Inflation Reduction Act: What Is Left for Methane in 2026

A federal methane charge of 1,500 dollars per metric ton, on emissions above set intensity thresholds, is still law for large oil and gas facilities [1]. The charge is scheduled to apply to methane emitted from calendar year 2034 onward [1]. It would be assessed on the methane reports facilities file with the U.S. Environmental Protection Agency (EPA), the federal agency that administers the Clean Air Act [2]. The next of those reports, for 2025, is now due on 10 March 2027, after EPA moved the deadline twice [3].

The Inflation Reduction Act (IRA), a federal law signed in August 2022, created the first federal charge on methane emissions from oil and gas facilities [2]. That charge, called the waste emissions charge, is a fee on each metric ton of methane a facility emits above a set intensity [2]. Two laws passed in 2025 affected it, one voiding EPA’s rule and one amending the charge itself, and neither repealed it [2]. The problem is that the statute still stands while the machinery to run it does not, so “repealed” headlines mislead.

This guide is for oil and gas operators and compliance teams who need to know what the charge means for them today. It explains what the Act set up, what the two 2025 laws did, and what still binds an operator in 2026. It closes with a dated timeline, where a Measurement-Informed Inventory fits, and answers to common questions.

Quick Answer: The Inflation Reduction Act added Clean Air Act section 136, a methane charge for oil and gas facilities that remains in the statute [2]. It reaches facilities reporting over 25,000 metric tons of CO2 equivalent, a unit that weights each gas against carbon dioxide (CO2) by warming effect [2]. Congress’s disapproval of EPA’s implementing rule became law on 14 March 2025 [2]. Public Law (P.L.) 119-21, a 2025 budget law, then moved the effective date to 2034, when the unamended rate is 1,500 dollars per metric ton [2].

What the Inflation Reduction Act Set Up for Methane

The Act built a charge on top of a reporting program that already existed. The Inflation Reduction Act is P.L. 117-169, signed on 16 August 2022, and it added section 136 to the Clean Air Act [2]. Section 136 directs EPA to impose a waste emissions charge on methane from oil and gas facilities [2].

The charge reaches those reporting more than 25,000 metric tons of CO2 equivalent a year under GHGRP Subpart W [2]. The Greenhouse Gas Reporting Program (GHGRP) is EPA’s emissions reporting rule, and its Subpart W covers petroleum and natural gas systems [4].

Nine segments fall inside it [2]. They are offshore and onshore production, gas processing, transmission compression and underground storage [2]. The rest are liquefied natural gas (LNG) storage, LNG import and export equipment, gathering and boosting, and transmission pipelines [2]. Natural gas distribution sits outside the charge [2].

The charge is not levied on all reported methane [2]. Section 136 sets an emissions intensity threshold per segment, expressed as a share of the natural gas sent to sale [2]. Only emissions above that threshold would be charged [2].

Segment	Threshold, share of natural gas sent to sale
Production facilities	0.20 per cent, or 10 metric tons of methane per million barrels of oil if no gas is sent to sale
Non-production: processing, gathering and boosting, LNG storage, LNG import and export	0.05 per cent
Transmission: transmission compression, underground storage, transmission pipelines	0.11 per cent

Thresholds are set in the statute itself, not in the rule Congress disapproved.

How the Charge Was Meant to Be Calculated

The rate was scheduled to climb for two years and then hold [2]. It began at 900 dollars per metric ton for 2024, rose to 1,200 dollars for 2025, and reached 1,500 dollars for 2026 and after [2]. Those figures apply to the metric tons above a facility’s threshold rather than to its whole reported total.

EPA published the machinery for that calculation in the Federal Register (FR), the government’s daily journal of rules, in November 2024 [5]. The rule was titled Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions [5]. Netting and exemptions were the substance of it, which is a useful signal about where the difficulty sat.

Netting mattered because a company with several commonly owned facilities, in one segment or across segments, would not necessarily be charged facility by facility. That rule is the one Congress later disapproved, so the procedures it set out no longer operate [6].

The Money That Came With the Charge

The Act paired the charge with funding, and the pairing was deliberate. It appropriated 850 million dollars for EPA grants, rebates, contracts, loans and other activities on methane monitoring, reporting and mitigation [1]. A further 700 million dollars was aimed at marginal conventional wells [2].

