The State Review process was created in 1989 by the Interstate Oil & Gas Compact Commission (IOGCC) Council on Regulatory Needs in response to the U.S. Environmental Protection Agency’s (EPA) determination that certain oil and gas exploration and production wastes should not be regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA). EPA provided several reasons for this exemption, including the fact that oil and gas producing states had programs in place to manage these wastes. However, EPA noted that regulatory gaps in state waste management programs existed and should be addressed by the states.
To address those gaps, the Council on Regulatory Needs developed an initial set of Guidelines for state oil and gas waste management programs and established a review process that included input from the oil and gas industry, regulators, and the environmental community. This became known as the “State Review” process.
From 1989 to 1998 the State Review process was managed by IOGCC. In 1999 an independent, multi-stakeholder organization named State Review of Oil and Natural Gas Environmental Regulations (STRONGER) was created to manage and advance the process.
Since its inception, STRONGER has expanded the scope of the Guidelines from their initial three topics associated with exploration and production waste management to nine topics addressing a wide array of environmental issues associated with oil and gas development. To date, 24 state programs accounting for regulatory oversight over 90% of U.S. domestic, onshore production have volunteered for at least one State Review, with many programs volunteering for multiple reviews.