? If so, did you realize the EPA intends to expand the Weld County, Colorado nonattainment designation and designate El Paso County, Texas as nonattainment? Well, it’s true.

Sep. 29
2021

Impacts of Colorado Ozone Nonattainment Bump Ups: DM/NFR

Regulatory Updates

Spirit has been keeping up with recent discussions regarding the Denver Metro/North Front Range (DM/NFR) ozone nonattainment area. As you may know, the DM/NFR ozone nonattainment area is currently classified as “serious” under the 2008 ozone standard and “marginal” under the 2015 ozone standard. This year (2021) is an attainment year for both of these standards.

Sep. 27
2021

Impacts of Texas Ozone Nonattainment Bump Ups: HGB, DFW, and San Antonio/Bexar County

Regulatory Updates

Have you been keeping up with recent discussions regarding the Ozone Nonattainment Areas in Texas? Spirit Has! As you may know, the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) ozone nonattainment areas are currently classified as “serious” under the 2008 ozone standard and “marginal” under the 2015 ozone standard. San Antonio/Bexar County is also “marginal” under the 2015 ozone standard (this area is attainment under the 2008 ozone standard). Another important piece of information is that 2021 is an attainment year for both standards.

Aug. 24
2021

Colorado Regulation 7 Deadlines

Regulatory Updates

With recent updates and changes to Colorado’s Regulation 7, you may be unaware of upcoming deadlines for oil and gas operators.

Aug. 16
2021

Update on EPA’s Proposed Rule to Phase Down HFCs

Regulatory Updates

Are you keeping track of hydrofluorocarbon (HFC) related items? If you are, then you may be interested in the following information. On May 19th, 2021, the EPA published a Proposed Rule in the Federal Register entitled, “Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act”.

Jul. 15
2021

Western Burrowing Owl Surveys: CPW Updates Survey Protocols

Regulatory Updates

Are you planning construction on your project site? Do you have prairie dog burrows or other mammal burrows such as those created by badgers or ground squirrels on the site? If so you will need to conduct surveys for the Western Burrowing Owl.

Jul. 13
2021

EPA Proposes 1-Bromopropane to be Added to HAP List Under Section 112 of FCAA

Regulatory Updates

On June 11, 2021, the EPA published an “Advanced Notice of Proposed Rulemaking” in the Federal Register. This notice concerns the addition of 1-Bromopropane (1‑BP) to the list of Hazardous Air Pollutants (HAPs) regulated under Section 112 of the Federal Clean Air Act (FCAA).

Jul. 1
2021

TCEQ Publishes Changes to Chapter 116 – Allows Use of Project Emissions Accounting within Major NSR Applicability Analysis

Regulatory Updates

Have you seen the June 25, 2021 edition of the Texas Register? The TCEQ published changes to 30 TAC 116 (Chapter 116) that will allow a company to use the EPA’s “Project Emissions Accounting” (PEA) capability within the Major New Source Review (Major NSR – PSD and Nonattainment Review) applicability analysis.

Jun. 23
2021

MSW Landfill Rule

Regulatory Updates

On May 21, 2021, the Environmental Protection Agency (EPA) published a new Final Rule entitled “Federal Plan Requirements for Municipal Solid Waste (MSW) Landfills That Commenced Construction On or Before July 17, 2014, and Have Not Been Modified or Reconstructed Since July 17, 2014”?

Jun. 14
2021

Colorado Pneumatic Controller Rule Sets New Standard: What you need to know

This year, Colorado adopted a new rule affecting well production facilities and compressor stations that operate natural gas driven pneumatic controllers. These devices are designed to release small amounts of natural gas as they control processes at oil and natural gas facilities. Beginning May 1, 2021, all new or modified oil and gas facilities upstream of a natural gas processing plant in Colorado are required to use non-emitting pneumatic controllers.

May. 20
2021

Phasedown of Hydrofluorocarbons and Establishing the Allowance Allocation and Trading Program

Regulatory Updates

Did you know that on May 19, 2021, the EPA published a new proposed rule regarding the phasedown of hydrofluorocarbons (HFCs)?

May. 12
2021

EPA Enforcement Memo: Strengthen Enforcement & Develop Community Engagement

Regulatory Updates

On April 30th, 2021, the Acting Assistant Administrator at the EPA issued a memo entitled “Strengthening Enforcement in Communities with Environmental Justice Concerns”. In this memo, the EPA is instructing their offices to strengthen the enforcement of violations related to cornerstone environmental statutes.

