PA Environment Digest Blog: DEP: More Than 99% Of Conventional Oil & Gas Facility Owners Failed To Comply With VOC/Methane Reduction Regulations Covering 64,660 Wells; Had 193 Days To File

On November 5, the Department of Environmental Protection reported 99.3% of conventional oil and gas facility owners failed to comply with a 2022 DEP regulation to reduce methane and volatile organic compound emissions from their oil and gas facilities, in response to questions from PA Environment Digest.

Conventional well owners were required to submit an annual report starting June 1, 2025 outlining their equipment subject to the regulation, the methods of emission controls used and any deviations from the requirements during calendar year 2024.

It’s been 193 days since conventional owners first knew they were required to file the report-- April 26,2025.

DEP said 32 [0.65%] of the approximately 4,960 conventional oil and gas well facility owners did submit reports covering approximately 36,400 [36%] out of the 101,000 wells required to report.

In contrast, DEP said 116 of the 126 unconventional shale gas facility owners required to report on June 1 did submit reports covering 4,456 of the approximately 4,500 facilities covered by the regulation.

DEP said it sent notices of violation to the 10 shale gas facilities that did not report.

In addition, DEP explained, “conventional oil & gas facilities are not required to submit emission inventory reports and are treated as ‘area sources.’ Their emissions are calculated by DEP in the aggregate using the EPA’s nonpoint sources methodology.”

Air emissions from unconventional shale gas facilities are reported annually as part of DEP’s Air Quality Emission Inventory database.

DEP said there are several entries in the database labeled conventional wells, however, these are data errors and will be corrected.

DEP made a presentation on this regulation to the Air Quality Advisory Committee on November 6 that included a description of an extensive outreach effort DEP made to conventional oil and gas facility owners on the regulation.

[Note: This 2022 regulation is separate from the updated regulation DEP is developing to reduce methane emissions from conventional and unconventional oil and gas facilities. Read more here.]

Expected Emissions Benefits

In 2022 when these regulations covering conventional and unconventional oil and gas facility emissions were adopted, DEP said it expected to achieve a 12,068 tons per year reduction in volatile organic compounds and a 221,066 tons per year reduction in methane.

DEP expected the regulation to reduce emissions from conventional facilities by 9,204 tons per year of volatile organic compounds and 175,788 tons per year of methane. Regulatory Analysis Form.

DEP expected reductions from unconventional shale gas facilities to be 2,864 tons per year of volatile organic compounds and 45,278 tons per year of methane. Regulatory Analysis Form.

Some quick math means DEP was counting on conventional oil and gas facility owner compliance for 76.3% of volatile organic compound emission benefits and 79.5% of methane reduction benefits.

‘Culture Of Non-Compliance’ Continues

In December 2022, DEP issued a report analyzing the compliance record of the conventional oil and gas industry in Pennsylvania and found they routinely abandoned wells and failed to comply with critical environmental laws and regulations. Read more here.

DEP concluded: “A significant change in the culture of non-compliance as an acceptable norm in the conventional oil and gas industry will need to occur before meaningful improvement can happen.”

In June before the House Environment and Natural Resource Protection Committee, Kurt Klapkowski, DEP Deputy Secretary for Oil and Gas Management, said DEP continues to see “widespread non-compliance with laws and regulations in the conventional oil and gas industry, particularly regarding improper abandonment of oil and gas wells, but also not reporting hydrocarbon and waste production [and disposal] and conducting mechanical integrity assessments.” Read more here.

Some examples--

-- Abandoned Wells: So far in 2025, 113 conventional oil and gas well owners were issued 529 violations for abandoning their wells. Read more here.

-- Waste Generation/Production Reports: 85% of conventional owners failed to submit 2024 annual reports on production and how much waste they generated and how it was disposed of-- 4,204 conventional well owners failed to submit covering 23,708 wells, 753 well owners covering 81,396 wells that did report. Read more here.

-- Well Integrity Reports: 87% of conventional well owners failed to submit 2024 annual well integrity reports critical to detect and prevent wells from leaking-- 4,314 conventional well owners failed to submit covering 24,620 wells, 638 well owners did submit covering 77,647 wells that did report. Read more here.

-- Violations Issued/Enforcement Actions: As of October 31 in 2025, DEP issued 5,029 violations to conventional oil and gas facility owners and took 369 follow-up enforcement actions (orders, consent agreements). Read more here.

As of November 1 in 2024, DEP took more enforcement actions against conventional well owners, in spite of the fact DEP said noncompliance was still “widespread,” -- 6,734 violations and 453 follow-up enforcement actions. Read more here.

Doing More Requires More

Klapkowski said, “It cannot be emphasized strongly enough, however, that increased oversight of the conventional oil and gas industry and enforcement will require additional resources, especially in the DEP Office of Chief Counsel and the Bureau of District Oil and Gas Operations.

“Governor Shapiro’s 2025-26 budget proposes $19 million to continue finding and plugging wells and the important mission of this office.

“Developing a stable funding source to fund these efforts will be critical to successfully altering the current course of non-compliance in the conventional oil and gas industry in Pennsylvania.”

[Note: DEP’s Oil and Gas Program compliance inspection staff has been frozen since December 2016 even though the number of shale gas wells issued permits grew 33% from 2016 to 2024. Read more here.

[DEP has used federal well plugging money to hire additional staff to administer that program.]

Click Here for a copy of DEP’s written House testimony.

(Photos: Row 1- Shale gas facility methane emissions; Row 2- Conventional oil & gas well methane emissions.)

Resource Links - Conventional Methane:

-- Conventional Oil & Gas Facility Owners Must Now File A Methane Emissions Compliance Report By June 1, 2025 Required By A 2022 DEP Methane Pollution Reduction Rule As A Result Of Court Settlement [PaEN]

-- Conventional Oil & Gas Well Owners Now Operate As Many As 95% Of Conventional Wells To Vent Methane Gas Making It Too Expensive To Comply With New EPA Methane Emission Reduction Regulations [PaEN]

-- DEP Methane Overflight Research Study Resulted In Voluntary Reductions In Oil & Gas, Landfill Facilities; Coal Industry Uncooperative [PaEN]

Resource Links - New DEP Oil & Gas Methane Rule:

-- DEP Sets 8th Hearing July 22 On State Plan To Implement Federal Rule Requiring Methane Emissions Reductions From Conventional Oil & Gas, Shale Gas Facilities [PaEN]

-- Oil & Gas Methane Pollution Reduction Testimony: Patrice Tomcik, Mother, Butler County Resident And Moms Clean Air Force Member [PaEN] [Includes Links To Other Testimony]

-- Shale Gas Industry VP Attacks Credibility Of A Mom And Allegheny County Resident For Comments She Submitted In Support Of DEP Plan To Reduce Methane Emissions From The Oil & Gas Industry [PaEN]

-- PA Marcellus Shale Gas Coalition Applauds President For Overturning Basis For Greenhouse Gas Reduction Programs-- Including Methane From Oil & Gas Operations [PaEN]