Methane compliance for U.S. oil and gas: build the evidence behind the filing

What the federal sources currently establish

Status checked September 15, 2026. EPA's published materials distinguish several actions often collapsed into one “methane rule.” Confirm the effective text and any applicable court order before changing a site's obligations.

NSPS OOOOb applies directly to covered new, modified, or reconstructed affected facilities. OOOOc is an emissions-guideline framework for plans addressing existing sources; the guideline itself does not directly impose the corresponding standards on each existing facility. Identify the applicable state, tribal, or federal implementation pathway, alongside any independently applicable older NSPS requirements.U.S. Environmental Protection Agency / Federal Register ↗

EPA also issued associated-gas flaring guidance in May 2026 addressing limited circumstances under the existing regulations. Guidance, a proposal, a final amendment, and a compliance-date extension have different effects. Record which one you are relying on. Pending reconsideration should stay marked pending until the operative action is verified.U.S. Environmental Protection Agency ↗

Make the equipment register the starting point

Do not assign one methane status to an entire lease. A site can contain equipment with different construction and modification histories. The federal reconsideration identifies December 6, 2022 as the dividing date used in OOOOb's new-source applicability, subject to the actual affected-facility definitions. Preserve the event and evidence behind the classification; the date the company purchased the asset is not a replacement for that analysis.U.S. Environmental Protection Agency / Federal Register ↗

Use this equipment register as an internal working record. It is not an additional regulatory filing.

Reconcile field drawings, production systems, maintenance records, and the last survey. Investigate equipment missing from individual systems. For acquisitions, preserve inherited evidence and the reasons for reclassification; a successful import does not establish completeness.

Keep the state requirements in view

New Mexico has two relevant programs that should not be merged. NMED's 20.2.50 NMAC addresses ozone-precursor pollutants, principally VOC and NOx, and includes equipment-leak monitoring, repair, recordkeeping, and reporting requirements within its geographic and equipment scope. Determine whether the site falls within the rule's jurisdiction and applicable area before assigning its tasks.New Mexico Commission of Public Records ↗

OCD's natural-gas waste provisions in 19.15.27 and 19.15.28 NMAC address upstream operations and gathering systems respectively. The agency maintains separate venting-and-flaring reporting guidance and forms. A single field event may need to be evaluated under both the air program and the waste program; completing one agency's report does not establish that the other has been addressed.New Mexico Energy, Minerals and Natural Resources Department ↗New Mexico Commission of Public Records ↗New Mexico Commission of Public Records ↗

Colorado's greenhouse-gas intensity program is another separate obligation. CDPHE describes calculations, operational records, and verification under Regulation 7, Part B, Section VIII, with operator-specific and state-default verification approaches. Its current guidance distinguishes reporting years and operator categories. Do not apply a historical factor or a larger operator's schedule to every asset.Colorado Department of Public Health and Environment ↗

Keep state rules, federal standards, and site-specific air-permit conditions as separate entries linked to shared evidence. Where their requirements differ, document how the operating procedure satisfies each applicable provision. Do not assume that a federal deadline extension changes the date written into a state requirement.

Connect detection, repair, and verification

For each emissions event, create one record that follows the work from the first observation through closure. New Mexico's equipment-leak provisions illustrate why a survey file alone is insufficient: the rule addresses monitoring, repairs, subsequent monitoring, and associated records. The exact deadlines and permitted exceptions must come from the requirements applicable to that equipment.New Mexico Commission of Public Records ↗

For example, a work order may say “tank hatch seal replaced” while the survey identifies component TH-017. Link the two explicitly. If the follow-up still identifies a leak, reopen the event rather than retaining a completed maintenance status as the compliance conclusion. Preserve the earlier observations so the chronology remains understandable.

Treat delayed repair as its own controlled state. Capture the applicable basis, approvals or notifications where required, the interim measures, and the next action. A blank due-date field or a note saying “waiting for parts” should not silently remove an event from the review queue.

Buy a compliant method, not just a sensor

EPA publishes approved alternative methane test methods with approval documents, application types, and detection performance information. Approval is tied to the method and its conditions. A vendor's inclusion on that list does not mean every deployment of every product satisfies every federal or state monitoring obligation.U.S. Environmental Protection Agency ↗

Before substituting aerial surveys, continuous monitoring, or another technology for an existing procedure, map the approval to the required task. Confirm the equipment and site coverage, operating envelope, follow-up requirements, and records. Check separately whether the state program accepts that substitution. Detection, quantification, and verification are different jobs; specify which output you need.

Retain the conditions that make a result interpretable: coverage, downtime, excluded equipment, instrument checks, weather where relevant, raw files, and the method version. A survey with no detected leaks is not interchangeable with a survey that could not observe part of the facility. Keep those outcomes distinct in both reporting and work planning.

Keep calculations tied to the operating record

Store measurements and calculations together with their basis: gas composition, meter units, pressure and temperature reference conditions where relevant, operating hours, source category, calculation method, and reporting period. Preserve original files before normalization. If an input changes, retain the previous value and recalculate affected outputs through review.

Set explicit rules for missing data. A disconnected sensor, an incomplete survey, and an idle unit describe different situations. None should become zero emissions by default. Where a prescribed reporting method requires an estimate or substitute data, retain the method and the reason it was used.

Reconcile boundaries before comparing numbers. A site-level observation, a component-level estimate, and a company inventory may cover different periods and sources. The gap needs investigation, not automatic averaging. Colorado's intensity program is a concrete example of a framework with defined verification and reporting methods; use the applicable program's procedure rather than inventing a reconciliation rule.Colorado Department of Public Health and Environment ↗

Change the workflow only after changing the legal basis

When a rule changes, write a short implementation note: affected provision, final or proposed status, effective date, assets in scope, tasks changed, records retained, and reviewer. Preserve the old configuration for historical reporting periods. A change to next year's method should not silently rewrite last year's submitted inventory.

Route agency notices and potential third-party detections to a named owner. Assess the currently applicable response duties and preserve the original notice. Keep a backup owner for absences. For each filing, save the reviewed output, supporting records, submission acknowledgment, and any corrected version. A portal upload without its supporting evidence is difficult to defend later.

Review exceptions before they reach the report

Review incomplete surveys, unresolved events, unverified repairs, questionable data, and open applicability decisions weekly. Show each item's age, owner, next step, and evidence. Escalate against the applicable requirement.

At month end, compare the equipment register, operating history, event log, and reporting inputs. Resolve differences while the field team remembers the work, before they reach the filing.