PA Environment Digest Blog: More Than 99% Of Conventional Oil & Gas Well Owners Failed To Comply With DEP’s 2022 Methane Emission Reduction Regulations; How Will It Be Any Different Under DEP’s New Methane Regulations?

On August 6, eight environmental organizations offered public comments to DEP’s Air Quality Technical Advisory Committee supporting DEP’s new initiative to adopt regulations to reduce methane emissions from oil and gas wells and facilities to comply with US Environmental Protection Agency 0000c oil and gas methane reduction regulations.

The Environmental Defense Fund and other groups called on DEP to develop regulations that target the largest methane emissions in the oil and gas industry -- conventional oil and gas wells and facilities.

Kate Courtin, Senior Manager with the EDF State Climate Team, told the Committee--

“The question before us is no longer whether methane should be addressed. It is how Pennsylvania can design the smartest, most effective rule.

“As DEP develops this rule, the data clearly identify where the greatest opportunity exists.

“Research from the Appalachian Methane Initiative shows that low-producing wells [conventional wells in Pennsylvania] account for roughly 64% of methane emissions [across the Appalachian Basin] while contributing to only 1% of production.

“That tells us something important. If Pennsylvania wants meaningful methane reductions, low-producing wells must be part of the solution.

“As was just noted, the simple truth is that large companies own the vast majority of low-producing wells.

“Eleven oil and gas corporations own nearly half of low-producing wells in Pennsylvania as of 2024.

“At the same time, there are truly small operators whose circumstances are different.

“A durable rule should recognize both realities. DEP should develop strong and resilient standards that achieve equivalent or greater reductions as the 2024 US EPA methane rule.”

The same research by the Appalachian Methane Initiative-- a coalition of CNX Resources, EQT Corporation, MPLX and Seneca Resources at the University of Texas and Colorado State University-- also found unconventional shale gas wells account for 17.5% of methane emission while producing over 98% of the basin-wide natural gas.

According to a FracTracker Alliance analysis, these are the top 11 conventional oil and gas well owners in Pennsylvania that own wells producing 15 BOE [barrels of oil equivalent] or less-- Diversified Production LLC - 21,147; Minard Run Oil Co. - 2,172; OWS Energy LLC - 2,603; Cameron Energy Co. - 1,867; Apollo Resources LLC - 1,876; Pennhills Resources LLC - 1,676; Snyder Bros Inc. - 1,705; VEC Energy LLC - 1,852; ARG Resources Inc. - 1,547; Bull Run Resources LLC - 1,489; and Kriebel Natural Gas Co. LLC - 1,675.

These top 11 conventional well owners account for 39,607 low-producing wells, which is about 44.4% of the 89,161 low producing conventional wells at 15 BOE or below, leaving out 55.6% of conventional wells in this count.

Readers of the PA Environment Digest Weekly Oil & Gas Compliance reports will recognize many of these conventional well owners’ names, because they show up frequently in DEP violations and enforcement actions.

Diversified Production LLC, as the largest owner, has frequent violations and signed an agreement with DEP in 2019 to plug over 1,400 abandoned wells it owns; Minard Run Oil Co. owns 390 abandoned wells; ARG Resources Inc. owns at least 36 abandoned wells and was the target of recent US Forest Service action to close unsafe facilities.

Visit DEP’s Oil and Gas Compliance Database to check them out for yourself

Click Here for the top 30 companies from FracTracker.

99% Noncompliance In 2022

This isn’t the first time DEP is adopting regulations limiting methane emissions from oil and gas operations.

In November 2025, DEP 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.

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.

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.

DEP made a presentation on the 2022 regulation to the Air Quality Advisory Committee on November 6, 2025 that included a description of an extensive outreach effort DEP made to conventional oil and gas facility owners on the regulation.

Expected Emissions Benefits 2022

In 2022, when these regulations 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 2022 regulation to reduce emissions from conventional facilities by much more than unconventional shale gas wells-- 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 2025 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: In 2025, DEP issued 688 violations to 132 conventional well owners for abandoning and not plugging 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.

What Will Be Different?

