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  • EPA Seeks Renewal of Information Collection for Oil and Gas NSPS Under Subpart OOOO

EPA Seeks Renewal of Information Collection for Oil and Gas NSPS Under Subpart OOOO

  • By: Learn Laws®
  • Published: 11/18/2025
  • Updated: 11/18/2025

The Environmental Protection Agency announced on November 18, 2025, in the Federal Register that it has submitted a request to renew an information collection activity related to emission standards for the oil and natural gas industry. This move seeks to extend approval for gathering compliance data from facilities under the New Source Performance Standards, specifically 40 CFR part 60, subpart OOOO. The request, identified as EPA ICR Number 2437.06 and OMB Control Number 2060-0673, is set for review by the Office of Management and Budget under the Paperwork Reduction Act. It allows an additional 30 days for public input following a prior 60-day comment period that ended in October 2024. This renewal is crucial for maintaining regulatory oversight of air emissions from new or modified oil and gas operations, ensuring facilities report data to demonstrate compliance with federal pollution controls. The action highlights ongoing efforts to balance environmental protection with administrative efficiency in a sector vital to energy production.

Background on NSPS Subpart OOOO

The New Source Performance Standards for the oil and natural gas sector, codified at 40 CFR part 60, subpart OOOO, were first proposed in August 2011 and finalized in August 2012, with the most recent amendments in March 2024. These standards target facilities involved in oil extraction, natural gas production, processing, transmission, and distribution that began construction, modification, or reconstruction after August 23, 2011, but on or before September 19, 2015. For later facilities, related subparts like OOOOa (post-September 18, 2015, to December 6, 2022) and OOOOb (after December 6, 2022) apply, though this ICR focuses on subpart OOOO. The rules aim to reduce emissions of volatile organic compounds, methane, and other pollutants from sources such as storage vessels, compressors, and pneumatic controllers. This regulatory framework stems from the Clean Air Act, which mandates the EPA to set performance standards for new stationary sources to minimize air pollution. Key players include the EPA's Office of Air Quality Planning and Standards, led by figures like Muntasir Ali, who serves as the contact for this ICR. The Office of Management and Budget plays a gatekeeping role, reviewing such requests to ensure they comply with the Paperwork Reduction Act of 1995, which requires federal agencies to minimize paperwork burdens on the public while justifying the need for information.

The Information Collection Request Process

Under the Paperwork Reduction Act, agencies must obtain OMB approval for any collection of information from 10 or more people, renewing it every three years. The EPA's ICR for subpart OOOO requires affected facilities to submit initial notifications of construction or modification, conduct performance tests, and provide semiannual or annual reports on compliance. Owners and operators must also maintain records of startups, shutdowns, malfunctions, and monitoring system downtimes. No specific forms are required, but the data helps the EPA verify adherence to emission limits. The current approval expires on November 30, 2025, prompting this renewal request. A 60-day public comment period was announced in the Federal Register on August 6, 2024 (89 FR 63933), and no comments are mentioned in the notice, though supporting documents are available in Docket ID EPA-HQ-OAR-2020-0670. This additional 30-day window, ending December 18, 2025, allows stakeholders to submit feedback via regulations.gov, email, or mail to the EPA Docket Center. The process underscores the act's emphasis on public participation to refine federal data collection efforts.

Changes in Burden Estimates and Costs

The renewal reflects adjustments based on updated data. The EPA estimates 417 respondents, a decrease from prior figures due to fewer existing sources and a projected growth rate of zero new sources. This leads to a reduced annual burden of 54,300 hours, defined under 5 CFR 1320.03(b) as the time required for reporting and recordkeeping. Total estimated costs are $11,000,000 per year, including $3,590,000 for capital or operation and maintenance. These figures incorporate updated labor rates from the Bureau of Labor Statistics' December 2023 report and an adjustment from 2012 dollars to 2023 dollars using the Chemical Engineering Plant Cost Index. The decrease in respondents has lowered overall labor costs, though inflation adjustments have increased capital expenses slightly. Industry groups, such as the American Petroleum Institute, have historically critiqued such burdens, arguing they impose unnecessary administrative loads on operators. Environmental advocates, like those from the Sierra Club, often support robust data collection to enforce emission reductions, viewing it as essential for public health and climate goals. The EPA maintains that these requirements are mandatory to assure compliance, without endorsing either perspective.

Legal and Political Context

This ICR renewal occurs amid broader debates on oil and gas regulations. The Clean Air Act's section 111(b) authorizes NSPS, with precedents like the 2009 endangerment finding on greenhouse gases influencing methane controls in subpart OOOO. Political forces include the Biden administration's focus on climate action, contrasting with prior rollbacks during the Trump era, though this notice is administrative rather than substantive. Court cases, such as American Lung Association v. EPA (2021), have shaped NSPS implementation by affirming the agency's authority while requiring reasoned decision-making. Potential implications include short-term administrative continuity for facilities, ensuring uninterrupted compliance monitoring. Long-term, it could inform future rulemakings, especially as the EPA addresses methane emissions under international commitments like the Global Methane Pledge. Different perspectives highlight tensions: industry seeks burden reductions to support energy independence, while regulators and environmentalists emphasize data's role in mitigating climate change and air quality risks.

In summary, this ICR renewal sustains essential compliance mechanisms for oil and gas emissions standards. Potential next steps include OMB review and possible approval by late 2025, with any public comments potentially leading to minor adjustments. Ongoing challenges involve balancing regulatory oversight with economic impacts on the sector, amid debates over transitioning to cleaner energy sources. These elements point to continued scrutiny of environmental data collection in federal policy.

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