Policy Overview

In May 2024, the Environmental Protection Agency (EPA) finalized significant updates to its Greenhouse Gas Reporting Program (GHGRP), specifically on the petroleum and gas industry source category known as Subpart W. These changes were prompted by the 2022 Inflation Reduction Act (IRA), which established a methane emissions charge, also known as the methane fee. The charge applies to certain oil and gas facilities that report more than 25,000 metric tons of CO2 equivalent per year, beginning at $900 per metric ton of methane reported in 2024 and increasing incrementally to $1,500 by 2026 and beyond (see InfluenceMap’s Methane Emissions Charge policy tracker page for an overview of how the fossil fuel industry advocated to weaken the ambition of the methane fee over the 2021-2022 time period leading up to the IRA’s passage).

To implement this methane emissions charge, the IRA requires the EPA to revise subpart W to more accurately reflect total methane and waste emissions from applicable facilities. Consequently, the EPA proposed methane reporting revisions in July 2023. The proposed revisions aimed to expand the scope and accuracy of methane emissions reporting through several changes, including the following:

  • Updated reporting requirements based on empirical data, including direct and site-specific measurements alongside top-down, basin-level data

  • New reporting sources, including a “large emission events” category to capture reporting of super-emitter events

Policy Outcome

The EPA finalized these revisions in May 2024, following a public comment period between July 2023 to October 2023. Despite heavy negative engagement on the reporting revisions from the oil and gas industry, the final revisions largely reflect the ambition of the proposal, by adding new reporting sources – including large emission events – and requiring the use of empirical data. The stringency of the methane reporting consequently influences strength of the methane emissions charge.

Policy Status

Final rule issued in May 2024. Regulations take effect from January 1, 2025 and apply to 2025 emissions. Updated calculations can be used sooner if applied to 2024 emissions. Additional comment periods expected in summer 2024 related to advanced measurement data.

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Policy Engagement Overview

The current state of corporate engagement on this regulation is summarized below. The graph to the right indicates InfluenceMap's capture of corporate positions on the regulation, ranging from strong opposition to strong support. Both this page and the graph were last updated on July 5, 2024.

At least 17 industry groups and companies engaged on the methane reporting revisions, with evidence indicating a strong negative response from fossil fuel interest groups. This opposition to methane abatement measures is misaligned with the recent April 2022 Intergovernmental Panel on Climate Change (IPCC) report which clearly indicates the need for significant methane emission reductions to limit global warming to 1.5°C and meet the Paris Agreement objectives. The International Energy Agency also estimates  that the oil and gas industry could achieve a 75% reduction in methane emissions by 2030 using existing technologies.

Oppositional/Unsupportive Positions

  • Several major oil and gas industry groups opposed the revisions, including the American Exploration and Production Council (AXPC), Independent Petroleum Association of America (IPAA) and National Federation of Independent Business. The American Petroleum Institute (API) submitted comments in August 2023 and September 2023 that emphasized the bureaucratic burden of the proposed revisions, including the burden of operation and maintenance costs associated with pneumatic devices. A joint comment submitted by the American Fuel & Petrochemical Manufacturers, API, AXPC, and IPAA specifically advocated for the EPA to weaken the thresholds for reporting large emission events, a position that American Gas Association also took in its own comments. Several of these groups emphasized that methane regulations, including the costs of implementation, would negatively impact the security of the American economy.

  • ConocoPhillips and Devon Energy endorsed the oppositional comments of API and AXPC in their own comments. ConocoPhillips emphasized concerns with several elements of the proposal, including the parameters for measuring large emission release events. While Devon seconded the negative positions of API and AXPC, its own statements supported the use of empirical data and advanced methane detection technologies.

  • Some utilities joined energy companies in advocating to weaken the revisions. The Differentiated Gas Coordinating Council (DGCC) – whose members include Williams Companies alongside utilities Sempra, Southern Company, and Xcel Energy – questioned the proposed use of site-level measurements, although the group did support the use of continuous monitoring technologies. Williams also submitted individual comments suggesting the EPA was acting beyond its legal boundary in proposing a reporting category for large emission events, among other criticisms of the revisions. Both Duke Energy, a utility, and Occidental Petroleum submitted comments advocating for weaker thresholds for reporting large emission release events.

Supportive Positions

  • A few entities expressed support for the revisions. Utility industry group Edison Electric Institute stated in its comments that it supported the EPA’s efforts to develop reporting rules based on empirical data. Meanwhile, BP and Honeywell called for continuous monitoring. In its comments, BP stated support for continuous monitoring technologies, however, while emphasizing some concerns with third-party reporting around large release events. Honeywell also called for continuous monitoring systems and broadly supported data collection for large emission release events.

Unclear Positions

  • The Truck and Engine Manufacturers Association (EMA) did not appear to take a clear position on the reporting revisions, although it did advocate for clarity to ensure the revisions apply only to the petroleum and fossil gas facilities and not to the transport sector.

Policy Status

Final rule issued in May 2024. Regulations take effect from January 1, 2025 and apply to 2025 emissions. Updated calculations can be used sooner if applied to 2024 emissions. Additional comment periods expected in summer 2024 related to advanced measurement data.

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Entities Engaged on Policy

The following table lists companies and industry associations that have engaged on the methane reporting revisions, with evidence indicating a strong negative response from fossil fuel interest groups. Click on an entity name to view the full profile on its climate policy engagement.

Influencemap Performance BandOrganizationPolicy PositionPolicy Engagement Intensity