While rulemakings under the Administrative Procedure Act typically take several years from proposal to enactment, that can vary significantly. While some rules run a fairly standard course, others languish for years with no action nor any apparent reason for inaction. EPA’s recent revival of a proposed rule that is now, were it a person, old … Continue Reading
The Ohio State Emergency Response Commission (SERC) recently issued a memorandum to the State’s oil and gas well owners and operators, clarifying that they must comply with the reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA) despite a State law that seemingly allows hydraulic fracturing (also known as “fracking”) operations to avoid such requirements. … Continue Reading
