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What Conventional Oil & Gas Operators Need to Know About PA’s VOC Reporting Rules

Pennsylvania’s Department of Environmental Protection (DEP) has released updated guidance to help conventional oil and natural gas operators comply with new Volatile Organic Compound (VOC) reporting requirements under 25 Pa. Code §§ 129.131–129.140.

These rules apply to owners and operators of conventional well sites, gathering and boosting stations, and natural gas processing plants that include certain pieces of VOC-emitting equipment.

While many small businesses may already know that annual VOC reports are due each year by June 1, it is important for operators to understand what equipment triggers reporting and how to submit reports correctly.

What Equipment Triggers Reporting?

According to DEP, reporting applies if your operation includes any of the following:

  • Storage vessels

  • Natural gas-driven continuous bleed pneumatic controllers

  • Natural gas-driven diaphragm pumps

  • Reciprocating and centrifugal compressors

  • Fugitive emission components (valves, flanges, connectors, etc.)

If your site operates any of this equipment, you may need to submit a report so DEP can determine whether your source is subject to the requirements or qualifies for an exemption.

How to Submit Reports

All initial and annual reports must be submitted using the DEP Public Upload System (Greenport).

  • No login or account is required

  • Reports must be uploaded as an Excel or spreadsheet file

  • DEP provides a reporting template, step-by-step guide, and a walkthrough video to help you complete the form accurately

If you are past due for your 2023 or 2024 submission, DEP recommends submitting as soon as possible.

Resources for Oil & Gas Operators

DEP has published a new flyer titled “Conventional Oil and Natural Gas VOC Sources – What You Need to Know for Reporting.” It includes:

  • A clear summary of what equipment is subject to reporting

  • Instructions for how, when, and where to file

  • Links to DEP’s upload portal, reporting templates, and guides

  • Contact information for DEP Air Quality staff

Free Help for Pennsylvania Small Businesses

Pennsylvania small businesses (generally 100 or fewer employees) can contact the Environmental Management Assistance Program (EMAP) for free and confidential assistance with:

  • Determining whether your site has reportable equipment

  • Completing the correct reporting template

  • Understanding the initial report requirement

  • Uploading reports through Greenport

  • Avoiding common errors that lead to rejected submissions

Call (877) ASK-EMAP or visit Contact EMAP for help. Additional resources are available on EMAP’s Oil & Gas Compliance Assistance page.

Why This Matters

Pennsylvania’s VOC reporting requirements apply to all owners and operators of conventional oil and natural gas wells, not just commercial oil and gas businesses. This means that individual homeowners, family farms, churches, or other organizations that own a conventional well may still have reporting obligations under 25 Pa. Code §§ 129.131–129.140.

EMAP can assist eligible small businesses with this process and help ensure compliance.

Note: this post was edited on December 10, 2025.

PA DEP Seeks Public Comment on Proposed Methane Emissions Plan for Existing Oil and Gas Facilities

The Pennsylvania Department of Environmental Protection (DEP) is inviting public comment on a proposed State Plan to reduce methane emissions from existing crude oil and natural gas facilities across the state. The proposal is in response to a federal rule from the U.S. Environmental Protection Agency (EPA) under 40 CFR Part 60, Subpart OOOOc—also known as the Emissions Guidelines (EG) for Greenhouse Gas Emissions from Existing Oil and Natural Gas Operations.

This federal rule, part of the EPA’s broader climate review for the oil and natural gas sector, sets national “presumptive standards” to limit methane—a potent greenhouse gas—from facilities that were in operation on or before December 6, 2022. These standards are designed to improve air quality and reduce emissions through updated monitoring, leak detection and repair (LDAR), and equipment upgrades.

Under Section 111(d) of the Clean Air Act, states like Pennsylvania must create and submit plans to the EPA to implement and enforce these federal guidelines at the state level. DEP’s proposed State Plan outlines how Pennsylvania will meet these federal requirements, including timelines for industry compliance.

What This Means for Small Oil and Gas Operators:

If your business owns or operates existing crude oil and natural gas facilities, this rule may impact your operations. The proposal may require new compliance measures such as enhanced leak detection, emissions controls, and recordkeeping. The proposed plan includes specific compliance schedules, giving operators time to prepare and adjust.

Public Comment Period Open Until July 30, 2025

DEP is accepting public comments on the proposed plan through July 30, 2025. You can view the full proposal and its appendices online at https://www.ahs.dep.pa.gov/eComment/.