Marginal wells are the hardest case for a per-metric-ton charge. An intensity threshold expressed as a share of gas sent to sale is harder to clear when the denominator is small.

P.L. 119-21 rescinded the unobligated balances of both funds, leaving money already obligated in place [7]. It did not repeal the section 136 funding provisions themselves [1]. The charge was rescheduled while the unspent help was withdrawn, which is not a symmetrical outcome.

What the Two 2025 Laws Actually Did

Two separate 2025 laws did two different things, and conflating them is the common error.

Congress disapproved EPA’s waste emissions charge rule under the Congressional Review Act through H.J.Res. 35, enacted as P.L. 119-2 on 14 March 2025 [2]. A disapproved rule cannot be reissued in substantially the same form [2].

EPA then removed the regulations from the Code of Federal Regulations (CFR), the official compilation of federal agency rules [6]. That revocation published on 19 May 2025 [6]. The agency states that the regulation no longer has any force of law [8].

P.L. 119-21, signed on 4 July 2025, then amended the statute itself [2]. It moved the charge’s effective date from 2024 to 2034 [2]. It left the rate schedule alone, so the first charge falls in a year the statute already priced at 1,500 dollars [2].

A Disapproval and an Amendment Are Different Things

The two actions leave different things standing: the disapproval left section 136 intact, while P.L. 119-21 amended it. The March disapproval removed the implementation framework. The July amendment moved the start date to 2034, which changed the starting rate from 900 to 1,500 dollars per metric ton [2].

Attributing both to one event is the mistake to avoid. A reader told only that Congress repealed the methane fee in early 2025 learns half of it. The charge itself was rescheduled to 2034 nearly four months later.

Under the amended law, reporting years 2024 through 2033 carry no charge; the charge is scheduled to apply from 2034.

What Survives, Provision by Provision

The statutory charge, the implementing rule and the funding each ended up in a different state [2]. Reading the provisions separately gives a clearer answer than reading the headlines.

Provision	State in 2026	What changed it
Clean Air Act section 136 charge	On the books, effective 2034	P.L. 119-21, 4 July 2025
Charge rate at first application	1,500 dollars per metric ton	Original IRA schedule, not amended
Intensity thresholds by segment	Unchanged in statute	Not amended
EPA implementing rule	Disapproved, removed from the CFR	P.L. 119-2, then 90 FR 21225
Netting and exemption procedures	EPA’s procedures gone with the rule; statutory netting and exemptions in section 136(f) unchanged	P.L. 119-2, then 90 FR 21225
850 million dollars for methane mitigation and monitoring	Unobligated balances rescinded, provision not repealed	P.L. 119-21, 4 July 2025
700 million dollars for marginal conventional wells	Unobligated balances rescinded, provision not repealed	P.L. 119-21, 4 July 2025
GHGRP Subpart W reporting	In force; the proposal would drop distribution after 2024 and suspend the rest to 2034	90 FR 44591 proposed 16 September 2025

The rows were changed by different instruments, or not changed at all, which is why a single headline cannot carry the answer.

Section 136 also carries a conditional exemption tied to Clean Air Act section 111 standards, the federal performance standards EPA sets for source categories [2]. It covers compliant facilities once EPA finds section 111 methane rules in effect in all states, equalling or exceeding its November 2021 proposal’s reductions [1]. The Congressional Research Service (CRS) notes that offshore production is not subject to the 2024 section 111 methane regulations, so it would not be eligible [2].

These section 111 standards are OOOOb and OOOOc; EPA published a final reconsideration on 9 April 2026 and proposed further changes on 29 October 2026. Their scope is covered in OOOOb and OOOOc Explained: Coverage and January 2027 Deadlines.

Get regulatory updates and emissions data insights in your inbox. Subscribe to the TetraSoft newsletter.

What Still Binds an Operator in 2026

So far, EPA has delayed the reporting that would feed the charge rather than removing it [9]. EPA proposed on 16 September 2025 to remove greenhouse gas reporting obligations for most source categories [10]. The same proposal would suspend the remaining Subpart W segments until reporting year 2034 [10].

