Three federal methane regulations directly affect upstream and midstream oil and gas operators in the United States, and each one carries a different regulatory status as of July 2026. OOOOa remains in effect for new and modified sources, and operators must continue meeting its compliance deadlines. [1] Congress disapproved EPA’s implementing rule for the IRA Methane Waste Emissions Charge in February 2025, leaving no enforceable charge. [2] OOOOb and OOOOc, published by EPA in 2024, face potential repeal or administrative stay and are not reliable planning targets.

Compliance teams that do not separate these three rules by current status risk spending resources on requirements that may never take effect while overlooking obligations that remain fully enforceable.

OOOOa Remains Enforceable, IRA Methane Charge Is Rescinded

Two of the three federal methane rules sit on solid ground. Operators can plan around both with confidence, because neither status is likely to shift in the near term.

OOOOa Applies to New and Modified Sources

OOOOa, codified at 40 CFR Part 60, Subpart OOOOa, applies to new, modified, and reconstructed oil and gas sources and remains in effect. [1] The rule requires leak detection and repair (LDAR), limits on pneumatic controller and pump emissions, and controls on storage vessels, among other source categories. [1] EPA promulgated OOOOa in June 2016. [1] The current administration has not proposed changes to OOOOa.

Sources that commenced construction or modification after September 18, 2015 fall under OOOOa. [1] Compliance teams should maintain OOOOa LDAR schedules and recordkeeping without interruption.

The IRA Methane Charge Has No Implementing Framework

Congress disapproved EPA’s implementing rule for the IRA Methane Waste Emissions Charge in February 2025. [2] The underlying IRA statutory provision (Section 60113) still exists in the U.S. Code, but without an implementing rule EPA cannot assess or collect the charge. [2] No operator owes a methane charge payment under current law.

Operators who budgeted for the charge or built it into forward-looking cost models should remove it from active compliance planning. The Congressional Review Act prohibits EPA from issuing a new rule that is “substantially the same” without new authorizing legislation. [3] That prohibition sharply limits the pathway for reimplementation. The detail most compliance teams overlook: the IRA charge is not just paused, it is effectively dead unless Congress acts again.

What Is Uncertain: OOOOb and OOOOc Face Active Repeal Risk

OOOOb and OOOOc have uncertain regulatory status as of July 2026 and should not be treated as enforceable obligations. OOOOb updates new source performance standards for sources constructed or modified after December 6, 2022, with expanded requirements beyond what OOOOa covers. [4] OOOOc creates emission guidelines directing states to develop implementation plans for existing sources. [4]

The current administration has signaled opposition to the existing-source provisions. In April 2026, EPA finalized a narrow burden-reduction rule for the 2024 OOOOb standards. [5] It eased the temporary flaring allowances for associated gas and the continuous net-heating-value monitoring requirement for flares and enclosed combustion devices. [5] That rule is already being challenged in court. Separately, EPA has signaled a broader reconsideration of OOOOb and OOOOc that remains ongoing, but it has not repealed or stayed the core standards. Congressional Review Act disapproval also remains a possible pathway. Operators cannot plan around OOOOb/c compliance dates while these proceedings remain open.

Separate from OOOOb/c, EPA is also reconsidering GHGRP Subpart W reporting requirements. EPA has proposed suspending mandatory Subpart W reporting for its remaining segments through reporting year 2034, and it anticipated finalizing that action by July 2026. As of mid-July 2026, EPA has not issued that final suspension rule, so mandatory Subpart W reporting remains on the books. The RY2025 GHGRP reporting deadline has already been moved from March 31 to October 30, 2026. [6] For a detailed analysis of the Subpart W situation, see GHGRP Subpart W Reporting in 2026: What Is Still Required.

State programs are unaffected by either of these federal actions. Colorado’s ONGAEIR remains fully in effect with a June 30 annual deadline, as do comparable programs in New Mexico, Texas, and other producing states. [7]

How Operators Should Structure Compliance Planning Now

Compliance teams should maintain full OOOOa compliance, close out the rescinded IRA charge from budgets, and take a conditional approach to OOOOb/c.

OOOOa work continues without change. [1] LDAR programs, pneumatic controller requirements, and storage vessel controls under OOOOa are enforceable and subject to inspection. [1] Any operator that has deprioritized OOOOa compliance because of broader regulatory confusion has misread the landscape.

