U.S. EPA Extends Compliance Deadlines for Oil and Natural Gas Sector

On July 31, 2025, the United States Environmental Protection Agency (U.S. EPA) issued an interim final rule to extend compliance deadlines established for crude oil and natural gas facilities that are subject to the provisions of 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOOb – Standards for Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After December 6, 2022 (Subpart OOOOb). With these changes, U.S. EPA is amending compliance deadlines and timeframes based on multiple petitions for reconsideration, allowing affected facilities additional time to meet the compliance deadlines under Subpart OOOOb. Likewise, U.S. EPA has determined that multiple states are still in the early stages of developing state plans under 40 CFR Part 60, Subpart OOOOc – Emissions Guidelines for Greenhouse Gas Emissions from Existing Crude Oil and Natural Gas Facilities (Subpart OOOOc). U.S. EPA has received many inquiries from state regulatory agencies regarding extensions to the state plan submission requirements under Subpart OOOOc. Therefore, U.S. EPA has extended the state plan submission deadline for Subpart OOOOc, allowing more time for states to submit their respective plans.

These extensions come on the heels of U.S. EPA’s March 12, 2025 announcement that they would reconsider specific provisions of Subparts OOOOb and OOOOc pertaining to vent gas net heating value (NHV) monitoring for flares and enclosed combustion devices and temporary flaring provisions for associated gas under certain conditions. According to the recently released Spring 2025 Unified Agenda, U.S. EPA plans to issue a proposed reconsideration of the subparts in November 2025 with a final rule in July 2026.

Key Deadline Extensions under Subpart OOOOb

U.S. EPA published 40 CFR Part 60 Subpart OOOOb, which finalized air quality regulations for greenhouse gas (GHG) and volatile organic compound (VOC) emissions from affected sources constructed, modified, or reconstructed after December 6, 2022. Affected sources regulated under Subpart OOOOb include wells, centrifugal compressors, reciprocating compressors, process controllers, storage vessels, process units, sweetening units, pumps, and fugitive emissions components at a well site, centralized production facility, or compressor station. In response to the final Subpart OOOOb, U.S. EPA received petitions from stakeholders and affected facilities regarding specific provisions within the rule that present challenges to achieving and maintaining compliance within the final time frames. Petitioners raised concerns about supply chain constraints, limited emissions testing resources, and limited laboratory analytical capacity related to the ability to demonstrate compliance with control device testing and monitoring requirements. Petitioners also cited conflicting regulatory language and technical guidance from U.S. EPA that imposed compliance deadlines perceived to be too stringent by many affected facilities and stakeholders within the sector.

In response to the concerns that were raised in the petitions, U.S. EPA issued an interim final rule on July 31, 2025, in which multiple Subpart OOOOb compliance deadlines were extended to January 22, 2027, providing affected facilities with an additional 18 months to procure equipment, coordinate performance testing schedules, and implement monitoring systems into facility operations and project plans. The deadline extensions align with U.S. EPA’s plan to issue a final reconsideration of Subparts OOOOb and OOOOc in July 2026, where certain provisions will be reviewed and likely revised. By specifying deadlines that allow sufficient lead time for affected facilities to comply with applicable Subpart OOOOb provisions, U.S. EPA aims to ensure a structured transition period providing regulatory certainty across the sector during the reconsideration process. The following table outlines several important compliance requirements promulgated within Subpart OOOOb that have been granted deadline extensions within the issuance of the interim final rule.

¹ The provisions of the Super Emitter program under 40 CFR Part 60, Subparts OOOO and OOOOa were suspended until January 22, 2027.

Extensions to State Plan Requirements under Subpart OOOOc

On March 8, 2024, emissions guidelines for existing sources in the crude oil and natural gas source category were finalized under 40 CFR Part 60, Subpart OOOOc. The final rule includes a deadline of March 9, 2026 for state regulatory agencies to submit their respective state plans for the implementation of Subpart OOOOc. Since the rule was finalized, U.S. EPA has received many inquiries from state regulatory agencies regarding extension of the deadline and the subsequent consequences of late state plan submissions. These inquiries ultimately prompted U.S. EPA to reassess the submission deadline for state plans, allowing states more time to develop their plans in accordance with the final emissions guidelines. The July 31, 2025 interim final rule extended the state deadline to January 22, 2027. This deadline extension also grants U.S. EPA sufficient time to conduct their reconsideration of Subpart OOOOc prior to a submittal deadline.

What’s Next?

The interim final rule became effective immediately (without formal notice and comment) upon publication, citing the ‘good cause’ exemption under the Administrative Procedure Act. The interim final rule provides targeted extensions to facilitate realistic and achievable compliance with GHG and VOC control requirements under Subparts OOOOb and OOOOc. On August 15, 2025, U.S. EPA extended the deadline for the public to submit comments on the interim final rule through October 3, 2025. Until then, U.S. EPA is accepting public comments on all aspects of the interim final rule under Docket ID. No. EPA-HQ-OAR-2025-0162. While the extended compliance deadlines offer relief, facilities can take advantage of the extensions to develop compliance strategies and plans, including procurement of long-lead equipment and services, to comply with the rule. The interim final rule was issued in the shadow of U.S EPA’s March 12, 2025 announcement of their planned reconsideration of specific provisions under Subparts OOOOb and OOOOc. U.S EPA is also considering certain provisions under Subparts OOOOb and OOOOc related to NHV monitoring at flares and enclosed combustion devices and flaring of associated gas. Until a reconsideration rule is proposed, affected facilities should remain engaged in the rulemaking process and maintain communication with their respective legal, technical, and environmental professionals.

Need help understanding how this affects you?

ALL4’s oil and natural gas experts are well-versed in all aspects of evaluating applicability to the federal regulations, developing plans for compliance, and implementing practical strategies aligned with U.S. EPA’s evolving regulatory landscape. If you are wondering how U.S. EPA’s final rule will affect your facility or ongoing projects directly, please reach out to your ALL4 project manager or contact Daniel Hickey at dhickey@all4inc.com.