Three things are worth continuing regardless of the charge’s status. Subpart W reporting still binds the facilities it covers, and EPA’s reconsideration of it remains a proposal rather than a final repeal. The 25,000 metric ton applicability test still keys off that reported data, so the reporting record is what a revived charge would be assessed on. An operator with years of consistent intensity data will know where it stands against the thresholds before 2034; one starting then will not.

One larger change did land in 2026, and it sits underneath all of this. EPA rescinded the greenhouse gas endangerment finding in a final rule published on 18 February 2026 [11]. That finding is the predicate for motor-vehicle greenhouse gas standards, while section 136 is a charge Congress itself required through the Inflation Reduction Act. The methane charge therefore survives the rescission, now challenged in the D.C. Circuit, and its 2034 date is unchanged by it.

The September 2025 Subpart W proposal has not been finalised. What EPA did finalise was narrower and more immediate [9].

Reporting year 2025 reports were due on 31 March 2026 [9]. EPA moved that deadline to 30 October 2026 [9]. An interim final rule published 14 October 2026 then moved it to 10 March 2027 [3]. The February rule said it changed only the deadline, and that EPA anticipates addressing the rest of the proposed rescission in later actions [9].

For a detailed breakdown of the deadline moves, see: GHGRP Subpart W Deadline Moved to March 10, 2027. What remains required is covered in Subpart W Proposed Rule: Is GHGRP Reporting Still Required?.

Six Federal Actions Reshaped the Charge and Its Reporting in 2025 and 2026

Six federal actions since March 2025 removed the charge rule, moved the charge to 2034, proposed suspending Subpart W and twice extended its deadline.

Date	Action	Effect
14 March 2025	P.L. 119-2	EPA’s 2024 charge rule disapproved
19 May 2025	90 FR 21225	Charge regulations removed from the CFR
4 July 2025	P.L. 119-21	Charge moved to 2034, funding rescinded
16 September 2025	90 FR 44591, proposed	Most Subpart W reporting would be suspended to 2034; not final
27 February 2026	91 FR 9712	Reporting year 2025 deadline moved to 30 October 2026
14 October 2026	91 FR 65112, interim final rule	Deadline moved to 10 March 2027; comments close 30 November 2026

EPA says it is currently evaluating options and obligations for implementing the charge provisions of section 136. [8]

The Reported Number Is Still the Basis

An emissions intensity is not a measurement. It is a ratio whose numerator Subpart W builds from measurement, engineering calculations and emission factors, so it is partly a modelled result. The threshold test in section 136 therefore reads calculated Subpart W emissions, which may rest on measurement data or engineering estimates.

That distinction has a measured consequence. Zavala-Araiza et al. (2017), in Nature Communications, inferred that super-emitters in natural gas infrastructure are most likely caused by abnormal process conditions [12]. EPA’s 2024 Subpart W revisions require large abnormal releases to be reported separately, as other large release events [13].

Where a Measurement-Informed Inventory Fits

A Measurement-Informed Inventory addresses the modelled quantity the threshold test reads. TetraSoft MAES, our facility-specific emissions estimation service, is built on the Mechanistic Air Emissions Simulator (MAES).

MAES is a mechanistic emissions model developed at Colorado State University (CSU) [14]. The University of Texas at Austin (UT Austin) contributed to its development through the Energy Emissions Modeling and Data Lab (EEMDL) [15]. TetraSoft provides access to MAES through a special license with CSU [16].

MAES simulates a facility from its equipment, site configuration and gas composition [14]. It generates an expected emission range rather than a single value [14].

Combining that model with field measurement is one way to build a Measurement-Informed Inventory, which Colorado bases on reported inventories plus monitoring. Santos et al. (2025), a study first-authored by TetraSoft cofounder Arthur Santos, applied that approach to the Denver-Julesburg Basin [17]. Their paper appeared in ACS ES&T Air, an American Chemical Society (ACS) journal of environmental science and technology (ES&T) [17].

MAES does not file a Subpart W report, and it does not predict whether Congress will restore the charge. It does not tell an operator what the charge will be either.

