PIOGA ALERT

EPA Proposes Major Changes to OOOOb/OOOOc Methane Rules

On October 27, 2026, in conjunction with a speech given by President Trump in Texas, EPA released a 388-page pre-publication proposed rule reconsidering its March 2024 methane regulations under Subparts OOOOb and OOOOc. Signed October 27 by Administrator Lee Zeldin, the proposal is expected to be published in the Federal Register in approximately 5–7 days.

The proposal includes significant changes that could reduce compliance burdens for Pennsylvania's oil and gas operators, most especially those with low-producing conventional wells. The entire proposal and supporting documents can be found on EPA's website HERE, under Regulatory Actions.

Overview of Proposed Changes

EPA proposes to (1) eliminate the Super Emitter Program broadly across federal air regulatory programs; (2) revise requirements covering liquids unloading, pneumatic controllers, and pumps, storage vessels, closed vent systems, control devices, and gas plant equipment leaks; (3) drastically modify the requirements for associated gas from oil wells; and, (4) significantly reduce requirements across all of these different aspects for marginal or conventional oil and/or gas wells. The proposal also includes technical corrections and clarifications.

For Unconventional Producers

For Marcellus and Utica Shale producers, EPA's proposed reconsideration of OOOOb and OOOOc offers potential regulatory relief through the elimination of the Super Emitter Program and revisions to requirements for fugitive emissions monitoring, pneumatic controllers and pumps, liquids unloading, storage vessels, and emissions control equipment. These changes could reduce compliance costs and provide greater operational flexibility for unconventional operators, although the extent of the benefits will depend on the final rule.

For Conventional Producers

Without question, however, the newly proposed rule provides the most relief for marginal or conventional operators. EPA proposes defining a marginal well site as a site containing only marginal wells, with combined production of 15 barrels of oil equivalent (boe) per day or less, averaged over the preceding 12 months. Importantly, the 15 boe/day threshold applies to the entire well site, not each individual well.

Qualifying marginal well sites would receive modified requirements, including:

• Fugitive emissions: Quarterly audible, visual, and olfactory (AVO) inspections instead of more costly instrument-based monitoring requirements like Optical Gas Imaging (OGI) cameras.
• Pneumatic controllers and pumps: Greater flexibility to use certain natural gas-driven equipment, subject to operating and emissions limitations.
• Associated gas: A proposed 20-ton-per-year methane threshold for specified control requirements.
• Storage vessels: Emissions-based thresholds for applicable control requirements.

Importantly, the proposed changes do not constitute a blanket exception from compliance for marginal wells. However, EPA is seeking comment (and will consider) whether even further reductions in requirements are warranted for wells that produce less than 6 boe/day. Interestingly, EPA is also considering whether to adopt these modified requirements not based upon production, but rather simply whether a well site is wholly conventional or not.

Comment Period and Public Hearing

Once the proposed rule is officially published in the Federal Register, a 48-day public comment period will commence. EPA will also be holding a public hearing 15 days after publication. PIOGA will provide further details on both the public comment period and the hearing as they become available.

PIOGA Working for its Members

PIOGA, along with our national partner, IPAA and state partners in Ohio, Michigan, West Virginia, and others who comprise the Producers Coalition, led the charge in having these important changes proposed.

Pennsylvania Independent Oil and Gas Association

“PIOGA heartily thanks President Trump, Administrator Zeldin, Regional Administrator van Blarcom-Lackey and their respective staffs for recognizing how burdensome the Biden-era methane regulations were on producing affordable energy for Pennsylvanians. Their efforts will help ensure that the millions of Americans that rely on locally-sourced natural gas and oil will continue to be able to heat and power their homes, farms, and small businesses, while at the same time keeping durable and sensible environmental protections in place. PIOGA looks forward to working closely with EPA and our state regulatory partners in finalizing these commonsense changes,” said Pennsylvania Independent Oil and Gas Association Executive Director, Dan Weaver.

PIOGA will host a members-only webinar before EPA's public hearing to review the proposal, discuss its implications for Pennsylvania operators, and identify opportunities for member input. Registration details will follow. PIOGA will also release a more detailed assessment once the official proposed rule is published in the Federal Register.

Members are encouraged to review the proposal and begin identifying provisions that could affect their operations.