In addition, a series of public hearings has been scheduled from June 30 through July 16, 2025 at various locations throughout the Commonwealth.  Advanced registration is needed at least 1 week in advance to provide public testimony.

How to Submit Comments:

  • Online: Use DEP’s eComment system: https://www.ahs.dep.pa.gov/eComment/

  • Email: Send to ecomment@pa.gov (include your name and address)

  • Mail:
    Policy Office
    Department of Environmental Protection
    Rachel Carson State Office Building
    P.O. Box 2063
    Harrisburg, PA 17105-2063

If providing comments, please include “Proposed OOOOc State Plan” in the subject line of your written comment. Comments sent by fax will not be accepted.

In addition, for questions or to request copies of the proposed plan, contact Panna Chibber at (717) 772-3993 or pchibber@pa.gov.

Annual VOC Reports for Oil & Natural Gas Sources Due June 1, 2025

If your small business owns or operates equipment related to oil and natural gas development in Pennsylvania, it’s time to prepare and submit your annual VOC emissions report. These reports are required under Pennsylvania’s VOC (Volatile Organic Compound) regulations for both unconventional and conventional oil and natural gas sources (25 Pa. Code §§ 129.121–129.130 and §§ 129.131–129.140).

What Do I Need to Do?

Each year, owners and operators must report specific compliance information related to equipment that is subject to the regulations. The Pennsylvania Department of Environmental Protection (DEP) developed Excel templates to help you meet these requirements—one for Unconventional O&G sources and one for Conventional O&G sources. Each tab in the spreadsheet corresponds to a different reporting requirement.

  • Using the DEP template is optional—but your report must still be submitted in spreadsheet format (Excel preferred).

When is the Report Due?

The next annual VOC report is due June 1, 2025 and will cover calendar year 2024.

This deadline applies to all covered sources and is not subject to any extensions or enforcement suspensions.

How to Submit Your Report

Reports must be submitted through DEP’s Public Upload System:

  • Submission Type: Air Quality Report or Miscellaneous Submission (No Payment)

  • Request Type: Other

  • Submission Notes: Include “129.130 Annual Report” or “129.140 Annual Report”

  • Be sure to include: County and Municipality for each site listed in the report

Do you need help with the submission process? DEP provides a step-by-step Public Upload Guide to walk you through the process.

Why Reporting Matters

Timely and accurate reporting helps ensure your business stays in compliance with environmental regulations, while contributing to Pennsylvania’s efforts to reduce harmful emissions. Staying on top of these requirements can also help your business avoid potential enforcement actions.

EMAP consultants are available to speak with you and ready to answer any questions your small business might have about the annual VOC reporting requirements. Contact us at (877) ASK-EMAP or email us at questions@askemap.org.

New Compliance Guide from EPA for Small Oil and Gas Operations

A new Small Entity Compliance Guide has been released to help small oil and gas operations comply with the latest federal air quality emission standards. Published by the U.S. Environmental Protection Agency (EPA), this guide aims to simplify adherence to the 40 CFR Part 60, Subpart OOOOb regulations, which cover new, reconstructed, and modified sources within the oil and natural gas sector.

Overview

The guide, developed under the Small Business Regulatory Enforcement Fairness Act (SBREFA), addresses essential environmental and human health issues by setting standards to control greenhouse gas (GHG) and volatile organic compound (VOC) emissions from affected facilities. It provides a structured approach for small entities to navigate the complex regulatory landscape and ensure compliance with federal standards.

Key Features

  1. Applicability:
    • The guide outlines which entities and facilities are subject to the new standards, including specific criteria for well completions, liquids unloading, and associated gas management.
  2. Compliance Timetable:
    • A detailed timetable is provided to help small businesses understand the compliance deadlines for different types of facilities. For example, new or modified sources that commenced construction after December 6, 2022, must adhere to the regulations starting May 7, 2024.
  3. Super-Emitter Events:
    • It introduces the Super-Emitter Program, which mandates reporting and corrective actions for significant methane emissions events (100 kg/hr or more).
  4. Detailed Requirements:
    • Sections in the compliance guide cover specific environmental compliance requirements, such as testing, monitoring, reporting, and record-keeping for various types of equipment and operations.
  5. Support and Resources:
    • The compliance guide includes contact information for further assistance and references to additional resources and documents to help small entities stay compliant.

Compliance Support

Small oil and gas operators in Pennsylvania are encouraged to review the guide thoroughly and reach out for assistance in implementing these new standards. For more detailed information, the full compliance guide can be accessed or downloaded here.
Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.