What the MAES platform addresses is the number the threshold test reads. A production facility whose methane intensity sits near 0.20 per cent is judged on Subpart W emissions built from measurement, engineering calculations and emission factors. Putting a defensible range around that number is the work.

Getting it wrong is priced in the statute. At 1,500 dollars per metric ton, 1,000 Mcf (thousand cubic feet) of methane above the threshold, roughly 19 metric tons, costs about 29,000 dollars. That arithmetic applies from 2034 emissions onward.

Frequently Asked Questions

Does a disapproved rule mean EPA can never write another one?

EPA can write another rule. What it cannot write is one in substantially the same form. Unless a later law specifically authorizes it, that bar applies, and CRS calls the disapproval’s effect uncertain.

Are reporting years before 2034 exposed to the charge?

Not under the statute as amended. P.L. 119-21 changed the effective date from 2024 to 2034 [2]. Years already reported sit before that date and are not reached by it.

Is the 25,000 metric ton test applied per facility or per company?

Per facility, as the greenhouse gas reporting rule defines one; for onshore production, that is all of one operator’s wells in a basin. Section 136 reaches facilities that report more than 25,000 metric tons of CO2 equivalent a year [2]. An operator producing in several basins can therefore hold facilities on both sides of the test, since each basin counts as one facility.

Does the section 111 exemption matter while the charge is dormant?

Not in practice. The exemption switches off a charge, and no charge applies before 2034, but section 111 actions taken now help decide whether it can apply then. Its trigger lies ahead: EPA must find section 111 methane standards and plans in effect in all states, achieving at least the 2021 proposal’s reductions [1].

Did the Inflation Reduction Act change anything else for oil and gas emissions?

Yes, including the section 45Q credit, a federal tax credit for capturing and storing carbon dioxide [18]. For geologic storage, the Act raised it to as much as 85 dollars per metric ton, or 180 dollars for direct air capture [18]. Enhanced oil recovery reached 60 dollars under that law, or 130 for direct air capture, for facilities meeting wage and apprenticeship requirements [18]. P.L. 119-21 later raised enhanced oil recovery to the same 85 dollars, for equipment placed in service after 4 July 2025 [7].

What happened to the netting rules operators were planning around?

EPA’s 2024 rule was titled Procedures for Facilitating Compliance, Including Netting and Exemptions, and the disapproval revoked it in full [5]. Its netting procedures went with it, but netting itself is in the statute [1]. Section 136(f)(4) still directs EPA to allow netting for facilities under common ownership or control [1]. Any future framework would have to set out netting procedures again, and without a new law, not in substantially the same form.

Is Subpart W reporting still required this year?

Yes, the reporting duty continues. No report falls due in 2026: an interim final rule, open for comment to 30 November 2026, moved the 2025 report to 10 March 2027 [3]. A separate September 2025 proposal, not finalised, would drop the distribution segment and suspend the rest of Subpart W until reporting year 2034 [10].

Should an operator stop tracking methane until 2034?

That is a business judgement rather than a compliance one, and the reporting record is the thing to weigh. Each reporting year adds to a record that a future framework, a state program, or a gas buyer can read. A methodology improved in 2032 does not improve the years already filed.

Interested in building a Measurement-Informed Inventory for your operations? Contact us to learn about our MAES-based estimation services.

