While these may work for EOM, it may be that individual production situations and well siting may not be conducive to meeting these suggestions. What is a fiscal inconvenience to a big operator can be a deal breaker for smaller ones.
Some suggestions may be good; Amerada Hess, now known as Hess, designed locations that very closely resemble what the BLM eventually adopted as their requirements, well before the BLM had requirements, and the result was a cleaner industry, at least here.
Not having seen what the proposals made by EOM are, I can't speak to them specifically, only say they could be a good industry proffered guideline, or a tendered requirement that would tilt the playing field in EOM's favor. There is advantage in having the industry suggest such, because the people suggesting it at least are knowledgeable, unlike the average legislator and all too many appointed regulators.
Unfortunately, all that really asks the wrong question. The right question is one of why there is insane pandering to the AGW/Climate Change crowd in the first place, because such only grants some apparent legitimacy to their claims of human caused warming.