On July 31, 2025, the U.S. Environmental Protection Agency (EPA) published an interim final rule amending the 2024 New Source Performance Standards (NSPS) under 40 CFR Part 60, subpart OOOOb, and Emissions Guidelines (EG) under Subpart OOOOc, effective immediately. NSPS OOOOb applies to crude oil and natural gas facilities which commenced construction, modification or reconstruction after December 6, 2022. EG OOOOc applies to existing crude oil and natural gas facilities which commenced construction, modification or reconstruction on or before December 6, 2022.
This regulatory action comes less than seventeen months after the final rule was published during the previous administration. The interim rule primarily extends several compliance deadlines for new, modified, and reconstructed sources under NSPS OOOOb, delays the implementation of the Super-Emitter Program, and provides additional time for states and Tribes to submit plans under EG OOOOc for existing sources.
These new timelines are intended to make implementation of the rules more reasonable for owners and operators of new and modified oil and natural gas sources. Additionally, according to EPA’s Economic Impact Analysis, the interim final rule is expected to reduce compliance costs by approximately $750 million between 2028 and 2039, the equivalent of $81 million per year.
The key changes under the interim final rule are summarized below.
Super-Emitter Events
The date for future implementation of the super-emitter program was extended until January 22, 2027.
Storage Vessels
The throughput-based modification triggers defined as an increase in fluids to an existing tank battery at well sites or centralized production facilities and an increase in fluids to an existing tank battery which cumulatively exceed the throughput used in the most recent determination of the potential for VOC or methane emissions for all other sites, only applies after January 22, 2027. In the interim, storage vessels can only trigger modification through physical changes to the tank battery (e.g. adding tanks or replacing existing tanks with larger tanks). Additionally, only after January 22, 2027, the potential for volatile organic compound (VOC) and methane emissions must be calculated within 30 days after startup of production using the specific “legally and practicably enforceable” criteria as defined in the rule. In the interim timeframe, operators also do not need to use the 30-day period of production calculation to estimate potential emissions from storage vessels.
Equipment Leaks
The requirements to repair a leaking valve at an onshore natural gas processing plant with a low-emission (low-e) valve or low-e packing do not apply until January 22, 2027.
Process Controllers
The on-ramp for zero emissions process controllers was extended until January 22, 2027. In the interim, sites can continue to comply with OOOOb through the requirements for process controllers located in Alaska at locations where access to electrical power from the power grid is not available.
Control Devices
The initial net heating value (NHV) testing requirement is delayed until November 28, 2025, or 180 days after startup, whichever is later, allowing operators additional time to complete initial sampling. Additionally, the continuous burning pilot or combustion flame and associated alert system are not required until January 22, 2027. Lastly, any owners or operators complying with the performance testing requirements for enclosed combustion devices are not required to complete an initial compliance demonstration until January 22, 2027.
Well Completions
Completion combustion devices, similar to other control devices, are not required to be equipped with a reliable continuous pilot flame until January 22, 2027.
Closed Vent System (CVS)
The “no identifiable emissions” demonstrations for closed vent systems and covers are not required until January 22, 2027. Therefore, the operator does not have a requirement to complete “no identifiable emissions” surveys/inspections until 30 calendar days after January 22, 2027, or upon startup of the affected facility routing emissions through the closed vent system, whichever is later. Other fugitive emissions surveys were not impacted by the interim rule.
Reporting Deadlines Unchanged
Despite these various timeline extensions and technical modifications, the fundamental compliance strategies are unchanged. Furthermore, owners and operators should note that the reporting deadline of August 5, 2025 was not affected by the interim final rule. Owners and operators subject to these regulations should have submitted reports through CEDRI in accordance with that deadline.
Other Considerations
In addition to the revisions under NSPS OOOOb, the interim rule delays the date in EG OOOOc for which the state or Tribal plan or negative declaration letter must be submitted to EPA. This date has been extended from March 9, 2026 to January 22, 2027. At this point, the interim rule does not make any other changes to the requirements of EG OOOOc.
While the interim rule is effective immediately, EPA is accepting public comments until September 2, 2025. Stakeholders, including industry groups, environmental advocates, and state agencies, are encouraged to provide feedback that may influence future amendments.
The future rule may look very different from the interim rule as NSPS OOOOb/c and the 2009 greenhouse gas endangerment finding are both being reconsidered by the EPA. The endangerment finding asserts that methane, among other greenhouse gases, poses a danger to public health and welfare. Under both the previous and interim versions of NSPS OOOOb/c, methane regulations are predicated on that endangerment determination. Should the endangerment finding be revised or overturned, the legal basis for regulating methane emissions in NSPS OOOOb/c could be heavily scrutinized. Furthermore, while the rule provides relief to industry, advocacy groups may view the delay as weakening climate policy, potentially increasing scrutiny or lawsuits.
Trinity is here to help
While the interim final rule provides an extension in compliance for some oil and gas operators, the fundamental requirements of NSPS OOOOb and EG OOOOc remain in effect while the regulatory framework continues to evolve. With compliance deadlines extended but not eliminated, it’s critical for owners and operators to maintain focus on implementation, documentation, and accurate reporting. Trinity’s team closely monitors EPA rulemaking and state-level developments and is prepared to help you adapt your compliance strategy as the landscape shifts. Whether you need help evaluating your facility’s applicability, preparing reporting submissions, or understanding state implementation plans, we’re here to support you.
Reach out to our experts to stay ahead of compliance obligations and avoid costly surprises in this dynamic regulatory environment. Contact Jared Murdock, Katie Jeziorski, or one of our O&G experts across Trinity.
