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EPA Super-Emitter Program for Oil and Gas | Validere

Written by Darren Belgrave | Oct 31, 2026, 9:32:28 PM

As of October 31, 2026, owners and operators are not currently required to investigate under EPA's Super-Emitter Program. Under 40 CFR 60.5371b, the response provisions are suspended from July 31, 2025, through January 22, 2027. EPA also proposed rescinding the program on October 29, 2026, with comments due December 16, 2026. That proposal is not a final rule, and the codified provisions are scheduled to apply after January 22, 2027.

Under §60.5371b, a super-emitter event is a methane release at or near an oil and natural gas facility, detected remotely at a rate of at least 100 kg/hr. The rule lists well sites, centralized production facilities, natural gas processing plants, and compressor stations as examples.

Under the codified process, the operator's response begins when EPA sends a notification based on a certified third party's remote detection. A release may already have ended by the time that notice arrives, so the operator has to reconstruct what happened and decide how the event affects reporting. A leak found during the operator's own survey does not, by itself, start that process.

How EPA Super-Emitter notifications work

Certified third parties detect potential super-emitter events using EPA-approved remote methods, including satellite, aircraft-based, and mobile monitoring technologies. The third party submits a notification to EPA with the detection date, the location, the quantified emission rate and its uncertainty, and the owner or operator of any oil and natural gas facility within 50 meters of that location, if one has been identified.

EPA reviews each submission for completeness and potential inaccuracies. If EPA accepts the notification, it assigns an identification number, sends the notice to the identified operator, and publishes it without the operator's attribution. Notifications and operator responses received before the July 2025 suspension are public in the Methane Super Emitter Data Explorer.

NSPS OOOO, NSPS OOOOa, and a state or federal plan for existing sources have related provisions that use the same EPA notice.

What the operator investigation involves

When the provisions apply, the owner or operator initiates an investigation within 5 calendar days of receiving EPA's notification and completes it within 15 days of receiving that notification. The first question is whether the company owns or operates an oil and natural gas facility within 50 meters of the latitude and longitude in the notice. If the company does not own or operate a facility within that distance, it reports that result, and the investigation is complete.

If the company does own or operate a facility within 50 meters, it investigates to determine the source. A field visit may find no ongoing release, so the team has to reconstruct what was happening when the event was detected. Maintenance records, liquids-unloading activity, and earlier monitoring results can help with that reconstruction. Control-device records may reveal a flare malfunction or another period of noncompliant operation, while recent fugitive surveys and continuous monitoring can narrow the source. The investigation may also include a screen of the facility using OGI, Method 21, or an approved alternative method. If the source still cannot be identified, the operator must certify that the applicable investigations were completed and that the affected facilities and associated equipment covered by the subpart were not responsible for the event.

If the investigation identifies fugitive emissions from components at a covered well site, centralized production facility, or compressor station, the repair requirements in §60.5397b apply. Survey frequencies and repair clocks are in NSPS OOOOb fugitive emissions monitoring.

What gets reported back to EPA

Under the codified rule, the operator submits its investigation report through the Super-Emitter Program Portal within 15 days of receiving EPA's notification. If the company does not own or operate an oil and natural gas facility within 50 meters, the report states that determination. No further facility or source information is required.

If the company does have a facility within that distance, the report includes the applicable facility information and states whether the source was identified. An identified source requires additional details about the release and whether it is ongoing. If the event has ended, the operator reports when it ended. If it is still ongoing, the operator provides a short plan and a target date for ending it. If the source cannot be identified, the operator provides the certification instead of those source and ongoing-event details.

If the event is still emitting at 100 kg/hr of methane or more when the initial report is submitted, the operator updates the report within 5 business days after the event ends. EPA publishes the operator's response and the attribution confirmed in that report.

How Super-Emitter events relate to Subpart W reporting

An investigation may establish where a methane release occurred and whether it has ended. That does not settle how much methane belongs in the annual greenhouse-gas report.

Section 98.233(y) applies the 100 kg/hr methane figure differently depending on whether the source is subject to one of the specified reporting methods. The first category includes events such as fires, explosions, well blowouts, and pressure-relief releases when they are not subject to those methods.

Source situation

Methane threshold

Reporting treatment

Not subject to the specified source-specific reporting methods

At least 100 kg/hr at any point during the event

Report emissions for the full event

Subject to the specified source-specific reporting methods

Methane release rate at least 100 kg/hr higher than the rate calculated under the applicable source-specific method

Report the event emissions as an other large release, and exclude the source-specific calculation for the same period


For a qualifying other large release, Subpart W requires the operator to calculate methane and carbon dioxide emissions over the event's full duration, including periods when the methane release rate falls below the threshold.

Subpart W's other-large-release provision does not require operators to measure every release. When EPA-funded or facility-funded monitoring indicates that a release meets an applicable threshold, or may reasonably be expected to meet one, the company calculates the event emissions and reports an other large release if the threshold is confirmed.

Under §98.233(y)(6), a facility that reports under Subpart W and receives an EPA Super-Emitter notification generally must include the emissions associated with that notification, unless a specified certification applies or EPA determines that the notification contains a demonstrable error.

The Super-Emitter investigation asks whether the operator owns or operates an oil and natural gas facility within 50 meters of the reported location. Under Subpart W, an operator with no petroleum and natural gas system equipment within 50 meters of the reported location may submit a certification stating that it does not own or operate the equipment there.

A second certification, in §98.233(y)(6)(ii), is available when the operator has equipment within 50 meters and another facility also owns or operates equipment there. To certify that its equipment was not responsible, the operator investigates the available data within 5 days of the notification and, if the source remains unidentified, surveys its own equipment within 50 meters of the reported location within 15 days. The findings must establish that its equipment did not cause the release.

Suspending the Super-Emitter response does not take other large release events out of Subpart W. As of October 31, 2026, §98.233(y) is still in the codified text. An interim final rule effective October 14, 2026, extended the Reporting Year 2025 greenhouse-gas reporting deadline to March 10, 2027. EPA has also proposed changes to future Subpart W reporting obligations, but those changes have not been finalized.

Keeping the event and investigation records together

Months later, a reporting team may need to establish when a release occurred, which equipment was involved, and how the emissions were accounted for. That means keeping the notification and detection coordinates connected to the operating records, the investigation findings, any repair, and the Subpart W calculation or certification. Without that history, the team may count the emissions twice, or may lose the evidence behind the reporting decision.

Frequently asked questions

Has EPA rescinded the Super-Emitter Program?

No. EPA proposed rescinding the program on October 29, 2026, and has not finalized that proposal. Comments are due December 16, 2026. Separately, the response provisions in §60.5371b are suspended.

Does a Super-Emitter notification have to be included in the Subpart W report?

For a facility that reports under Subpart W, emissions associated with an EPA Super-Emitter notification generally must be included unless a specified certification applies or EPA determines that the notification contains a demonstrable error.

Does a leak found during an OOOOb fugitive survey trigger the Super-Emitter response process?

No. Finding a leak during a fugitive survey does not itself start the EPA Super-Emitter notification process. That process begins when EPA notifies the operator of a qualifying remote detection, and only when the response provisions apply. The same release can still be subject to the OOOOb monitoring and repair requirements.

Related: Emissions measurement and response