Strategies to Survive and Thrive in a Low Oil Price Environment

Adapting business strategies to navigate a prolonged period of lower oil and gas prices is a challenge that many companies throughout the Middle East and wider world are currently facing up to. While surviving such a volatile commodity cycle is the main priority for some, other corporates are using sub $50 a barrel oil as an opportunity to innovate and recalibrate their businesses. This was certainly the key takeaway from the recently held Abu Dhabi International Petroleum Exhibition and Conference (ADIPEC), where the overall mood amongst major companies at the industry symposium was upbeat...

EPA Requires Natural Gas Processing Facilities to Annually Report Emissions to National Database; A Classic Example of Sue and Settle

If the current EPA has its way, natural gas processing facilities will soon be required to report release and waste management data in accordance with Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), otherwise known as the Toxics Release Inventory (TRI). On January 6, 2017, EPA published in the federal register a proposal to add natural gas processors to the list of industries that are subject to TRI annual reporting. EPA’s decision arose out of an Administrative Procedure Act (APA) petition filed by an environmental group in 2012 and is a classic example of the...

Down to the Wire, the U.S. Army Corps of Engineers Reissues Nationwide Permits

On January 6, 2017, the U.S. Army Corps of Engineers (“Corps”) published the final rule reissuing 50 nationwide permits (“NWPs”) and issuing two new NWPs. The NWPs will take effect on March 19, 2017, and will replace the existing NWPs that are set to expire on March 18, 2017 (“2012 NWPs”). States and industry groups had previously expressed concern that if the NWPs were not finalized in early January, there would be inadequate time for mandatory state coordination under Section 401 of the Clean Water Act and the coastal consistency provisions of the Coastal Zone Management Act, resulting in...

U.S. Futures Exchanges Disciplinary Actions Report - December 2016

NYMEX NYMEX 16-0530-BC Position Limits Violation of Rule 562 – Position Limit Violations. At the close of business on a single day in September 2016, a member firm held a short position which was 38.4% over the standard expiration month limit for October 2016 Henry Hub Natural Gas Futures contracts. Pursuant to a settlement offer, the member firm neither admitted nor denied the violation. $40,000 penalty. ICE 2015-114 Block Trades; Misc. Violation of Exchange Rule 4.01 - Duty to Supervise; Rule 4.02(c) – Trade Practice Violations; Rule 4.02(d) – Trade Practice Violations; Rule 4.04 – Conduct...

Obama Bans Drilling Offshore Atlantic, Arctic – But For How Long?

With a new President on the White House doorstep, President Obama has announced a ban – ostensibly permanent – on offshore oil and gas drilling in federal waters along the Eastern seaboard and offshore Alaska. President Obama appears to be relying upon a seldom-used provision of the 1953 Outer Continental Shelf Lands Act (“OCSLA”) 43 U.S.C. §§ 1331 et seq.), which allows the President to withdraw any “unleased lands of the outer Continental Shelf.” Whether the ban proves permanent is likely to be tested politically and legally, as the Trump Administration takes office alongside a Republican-...

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