New EPA methane regulations have turned long-term sustainability plans into a race against time. Oil and gas operators who had mapped out a 10-year plan for voluntary emissions reductions and capital investments are now mandated to achieve reductions in a fraction of that time.

With regulatory-driven timelines looming, operators may be tempted to prioritize immediate compliance requirements without carefully considering longer-term objectives. With the myriad of overlapping and potentially conflicting elements of New Source Performance Standards (NSPS) under Subpart OOOOb, amendments to EPA’s GHG Reporting Program under Subpart W, the IRA’s methane Waste Emissions Charge (WEC), and various state initiatives under Subpart OOOOc, operators must plan strategically to ensure that compliance risks are minimized and opportunities are not overlooked.

Streamline Compliance Without Disrupting Operations

Compliance with the suite of new methane rules isn’t only about making big changes quickly—it’s about making the right changes, efficiently and thoughtfully. That starts with understanding where you stand today. Do you have an accurate and complete accounting of emission sources? Are your emissions controls and work practices adequate to meet upcoming requirements? Do you have monitoring systems and digital solutions to track activity data and compile inputs needed for emissions calculations and reporting obligations?

Identify any gaps you may have and focus on implementing the most impactful changes now, being mindful of how those may impact longer-term goals as well. Assess how you are managing compliance today and what that will look like into the future. Whether it’s pipelines or compressors, auditing your assets, data management systems, and business processes helps you spot vulnerabilities before they turn into bigger problems.

For example, a structured Management of Change (MOC) system can help proactively manage compliance and mitigate risk by ensuring that regulatory obligations and industry best practices are systematically evaluated as part of the project planning process. Even small changes, like upgrading a controller or expanding tank capacity, can introduce new compliance requirements.

Digital solutions can enable you to more effectively manage your assets and the vast volume of data they generate. Automation can improve data completeness and accuracy, as well as streamline reporting, reduce the risk of manual errors, and minimize administrative workloads. In addition to data management, implementing digital solutions can facilitate workflows and formalize critical procedures to help document compliance for internal auditing and agency inspections as well as minimize disruptions during personnel transitions.

Move From Reactionary Compliance to Strategic Decision-Making

With methane regulatory deadlines looming, it’s easy to focus on the immediate future and the most urgent compliance needs. But you should also be considering: how will your short-term actions set the stage for long-term success?

A rigorous cost-benefit analysis can help you determine the most effective path forward. Compliance with NSPS rules is non-negotiable, but additional steps to minimize methane fees under the Waste Emissions Charge (WEC) requires more strategic consideration. For example, retrofitting pneumatic devices might cost $1 million but only reduce WEC fees by $500,000. With the complexities of these various methane initiatives, operators must carefully weigh compliance imperatives alongside their financial goals, risk tolerance, and long-term sustainability goals or targets.

Each operator has unique drivers, financial models, and operating structures. Some prioritize minimal risk exposure, while others focus on cost containment or Environmental, Social, and Governance (ESG) outcomes. The key is to align compliance actions with the outcomes that matter most to the business.

Navigating the myriad of methane programs isn’t just about ticking boxes—it’s about making financially smart decisions, like evaluating compliance options to prioritize investments that meet regulatory requirements while also reducing methane fees and supporting sustainability goals.

For many operators, the challenge lies in balancing investor expectations and supply chain demands with compliance obligations. By integrating these factors into broader business strategy, companies can demonstrate value while prioritizing compliance and minimizing financial exposure.

Build a Future-Ready Compliance Strategy

While short-term compliance is essential, operators should also consider long-term adaptability. Ensure that your strategy encompasses the following areas:

• Applicability determinations: Taking a close look at your assets early on helps you pinpoint risks, avoid costly mistakes, and streamline compliance from the start. This includes details like installation dates, production rates, design parameters, and the controls on each piece of equipment. Successful oil and gas operators build this knowledge into their processes, often using tools like centralized databases, project checklists, or standard design specifications that account for regulatory requirements right from the start.
• Compliance obligations: Understand how much compliance will cost on a project or long-term basis and how it may differ from basin to basin. Ensure that you know how others in your sector have interpreted compliance, because eventual enforcement may differ from a strict read of the rule text. You should also stay informed about local, regional, and global market trends, including state policies and initiatives, investor-driven sustainability focus areas, and non-U.S. mandates that may be more stringent than their U.S. counterparts.
• Staff training: Staff training is the foundation of a strong compliance culture. For example, process engineers need guidance on designing systems to meet regulatory standards, while field staff benefit from clear, actionable advice for day-to-day compliance tasks. Tailoring training to each role helps everyone see how their work fits into the bigger picture.
• Resource allocation: What can you realistically manage in-house, and where does it make sense to bring in outside expertise? For example, you may decide to handle routine data collection internally while outsourcing complex regulatory interpretations or specialized technical work like emissions modeling. Don’t forget to consider any resource allocation risks: Spreading internal teams too thin can lead to omissions or errors, while outsourcing requires a partner you can trust to deliver quality work. Balancing these factors ensures that you’re using your staffing and capital effectively while minimizing compliance risks and staying focused on your broader business goals.

Your Path Forward

To successfully navigate the evolving programs driving methane reductions, operators must shift from reactive to proactive strategies. Here are some steps to help you get started:

1. Identify potential risks and opportunities: Begin with a robust asset inventory and a detailed regulatory applicability review. Identify gaps in data and steps needed to achieve compliance and/or meet other objectives.
2. Develop a plan: Create a detailed action plan to fill data gaps, implement monitoring and testing programs, and develop recordkeeping and reporting procedures.
3. Leverage technology: Utilize digital tools to enable business processes such as data collection and analysis, task management/workflows, emissions calculations, and reporting functions.
4. Foster a proactive culture: Provide training for employees to build their knowledge base, encourage ownership of compliance, and promote continuous learning and improvement.
5. Regularly review and adjust: Continuously audit and review your performance and make adjustments as needed. Stay informed about evolving regulations, enforcement priorities, and industry trends to remain ahead of potential challenges.

Learn more about how Trinity is helping operators of all sizes comply with stringent new rules, minimize emission fees, and maximize return on investment in our new report, “Navigating the Methane Landscape.” If you have immediate needs or want to discuss how the new rules could affect your operation, please “contact us” today to schedule a consultation.