The IRA methane charge requires no further action. Budget line items, cost projections, and compliance timelines that incorporated the charge should be updated to reflect its rescission.

OOOOb/c calls for conditional planning. Operators should identify which existing sources would fall under OOOOc if the rule survives and estimate what compliance costs those requirements would impose. That analysis is cheap relative to the alternative. Capital expenditures on OOOOb/c-specific equipment or physical modifications are not, and operators should defer those until the rule’s status is resolved.

State-level obligations remain the most concrete near-term compliance priority for most operators. For Colorado operators, the ONGAEIR annual report deadline remains June 30, 2026, and a filing checklist is available at Colorado ONGAEIR Due June 30: A Practical Filing Checklist. [7]

Frequently Asked Questions

Is OOOOa the same rule as OOOOb/c?

OOOOa and OOOOb/c are separate subparts under 40 CFR Part 60 with different applicability scopes and different regulatory statuses. [8] OOOOa applies to sources constructed or modified after September 18, 2015, has been in effect since 2016, and is not subject to repeal. [1] OOOOb updates standards for sources constructed or modified after December 6, 2022, and OOOOc creates emission guidelines for existing sources. [4] Changes to OOOOb/c do not affect OOOOa obligations.

Do state reporting requirements change if OOOOb/c is repealed?

State programs operate under independent state authority and are not affected by OOOOb/c. Colorado’s ONGAEIR, New Mexico’s methane rules, and Texas air quality requirements remain in effect regardless of what happens to OOOOb/c at the federal level. Several states have emission control requirements that exceed what OOOOb/c would require. [9] Operators must continue meeting all applicable state requirements on their existing schedules.

Should operators invest in OOOOb/c compliance work now?

Operators should not commit capital to OOOOb/c-specific modifications while the rule’s status is uncertain. Identifying covered sources and estimating compliance costs is a reasonable investment. That preparatory work positions compliance teams to act quickly in either direction. EPA or Congress could resolve OOOOb/c on a timeline that is hard to predict, and operators who have scoped their exposure will respond faster than those who waited.

What happens to GHGRP Subpart W while these rules are being resolved?

GHGRP Subpart W reporting faces its own uncertainty, separate from OOOOb/c. EPA is reconsidering whether to suspend mandatory Subpart W facility-level reporting for its remaining segments through reporting year 2034. EPA anticipated finalizing that decision by July 2026, but as of mid-July 2026 it has not issued a final rule. The RY2025 GHGRP deadline has already been moved from March 31 to October 30, 2026. [6] Operators should track OOOOb/c and GHGRP developments as separate proceedings, since each could be resolved on a different timeline and with a different outcome.

This post is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel or a compliance professional for guidance specific to your operations and jurisdiction.

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References

  1. EPA, “Standards of Performance for Crude Oil and Natural Gas Facilities,” 40 CFR Part 60, Subpart OOOOa, available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-60/subpart-OOOOa.
  2. Congressional Review Act disapproval of EPA’s implementing rule for the IRA Methane Waste Emissions Charge (IRA Section 60113); H.J.Res.35, signed into law as Public Law 119-2 on March 14, 2025.
  3. Congressional Review Act, 5 U.S.C. § 801(b)(2) (prohibition on substantially similar rules following CRA disapproval).
  4. EPA, “Standards of Performance and Emission Guidelines for Oil and Natural Gas Facilities,” 40 CFR Part 60, Subparts OOOOb and OOOOc, final rule published 2024, available at: https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry.
  5. EPA, 2026 Final Rule to Reduce Burden on the Oil and Natural Gas Industry, published April 9, 2026, FR Doc. 2026-06808, https://www.federalregister.gov/documents/2026/04/09/2026-06808/reconsideration-of-standards-of-performance-for-new-reconstructed-and-modified-sources-and-emissions.
  6. EPA, “Greenhouse Gas Reporting Program, Subpart W, Petroleum and Natural Gas Systems,” 40 CFR Part 98, Subpart W. GHGRP RY2025 deadline extension per FR Doc. 2026-03995.
  7. CDPHE, Colorado Oil and Natural Gas Sector Emission Inventory and Reporting (ONGAEIR) program, annual reporting deadline June 30.
  8. 40 CFR Part 60.
  9. Colorado Regulation 7; New Mexico methane rules (requirements exceeding federal NSPS in certain source categories).