Jan 6, 2026 IPAA Advocates for Small Operators in EPA Subpart W Letter
WASHINGTON – Today the Independent Petroleum Association of America (IPAA) sent a letter to the Environmental Protection Agency (EPA) urging the agency to address issues within Subpart W in the Greenhouse Gas Reporting Program (GHGRP) that negatively affect small business, low production well operators. Low production wells are defined as producing 15 barrels/day of oil equivalent or less; they cumulatively contribute significantly to the United States’ total production.
IPAA COO and EVP Dan Naatz, “IPAA appreciates the EPA decision to grant reconsideration of the 2024 Subpart W regulations. The data available on low production well emissions clearly shows that a reasonable, cost-effective regulatory framework is possible if EPA is willing to embrace the recommendations here. IPAA strongly requests that the Subpart W reconsideration process continue as quickly as possible.”
IPAA’s letter highlights the urgency for this administration to complete the revisions: “As an Administration committed to regulatory reform, leaving revision of Subpart W to a different administration ten years in the future creates an inappropriate risk that its problematic issues would not be addressed.”
The letter details two important areas that need to be addressed in Subpart W. The first relates to the definition of facility in Subpart W. The second involves specific inaccuracies of emission factors.
IPAA has opposed the current Subpart W facility definition since it was proposed in 2010. This opposition results from the adverse effects the definition creates for small business, low production well operators and its inconsistencies with the Clean Air Act. As currently written, Subpart W can subject low production, marginal wells to the methane tax despite the intent of Congress to exclude small businesses from the impact of the tax. The complexity of the 2024 Biden Administration Subpart W calculation process will also likely force thousands of independent producers to incur significant costs to just to confirm they fall below reporting thresholds.
The letter also provides suggested revisions to the emissions factor calculations that would make estimates more accurate and reflective of operations.
