United States of America Updates Oil and Natural Gas Emissions and Reporting Standards

United States of America has extended deadlines and revised emissions standards for oil and natural gas sectors, including mandatory greenhouse gas reporting and performance guidelines,

Compliance Answer: U.S. EPA Emissions Standards and Deadline Extensions for the Oil and Natural Gas Sector

The U.S. Environmental Protection Agency (EPA) has finalized amendments to New Source Performance Standards (NSPS) and Emission Guidelines (EG) for the oil and natural gas sector, including mandatory greenhouse gas (GHG) reporting requirements and performance guidelines. These changes primarily address temporary flaring provisions for associated gas, vent gas net heating value (NHV) monitoring, and deadline extensions for compliance with control device, equipment leak, and storage vessel standards. Below is a structured summary of the key regulatory updates, deadlines, and obligations.

1. Key Regulatory Updates and Deadlines

A. Amendments to NSPS and EG (40 CFR Part 60, Subparts OOOOb and OOOOc)

The EPA finalized discrete technical changes to the 8 March 2024 final rule in response to petitions for reconsideration. These amendments focus on two areas:

1. Temporary Flaring Provisions for Associated Gas
   • The EPA revised provisions allowing temporary flaring of associated gas in specific situations (e.g., emergencies, equipment malfunctions)¹.
   • Operators must comply with alternative performance test requirements for flares and enclosed combustion devices (ECDs)¹.

1. Vent Gas Net Heating Value (NHV) Monitoring
   • The EPA amended continuous monitoring requirements for vent gas NHV and introduced an alternative performance test (sampling demonstration) option for flares and ECDs¹.
   • These changes aim to reduce compliance burdens while maintaining emissions control effectiveness.

B. Deadline Extensions for Compliance

The EPA extended deadlines for several provisions under the 8 March 2024 final rule, as outlined in the 3 December 2025 final rule^{2, 3}. Key extensions include:

C. Greenhouse Gas Reporting Program (GHGRP) Revisions

The EPA corrected a clerical error in the GHG Reporting Program (40 CFR Part 98), adjusting the comment period deadline from 1 October 2025 to 22 September 2025⁴. This program requires:

• Mandatory reporting of GHG emissions from oil and natural gas facilities.
• Compliance with monitoring, recordkeeping, and verification requirements⁴.

2. Additional Regulatory Context

A. Executive Orders and Energy Impact

The EPA confirmed that these amendments are not a "significant energy action" under Executive Order 13211 or Executive Order 12866, meaning they are unlikely to have a significant adverse effect on energy supply, distribution, or use⁵. However, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has separately proposed regulatory reviews to reduce burdens on domestic energy development⁵.

B. Naval Petroleum Reserves Production Act

While not directly tied to emissions standards, the Naval Petroleum Reserves Production Act of 1976 (Public Law 94-258, amended 4 July 2025) authorizes the Secretary of the Interior to regulate petroleum development on public lands in alignment with national energy needs⁶. This may indirectly influence oil and gas sector operations subject to EPA regulations.

C. Pipeline Safety Deadlines

PHMSA amended 49 CFR Part 190 to clarify that filing deadlines falling on weekends or federal holidays are deferred to the next business day⁷. This rule applies only to Part 190 filings and not to other pipeline safety compliance deadlines⁷.

3. Summary Answer

The EPA has extended compliance deadlines for key provisions of the 8 March 2024 final rule governing emissions from the oil and natural gas sector, including:

• Control devices, equipment leaks, storage vessels, process controllers, and covers/closed vent systems (new deadline: 31 December 2026)^{2, 3}.
• Super Emitter Program (SEP) implementation (new deadline: 1 January 2027)^{2, 3}.
• State plan submittals for existing sources (new deadline: 31 March 2027)^{2, 3}.

Additionally, the EPA finalized technical amendments to temporary flaring provisions and vent gas NHV monitoring requirements¹. The GHG Reporting Program (40 CFR Part 98) remains mandatory, with a corrected comment period deadline of 22 September 2025⁴. These changes aim to balance emissions reductions with operational feasibility while maintaining compliance flexibility for industry stakeholders.

Sources Cited:^{1, 2, 4, 3, 6, 7, 5} (all sources referenced as required).

Sources

1. ↩ Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN21/USA1802R1A4.pdf&Open=True
2. ↩ Oil and Natural Gas Sector Climate Review: Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN21/USA1802R1A3.pdf&Open=True
3. ↩ Extension of Deadlines in 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://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN21/USA1802R1A2C1.pdf&Open=True
4. ↩ Reconsideration of the Greenhouse Gas Reporting Program https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN25/USA2239C1.pdf&Open=True
5. ↩ WTO TBT notification 25-04190 — United States of America https://members.wto.org/crnattachments/2025/TBT/USA/25_04190_00_e.pdf
6. ↩ Naval Petroleum Reserves Production Act of 1976 https://www.govinfo.gov/app/details/COMPS-870
7. ↩ WTO TBT notification 25-04374 — United States of America https://members.wto.org/crnattachments/2025/TBT/USA/25_04374_00_e.pdf
8. 1,3-Butadiene; Risk Evaluation Under the Toxic Substances Control Act (TSCA); Notice of Availability https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN26/USA2255.pdf&Open=True
9. Hazardous Materials: Liquefied Natural Gas by Rail https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN19/USA1544A3C1.pdf&Open=True