Federal methane rules, alongside state rules, shape what covered oil and gas sources must inspect, retrofit and budget for over the next several years. EPA, the U.S. Environmental Protection Agency that writes these rules, proposed another round of changes on October 29, 2026 [1]. Its virtual public hearing is November 16, 2026, and comments are due December 16, 2026 [2]. Plan around the wrong status and you may fund work that is never required, or miss work that is enforceable today.

OOOOb and OOOOc are EPA’s 2024 air standards for oil and natural gas facilities [3]. OOOOb sets standards for sources built, modified or reconstructed after December 6, 2022, and OOOOc gives states guidelines for regulating existing sources [3]. Both remain in force, and in 2025 EPA moved several compliance dates and the OOOOc state plan deadline to January 22, 2027 [4]. EPA is now reconsidering both, so their requirements may change, though the January 22, 2027 OOOOc state plan deadline still stands.

The post first covers OOOOa, EPA’s older methane standard, and the deferred methane charge under the Inflation Reduction Act (IRA). It then turns to the open OOOOb/c proceedings and EPA’s Greenhouse Gas Reporting Program (GHGRP), with a dated timeline. It closes with a planning approach and answers to common questions, for compliance and finance teams at upstream and midstream operators.

OOOOa Remains Enforceable, IRA Methane Charge Is Deferred to 2034

Two of the three federal methane measures have a clearer near-term status, though EPA’s October 2026 proposal would also amend OOOOa.

OOOOa Applies to New and Modified Sources

OOOOa, EPA’s earlier standard, covers oil and gas sources built, modified or reconstructed after September 18, 2015 through December 6, 2022, and remains in effect [5]. Its text sits at 40 CFR Part 60, Subpart OOOOa, part of the federal rulebook of performance standards for new stationary sources [6].

The rule requires leak detection and repair (LDAR), periodic surveys that find and fix leaking equipment, at well sites, compressor stations and gas processing plants [5]. It also limits pneumatic controller and pump emissions and controls storage vessels, among other source categories [5].

EPA’s October 2026 proposal would rescind the Super Emitter Program, whose start EPA had deferred to January 22, 2027, from OOOO, OOOOa, OOOOb and OOOOc [1]. Compliance teams should keep OOOOa LDAR schedules and recordkeeping running without interruption.

Congress Revoked the IRA Methane Charge’s Rule and Deferred the Charge

Congress voided the charge’s implementing rule in 2025 and moved the charge itself to 2034. The Inflation Reduction Act (IRA), a federal law, gave EPA new Clean Air Act authority that included a methane Waste Emissions Charge [7].

Congress disapproved EPA’s implementing rule for the charge in March 2025 [8]. EPA struck that 2024 rule (89 FR 91094, a Federal Register page where rules are published) from the federal code in May 2025 [9]. The statute itself, Clean Air Act Section 136, the provision that sets the methane charge, still stands [10].

A July 2025 law, P.L. 119-21, changed its start year from 2024 to 2034 [10]. No charge applies before then [10].

Operators can drop the charge from budgets for years before 2034, but weaker OOOOb/c rules could leave the 2034 charge without its compliance exemption. The Congressional Review Act prohibits EPA from issuing a new rule that is “substantially the same” without new authorizing legislation [11]. For what the charge still means for operators, see Inflation Reduction Act: What Is Left for Methane in 2026.

OOOOb and OOOOc Are in Effect but Under Reconsideration

OOOOb and OOOOc remain in force with some compliance deadlines extended, but their future is uncertain as of November 2026 [4].

The current administration is reconsidering OOOOb and OOOOc, including the existing-source emission guidelines. In April 2026, EPA finalized a narrow burden-reduction rule for the 2024 OOOOb and OOOOc standards [12]. It made technical changes that allow longer temporary flaring of associated gas and revise net-heating-value monitoring for flares and enclosed combustion devices [12]. That rule is already being challenged in court.

