EPA’s New Owner Clean Air Act Audit Program Could Streamline Acquisition Process for Upstream Oil and Gas Assets

The U.S. Environmental Protection Agency (“EPA”) is in the process of developing a New Owner Clean Air Act Audit Program (the “Audit Program” or the “Program”) for the upstream oil and gas sector. If finalized, the Audit Program could streamline the process of acquiring upstream oil and gas assets and allow parties to more easily manage Clean Air Act (“CAA”) compliance risks.