---

References

1. 42 U.S.C. 7436, Clean Air Act section 136, Methane Emissions and Waste Reduction Incentive Program for Petroleum and Natural Gas Systems. https://www.law.cornell.edu/uscode/text/42/7436
2. Congressional Research Service, Inflation Reduction Act Methane Emissions Charge: Overview and Considerations for Policymakers, R48906, April 2026. https://www.everycrsreport.com/reports/R48906.html
3. 91 FR 65112, October 14, 2026. Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027 (interim final rule). 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
4. U.S. Environmental Protection Agency, Subpart W, Petroleum and Natural Gas Systems page, verified November 2026. https://www.epa.gov/ghgreporting/subpart-w-petroleum-and-natural-gas-systems
5. 89 FR 91094, November 18, 2024. Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions. https://www.federalregister.gov/documents/2024/11/18/2024-26643/waste-emissions-charge-for-petroleum-and-natural-gas-systems-procedures-for-facilitating-compliance
6. 90 FR 21225, May 19, 2025. Congressional Review Act Revocation of Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions.
7. Public Law 119-21, One Big Beautiful Bill Act, signed 4 July 2025. https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.htm
8. U.S. Environmental Protection Agency, Waste Emissions Charge program page, verified November 2026. https://www.epa.gov/inflation-reduction-act/waste-emissions-charge
9. 91 FR 9712, February 27, 2026. Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025. https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025
10. 90 FR 44591, September 16, 2025. Reconsideration of the Greenhouse Gas Reporting Program (proposed rule).
11. 91 FR 7686, February 18, 2026. Rescission of the Greenhouse Gas Endangerment Finding and Motor Vehicle Greenhouse Gas Emission Standards Under the Clean Air Act. https://www.federalregister.gov/documents/2026/02/18/2026-03157/rescission-of-the-greenhouse-gas-endangerment-finding-and-motor-vehicle-greenhouse-gas-emission
12. Zavala-Araiza et al., Nature Communications, 8, 14012, 2017. “Super-emitters in natural gas infrastructure are caused by abnormal process conditions.” https://doi.org/10.1038/ncomms14012
13. 89 FR 42062, May 14, 2024. Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. https://www.federalregister.gov/documents/2024/05/14/2024-08988/greenhouse-gas-reporting-rule-revisions-and-confidentiality-determinations-for-petroleum-and-natural
14. Mollel et al., 2025, ACS ES&T Air, 2, 723-735, DOI 10.1021/acsestair.4c00168. “Using Prototypical Oil and Gas Sites to Model Methane Emissions in Colorado’s Denver-Julesburg Basin Using a Mechanistic Emission Estimation Tool.” https://doi.org/10.1021/acsestair.4c00168
15. Energy Emissions Modeling and Data Lab, Mechanistic Air Emissions Simulator (MAES) one-pager. https://www.eemdl.utexas.edu/s/EEMDL_MAES_One-Pager.pdf
16. TetraSoft, MAES platform page. https://www.tetrasoftco.com/maes-platform/maes-landing.html
17. Santos et al., 2025, ACS ES&T Air, 2, 1598-1611, DOI 10.1021/acsestair.5c00089. “Using Measurement-Informed Inventory to Assess Emissions in the Denver-Julesburg Basin.” https://doi.org/10.1021/acsestair.5c00089
18. Congressional Research Service, The Section 45Q Tax Credit for Carbon Sequestration, IF11455, August 2023. https://www.everycrsreport.com/reports/IF11455.html
19. 91 FR 18056, April 9, 2026. Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (final rule). https://www.federalregister.gov/documents/2026/04/09/2026-06808/reconsideration-of-standards-of-performance-for-new-reconstructed-and-modified-sources-and-emissions
20. 91 FR 68234, October 29, 2026. 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). https://www.federalregister.gov/documents/2026/10/29/2026-22082/additional-reconsideration-standards-of-performance-for-new-reconstructed-and-modified-sources-and

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.

Interactive tool

Waste emissions charge exposure

What Clean Air Act section 136 would charge a facility, on its own reported figures. Prefilled with an illustrative production facility.

Not collectible today. EPA's implementing rule was disapproved on 14 March 2025 and revoked from the CFR at 90 FR 21225, published 19 May 2025. The charge does not reach any reporting year before 2034.

Segment

Production 0.20% threshold Non-production 0.05% threshold Transmission 0.11% threshold

Natural gas sent to sale Mcf/yr Reported methane t/yr Reported total t CO2e/yr

Charge if section 136 applied

$1,812,365 per reporting year

Above threshold

Methane intensity

1.460%

Threshold

192 t

Above threshold

1,208 t

In scope: reports above 25,000 t CO2e.

Thresholds, the 25,000 t CO2e scope test and the $1,500 rate are set in Clean Air Act section 136. Because EPA's implementing rule was disapproved, no authoritative method currently exists for turning a Subpart W filing into a charge. This tool states its own basis: gas sent to sale is converted to the methane mass it represents at 379.49 cubic feet per pound-mole, and the intensity is reported methane over that mass. Treat the output as the statutory percentages applied to your figures, not as a determination. Nothing leaves your browser.