If you are a conventional or unconventional oil and gas operator in Pennsylvania, you have likely received a recent letter from DEP requiring, for the first time, reporting of your greenhouse gas (GHG) emissions. In requiring GHG reporting, DEP may be exceeding its statutory and regulatory authority. Oil and gas operators may wish to explore their options in responding to the letter, which could include a legal challenge, responding with the requested information but with a reservation of rights to object to DEP’s authority in the future, or other action/inaction. If a legal challenge is considered, it must be brought within 30 days of the date of the operator’s receipt of the letter.
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