Apr. 29
2021

Currently Trending: Renewable Diesel Fuels on the Rise

Publications

The production of renewable diesel fuels, sometimes called green diesel, in the United States is on the rise. Since renewable diesel is chemically the same as petroleum diesel, it may be used in its pure form (called R100) or mixed/blended with petroleum diesel similar to biodiesel blending.

Mar. 25
2021

How to Surf the ESG Wave

Publications

The ESG wave is cresting, and as it does, companies are being caught in various positions ranging from surfing it to being caught in the break. For those not yet riding the wave, there can be a lot of consternation that can ripple from the boardroom to the field. For Environmental Health and Safety Managers, this presents both risks and opportunity.

Feb. 25
2021

New Well Production Facility LDAR Requirements in Colorado

Regulatory Updates

The Colorado Air Pollution Control Division is implementing new well production facility LDAR requirements for facilities within 1,000 ft. of an occupied area which go into effect March 1, 2021.

Feb. 11
2021

TCEQ Clean Water Program for Oil & Gas

Regulatory Updates

Discharges associated with oil and gas activities, pipelines, and natural gas processing plants, will no longer fall under Railroad Commission of Texas jurisdiction.

Jan. 27
2021

Colorado Regulation 3 & 7 Deadlines

Regulatory Updates

Recent updates and changes to Colorado’s Regulations 3 and 7 may have you unaware of upcoming deadlines for oil and gas operators.

Jan. 19
2021

Annual Tier II Reporting – Due March 1st

Publications

2021 is officially here and one of the early annual compliance reporting requirements is just around the corner!

Nov. 4
2020

New Colorado Emission Inventory Reporting Requirements

Regulatory Updates

As part of the December 2019 rulemaking process, Colorado passed new emission inventory reporting requirements (EI) under Regulation No. 7. The new requirements apply to oil and natural gas sources located at or upstream of a natural gas processing plant.

Oct. 29
2020

Reporting Season – Spirit is Here to Help!

Regulatory Updates

Our team is equipped to assist clients in a wide range of industries to accomplish their reporting needs. Spirit’s experts are prepared to work with clients to streamline reports, implement facility objectives, and provide necessary trainings and education on regulatory compliance.

Oct. 27
2020

Colorado Air Quality Control Commission September 2020 Rulemaking: What You Need to Know

Regulatory Updates

As we head into the final months of 2020 (can you believe it?), the Colorado Air Quality Control Commission (“AQCC”) has finalized changes to Regulation Number 7, increasing regulations to reduce emissions from oil and gas facilities.

Oct. 8
2020

Revised Final Rules for NSPS OOOO and OOOOa

Regulatory Updates

On September 15, 2020, the EPA published the revised final rules for NSPS OOOO and OOOOa. Changes to these rules could affect your oil or natural gas facility. 

Aug. 20
2020

Colorado EI – Is BAMM the Route for You?

Regulatory Updates

Let Spirit assist you in determining if Best Available Monitoring Method (BAMM) is the approach for you.

Jul. 2
2020

Navigating the New Colorado Emission Inventory Requirements?

Regulatory Updates

Navigating the new Colorado EI requirements and submittal process?

Jun. 22
2020

Colorado Oil & Gas New Annual Emissions Inventory

Regulatory Updates

Beginning July 1st, oil and gas operators in Colorado will need to start collecting activity data on all emission sources for the new annual emission inventory.

Apr. 30
2020

Colorado APCD Temporarily Allowing Electronic Submission of APEN(s) and Construction Permits

Regulatory Updates

Are you submitting APEN(s) or construction permit applications to the Colorado Air Pollution Control Division during COVID-19?

Apr. 6
2020

EPA Enforcement Discretion Related to COVID-19 Pandemic

Regulatory Updates

Spirit’s summary of the recently issued Enforcement and Compliance Assurance Program memo.

Mar. 18
2020

TCEQ Extends 2019 Point Source EI Reporting Deadline

Regulatory Updates

The Texas Commission on Environmental Quality (“TCEQ”) has extended the 2019 Point Source Emissions Inventory (“EI”) Reporting deadline to on or before April 30, 2020.