Policy Briefing — March 31, 2025

Executive briefing: EPA’s final Methane Emissions Reduction Program rule (40 CFR Part 99) implements Inflation Reduction Act Section 136 by requiring covered petroleum and natural gas facilities to pay a waste emissions charge beginning with calendar year 2024 emissions. Operators must submit Subpart W greenhouse gas data and the new Part 99 supplemental report by 31 March 2025, then remit the $900-per-metric-ton charge through the U.S. Treasury’s pay.gov portal on the same date. Facilities that do not reconcile measurement systems, intensity thresholds, and allowable adjustments before the March window face interest accrual, late-payment penalties, and enforcement referrals.

Key policy checkpoints

Applicability testing. Confirm segment-level emissions intensities (e.g., 0.20 metric tons methane per thousand barrels of oil equivalent for production) exceed the statutory thresholds detailed in Part 99 Subpart B before triggering the charge.
Supplemental reporting. Prepare the Part 99 submission that accompanies Subpart W to document approved reductions, flare efficiency adjustments, and destruction verification evidence.
Payment operations. Coordinate treasury and controllership workflows for the March 31 ACH payment deadline, including SOX-ready approvals, cash forecasts, and reserve disclosures.

Operational priorities

Measurement assurance. Recalibrate flow meters, flare monitoring, and leak detection systems; retain QA/QC logs to substantiate 2024 measurement accuracy during EPA reviews.
Data reconciliation. Align greenhouse gas reporting platforms, production accounting, and mitigation project trackers so Subpart W data, supplemental files, and charge calculations reconcile before submission.
Mitigation evidence. Document methane abatement projects—such as pneumatic controller replacements or capture upgrades—and ensure claimed reductions are backed by engineering studies and completion certificates.

Enablement moves

Run tabletop exercises across environmental compliance, finance, and legal teams to rehearse the March 31 reporting and payment workflow.
Update board and sustainability reporting to highlight projected charge exposure, mitigation progress, and risk mitigation strategies ahead of investor disclosures.
Engage third-party verifiers early to validate measurement methodologies and supporting documentation before EPA sampling begins.

Sources

Zeph Tech equips operators with emissions data governance, supplemental reporting automation, and treasury controls to clear the inaugural March 2025 waste emissions charge without compliance slippage.