EPA Has Taken Seven OOOOb/c and GHGRP Actions Since July 2025

Since July 2025, EPA has published seven such actions, not counting correction notices: four on deadlines, one burden-reduction final rule and two proposals. They follow the 2024 rule’s March 8, 2024 publication and EPA’s March 12, 2025 announcement of a broader reconsideration [2].

DateActionSource
Jul 31, 2025Interim final rule extends OOOOb/c compliance dates[4]
Sep 16, 2025GHGRP reconsideration proposed, suspending Subpart W until reporting year 2034[13]
Dec 3, 2025Final rule further extends deadlines for net heating value (NHV) monitoring, which tracks the energy content of gas sent to flares, and for first reports; OOOOc state plans due January 22, 2027[4]
Feb 27, 2026Deadline for reporting year 2025 (RY2025), meaning 2025 emissions data, moved to October 30, 2026[14]
Apr 9, 2026Final rule allows longer temporary flaring and revises net-heating-value monitoring for flares[12]
Jun 8, 2026Environmental Defense Fund asks a federal appeals court to review the April rule
Oct 14, 2026RY2025 deadline moved to March 10, 2027[15]
Oct 29, 2026Broader OOOOb/c reconsideration proposed[1]
Nov 16, 2026Virtual public hearing on the October proposal[2]
Nov 30, 2026Due date for all OOOOb annual reports originally due earlier, including first and second reports, under the December 2025 rule[4]

The comment period pauses no deadline: deferred OOOOb annual reports are due November 30, 2026, and OOOOb equipment and OOOOc state-plan deadlines January 22, 2027. In the timeline, the first OOOOb reports fall due before comments close, and no final-rule date is set.

Timeline showing that EPA's October 29, 2026 proposal takes comments until December 16, 2026, while first OOOOb annual reports stay due November 30, 2026, OOOOc state plans January 22, 2027, and Subpart W reports March 10, 2027.

The October proposal would drop the sales-line routing requirement for associated gas from oil wells in favor of controls or flares achieving 95 percent reduction [1]. It would also remove the temporary flaring provisions that the April 2026 rule revised [1]. It also co-proposes lighter requirements for marginal or conventional well sites [1].

The March 2024 rule’s Congressional Review Act period lapsed, and it predates the lookback window; disapproval could still reach later OOOOb/c rules. New sources already fall under OOOOb on its extended deadlines, yet the open proceedings would revise both OOOOb standards and OOOOc existing-source guidelines. For what the standard requires of a covered site while it stands, see EPA OOOOb Explained: Who It Covers and What It Requires.

Separate from OOOOb/c, EPA is also reconsidering the GHGRP. The GHGRP is the EPA program that requires large emission sources to report their greenhouse gas data [16]. Its Subpart W, the section for oil and gas systems, covers ten industry segments, including onshore production, gathering and boosting, and natural gas distribution [17]. EPA proposed ending GHGRP reporting except Subpart W, dropping distribution and suspending other segments until RY2034; it now targets final action before March 10, 2027.

EPA had not finalized that suspension when it extended the reporting deadline again in October 2026, so mandatory Subpart W reporting remains on the books [15]. The deadline for RY2025 data, meaning 2025 emissions, moved from March 31 to October 30, 2026 [14], and again to March 10, 2027 [15]. For a detailed analysis of the Subpart W situation, see GHGRP Subpart W Reporting in 2026: What Is Still Required.

How Operators Should Structure Compliance Planning Now

Compliance teams should maintain full OOOOa compliance and drop the deferred IRA charge from budgets before 2034. For OOOOb/c, a conditional approach fits best.

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. OOOOc retrofit capital is not, and can wait for the state plan and rule status; a weaker rule may keep the 2034 charge exemption unavailable.

State-level obligations, such as Colorado’s annual emission inventory filing, remain a concrete compliance priority for operators in those states. Colorado’s ONGAEIR, the annual emission inventory operators file with the state health department, is due June 30 each year [18]. A filing checklist is available at Colorado ONGAEIR Due June 30: A Practical Filing Checklist.

