The Independent Petroleum Association of America is urging the Environmental Protection Agency to revise elements of Subpart W in the Greenhouse Gas Reporting Program that affect low-production and marginal-well operators. In a letter sent from Washington, the group said wells producing 15 boed or less represent a substantial share of U.S. output and require a regulatory framework aligned with small-business realities.
IPAA said the existing facility definition and the emission factors used in Subpart W could subject thousands of small operators to disproportionate compliance costs. The association has opposed the facility definition since it was first proposed in 2010, arguing it conflicts with the intent of Congress to shield small businesses from certain methane-tax impacts introduced under 2024 rulemaking.
Dan Naatz, IPAA COO and EVP, said the association appreciates EPA’s decision to reconsider the 2024 regulations but stressed the need for rapid action. “The data on low-production well emissions shows that a reasonable, cost-effective framework is possible if EPA embraces these recommendations,” he said. “Leaving revision to a different administration a decade in the future creates inappropriate risk that problematic issues would not be addressed.”
The letter identifies two principal areas for review: clarification of what constitutes a facility under Subpart W and correction of inaccuracies in emission factors. IPAA said the complexity of the 2024 calculation process could force independent producers to spend heavily just to confirm they fall below reporting thresholds, potentially accelerating shut-in dates for marginal wells without delivering meaningful emissions benefit.
IPAA also provided suggested updates to the factors used to estimate methane volumes so that calculations better reflect field operations and historical production profiles. The association said it expects continued engagement with EPA as the reconsideration proceeds and encouraged members to review the full text of the letter and related research on methane reporting.
