Consent Decree Support

A Consent Decree is a court-approved agreement between a company and the government that outlines specific actions required to correct alleged environmental violations - often under the Clean Air Act.

For oil and gas operators, that can mean retrofitting facilities, implementing monitoring programs, submitting self-disclosures or reporting compliance activities for years. 

Consent Decrees often cover hundreds (sometimes thousands) of facilities, and come with steep penalties for non-compliance.

Whether you’re at the beginning of a Consent Decree or trying to close one out, there’s a lot to manage - and very little room for error.

Who We Help

Consent Decrees are formal, enforceable and demanding. If you’re dealing with one, you already know.

We typically support operators who are:

  • Negotiating the terms of a Consent Decree

  • Managing active requirements across dozens - or thousands - of sites

  • Submitting plans, reports, or self-disclosures to regulators

  • Preparing for termination  by compiling a termination report

No two Consent Decrees are the same, but they all involve large volumes of technical work, court-enforceable deadlines, and little margin for error.

While many companies wait until the decree is finalized to get support, we’ve seen how early involvement can flag unrealistic requirements, build stronger systems and processes, and prevent bigger issues later.

What’s Included in a Consent Decree?

Consent Decrees typically include requirements across several categories. Depending on your situation, you may need to:

  • Implement environmental mitigation projects like retrofitting drill rigs or converting to instrument air pneumatics

  • Create and maintain detailed inspection schedules

  • Submit semi-annual or annual compliance reports

  • Self-disclose potential violations within strict timelines

  • Respond to regulator questions, or requests for data, documentation or corrective actions

  • Compile final termination reports years later

In many cases, operators underestimate how much technical work is involved, especially when legal teams are the ones negotiating the decree.

That’s why early technical input matters.

3 Common Challenges with Consent Decrees

We’ve worked with operators managing more than 2,000 facilities under Consent Decrees, and we’ve seen a few patterns:

  1. Unrealistic Requirements

    Once a decree is signed, the terms are locked in. If no one flags the technical challenges up front, it becomes difficult (and expensive) to change them later.

  2. Reporting Risk

    Missing a single report or self-disclosure can trigger daily fines - starting at $500 and climbing to $7,500 per day in some cases.

  3. Unclear Termination Path

    Even after the major work is done, the final report must be defensible. Regulators can (and do) request additional data years later, and errors or omissions can delay closure.

When is Support Most Valuable?

Support can help at any point, but here’s where we’ve seen the biggest impact:

  • During negotiation - Helping technical, legal and regulatory teams align before terms are finalized

  • During implementation - Building tracking systems, managing inspections, reviewing reports and coordinating disclosures

  • Before termination - Reviewing the full compliance history, fixing errors and compiling a clean final submission

Many Consent Decree requirements eventually influence future state or federal regulations. Getting it right now can put your team in a better position down the road.

How We Help

Here’s how we support operators managing Consent Decrees:

  • We’ve negotiated with regulators and supported operators across multiple EPA Regions.

  • We’ve managed systems for more than 2,000 sites under active Consent Decrees.

  • We build inspection schedules, tracking systems and reporting tools from the ground up.

  • We lead regulator meetings and help clients respond confidently to EPA and state agency requests.

  • We prepare and QA final termination reports so operators can close out Consent Decrees without unnecessary delays.

Whether you’re in the early stages or deep into implementation, we’re here to help.

Consent Decree FAQs

What’s the difference between a Consent Decree and a standard regulatory requirement?

A Consent Decree is court-enforceable. Once filed, the terms are legally binding, and failing to meet them can result in daily fines and extended oversight.

Can a Consent Decree be changed once it’s signed?

Major changes require regulatory approval and sometimes court involvement - and the process can take months or possibly years.

What happens if I miss a reporting deadline?


You could face escalating daily penalties and additional scrutiny. Having a strong tracking and QA system helps avoid those risks.