Air Permit Renewal
Louis Rose successfully represented a midstream oil and gas company in negotiating renewals of air quality operating permits for three (3) of its Southeastern New Mexico gas processing plants. The plants, which are major emitting facilities, process sour (hydrogen sulfide containing) natural gas for transmission in interstate pipelines. They had been under enforcement actions for violation of emission limits in the applicable permits. Mr. Rose, in conjunction with the company’s staff, was able to avoid the imposition of stringent emission limits, monitoring and reporting requirements, while assuring that national and state ambient air quality standards were protected. Mr. Rose prepared detailed comments on the proposed permits, proposed alternative permit language and negotiated the ultimate permit conditions.