The stakes have never been higher for oil and gas operators navigating the EPA’s new methane regulations. With non-compliance penalties, methane emission charges, and increased regulatory complexity, operators face a critical question: How do you reduce risk while building a framework for long-term compliance?

Understanding the Compliance Landscape

Operators face a maze of federal and state rules, evolving enforcement priorities, and new compliance obligations. Operators must also navigate interconnected and often conflicting federal and state regulations, as many states are crafting their own methane rules.

The first step is to determine what regulations you are subject to. Key federal standards include the New Source Performance Standards (NSPS), which dictate control and monitoring requirements for new, reconstructed, and modified facilities, and Subpart W, which ties directly to the Waste Emissions Charge (WEC), requiring operators to accurately calculate and report methane emissions. These are in addition to a variety of existing rules regulating oil and gas sources, such as engines, turbines, and dehydration units. Beyond EPA rules, the Bureau of Land Management (BLM) has additional requirements for operations on federal lands, adding another layer of compliance for some sites.

Compounding the challenge, each regulation comes with unique obligations depending on factors like equipment type, site classification, and operational changes:

• Control devices, such as flares and combustors, now require detailed monitoring and reporting based on their specific type. Operators must account for differences in monitoring frequency, flow rates, and net heating values for each device. This makes compliance a logistical challenge for operators managing dozens—or even hundreds—of sites.
• The EPA has several classifications for oil and gas sites, each with unique monitoring and repair requirements. Operators must not only understand their current classification but also recognize how site modifications, such as adding major equipment, can shift them into a new category with stricter obligations. Operators without robust Management of Change (MOC) systems in place run the risk of overlooking these changes, increasing compliance risks.
• The EPA’s Super-Emitter Program will use satellite technology to identify high-emission sites, requiring operators to respond quickly to minimize penalties and public scrutiny.

With rules that are often ambiguous or open to multiple interpretations—not to mention inconsistencies in EPA guidance, varying enforcement priorities across states, and evolving regulatory expectations over time—many operators find themselves in a gray area of uncertainty. For example, operators may struggle to determine their site’s classification or whether certain equipment qualifies as “major production equipment,” with interpretations differing among colleagues, agencies, or even within the same organization.

These challenges highlight the need for operators to move beyond reactive fixes. A proactive approach to managing risk can help operators manage immediate obligations while positioning themselves for success over the long term.

Key Actions to Manage Methane-Related Risk

Operators need to build a compliance framework that anticipates and accounts for uncertainty. A structured approach to identifying and addressing areas of potential non-compliance can help reduce risk:

• Develop a detailed asset inventory—the foundation of risk management: Document all equipment, production rates, installation dates, and controls to identify potential vulnerabilities and anticipate regulatory obligations.
• Perform gap analyses to identify risk hotspots: Use targeted analyses to uncover areas of exposure related to equipment gaps (i.e., missing or incomplete data that could lead to overlooked risks) and regulatory gaps (i.e., high-stakes areas where current operations may fail to meet regulatory expectations).
• Establish Management of Change (MOC) processes: Operational changes, like increasing production or upgrading equipment, can create hidden risks. A robust MOC system ensures that changes are tracked, evaluated, and aligned with evolving requirements, avoiding surprise obligations and mitigating risks.
• Rank and prioritize risks: Not all risks are created equal. Evaluate and prioritize risks based on potential penalties, public health impacts, and regulatory scrutiny, so you can direct resources to the areas that will have the greatest impact on risk.
• Engage with state regulators: Proactively involve state agencies to clarify interpretations, align expectations, and influence state-specific methane regulations. This can reduce uncertainty and the risk of enforcement actions.
• Prepare for high-profile risk areas, like the Super-Emitter Program: Satellite monitoring is raising the stakes for high-emission sites. A rapid-response plan to address flagged emissions quickly can help reduce potential penalties and reputational damage.
• Document risk management strategies consistently: Maintain detailed records of decisions, interpretations, and corrective actions. Consistency in documentation can protect your organization if enforcement priorities shift or if regulatory interpretations evolve.

Making a Case for Early Action

As with many regulatory requirements, the key to minimizing methane emission charges lies in acting early. Operators who proactively replace outdated equipment, implement leak detection programs, and invest in low-emission technologies are likely to see greater returns in the long run. Taking these actions early not only reduces the risk of hefty fines but also positions operators to benefit from future regulatory shifts.

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.