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 [6]. OOOOa covers sources built, modified or reconstructed after September 18, 2015, through December 6, 2022; EPA proposes removing its Super Emitter provisions [5]. OOOOb updates standards for sources constructed or modified after December 6, 2022, and OOOOc creates emission guidelines for existing sources [3]. Changes to OOOOb/c can affect OOOOa sources, which are existing sources under OOOOc, and the October proposal also amends OOOOa.

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

State programs rest on state authority, but OOOOc reaches existing sources through state plans due January 22, 2027. Colorado’s ONGAEIR, New Mexico’s methane rules, and Texas air quality requirements remain state law, but OOOOc state plans due January 2027 may add to them. A federal repeal would not end state-law requirements, though state rules that adopt or cite the federal standards could change with them.

Should operators invest in OOOOb/c compliance work now?

Operators need not commit capital to OOOOc-specific retrofits while the rule is uncertain, though weakening it may keep the 2034 methane charge’s exemption unavailable. New sources remain subject to OOOOb on its extended deadlines; no OOOOb annual report is due before November 30, 2026 [4]. EPA or Congress could resolve OOOOb/c on a timeline that is hard to predict.

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

EPA is reconsidering whether to suspend mandatory Subpart W reporting until reporting year 2034 and remove the Natural Gas Distribution segment. As of its October 2026 deadline extension, EPA had not issued a final rule, so RY2025 reports remain due March 10, 2027 [15]. Track OOOOb/c and GHGRP as separate proceedings, since each could end on a different timeline.

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, “Additional Reconsideration Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review,” proposed rule, 91 FR 68234, October 29, 2026. https://www.govinfo.gov/content/pkg/FR-2026-10-29/html/2026-22082.htm
  2. EPA, “2026 Actions to Reduce Burden on the Oil and Natural Gas Industry,” accessed November 2026. https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-operations/2026-actions-reduce-burden-oil-and-natural
  3. 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.
  4. EPA, extension of NSPS OOOOb and EG OOOOc compliance deadlines, interim final rule, 90 FR 35966, July 31, 2025, and final rule, 90 FR 55671, December 3, 2025. https://www.federalregister.gov/documents/full_text/text/2025/07/31/2025-14531.txt; https://www.federalregister.gov/documents/full_text/text/2025/12/03/2025-21788.txt
  5. 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.
  6. 40 CFR Part 60.
  7. EPA, “Methane Emissions Reduction Program,” accessed November 2026. https://www.epa.gov/inflation-reduction-act/methane-emissions-reduction-program
  8. 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.
  9. EPA, “Congressional Review Act Revocation of Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions,” final rule, 90 FR 21225, May 19, 2025. https://www.federalregister.gov/documents/full_text/text/2025/05/19/2025-08688.txt
  10. Public Law 119-21, Section 60012(b), amending Clean Air Act Section 136(g), July 4, 2025. https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
  11. Congressional Review Act, 5 U.S.C. § 801(b)(2) (prohibition on substantially similar rules following CRA disapproval).
  12. 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.
  13. EPA, “Reconsideration of the Greenhouse Gas Reporting Program,” proposed rule, 90 FR 44591, September 16, 2025. https://www.govinfo.gov/content/pkg/FR-2025-09-16/html/2025-17923.htm
  14. 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.
  15. EPA, “Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027,” interim final rule, 91 FR 65112, October 14, 2026. https://www.federalregister.gov/documents/2026/10/14/2026-20982/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-reporting-year-2025-to
  16. EPA, “Learn About the Greenhouse Gas Reporting Program (GHGRP),” accessed November 2026. https://www.epa.gov/ghgreporting/learn-about-greenhouse-gas-reporting-program-ghgrp
  17. EPA, “Subpart W: Petroleum and Natural Gas Systems,” accessed November 2026. https://www.epa.gov/ghgreporting/subpart-w-petroleum-and-natural-gas-systems
  18. CDPHE, Colorado Oil and Natural Gas Annual Emission Inventory Reporting (ONGAEIR) program, annual reporting deadline June 30.