Given the ‘culture of non-compliance’ in the conventional oil and gas industry and the already failed attempt to adopt methane regulations covering the industry in 2022, what will DEP do differently in the new oil and gas methane regulation to achieve compliance?

Well, that’s the question isn’t it.

Resource Links:

-- DEP To Adopt Regulations Limiting Methane Emissions From Conventional Oil & Gas, Shale Gas Infrastructure; Will Outline Approach At Aug. 6 Air Quality Technical Advisory Committee Meeting [PaEN]

-- 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 [PaEN]

PA Oil & Gas Industry Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Snapshot - Aug. 8 to 14

-- DEP - Day 632: Seneca Resources Installs Trench, Concrete Catch Basin To Collect Continuing Releases Of Contaminated Water From The Taft Shale Gas Well Pad In Middlebury Twp., Tioga County [PaEN]

-- DEP Nucomer Energy LLC Making Progress Reclaiming Shale Gas Water Impoundment In Forest County Nearly 14 Years After It Was No Longer In Use, 981 Days After A DEP Order Requiring Restoration [PaEN]

-- DEP Evaluating 37 Conventional Oil & Gas Wells In Venango County For Plugging As A Result Of Owner’s Death [PaEN]

-- DEP: Keystone Crude LLC Making Progress On Spills, Releases At 3 Conventional Gas Well Sites In Allegheny County Dating Back To 2024 [PaEN]

-- DEP: Trinity Mineral Partners Report Release Of Contaminated Water From Conventional Oil & Gas Wells From A 44,100 Gallon Battery Of 5 Storage Tanks In Warren County; Inspection Of 2nd Trinity Spill Site Shows No Cleanup Progress [PaEN]

-- Allegheny County - D & B Gas Production LLC - Conventional Well Compressor Leak: August 10, 2026 routine inspection of the Springdale Boro 1 conventional well in Springdale Township found gas was leaking from a compressor onsite. Violation issued, response requested by Aug. 28. DEP inspection report.

-- Elk County - Pin Oak Energy Partners LLC - Improperly Abandoned Gas Pipeline [297 Days] August 7, 2026 follow-up inspection of an abandoned conventional gas gathering line crossing Pine Run stream in Ridgway Township found the pipeline needs to be capped to prevent the stream from entering and discarded pipeline needs to be removed. Original violations Oct. 14, 2025. Violations continued. DEP inspection report.

-- Tioga County - Seneca Resources Co LLC - Shale Gas Casing/Cement Failure [621 Days] July 27, 2026 inspection of the Taft 75HU Utica shale gas well in Middlebury Township for casing/cementing failure found gas still present. Original violation Nov. 13, 2024, violation continued. DEP inspection report. This same pad has continuing wastewater releases

-- Washington County - EQT Production Co. - Conventional Well Venting Gas: August 3, 2026 inspection of the Ellsworth Collieries 3256 conventional gas well in Somerset Township found the well venting gas. Violations issued. Response requested by Aug. 28. DEP inspection report.

DEP inspected 62 conventional oil and gas wells as part of federal-funded well plugging program - August 8 - 14

Click Here for Violations Issued August 8 - 14

Click Here for Inspection Reports August 8 - 14

-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - August 15 [PaEN]

-- DEP Invites Comments On Air Quality Permit For Installation Of 86 More Backup Diesel Generators, Fuel Storage Tanks For An Expansion Of The Existing Amazon Data Center In Salem Twp., Luzerne County [PaEN]

-- DEP Invites Comments On Proposed Use Of Emission Credits By Invitium Energy LLC [PPL-Blackstone Joint Venture] For Proposed Shermans Dale Natural Gas Power Plant In Carroll Twp., Perry County To Feed Data Centers [PaEN]

-- DEP Invites Comments On Chapter 105 Permit For Construction Of A Shale Gas Water Withdrawal Structure In The Susquehanna River By Expand Operating LLC In Standing Stone Twp., Bradford County [PaEN]

-- DEP Issues Chapter 102 Permit For Northeast Natural Gas Supply Enhancement Project Quarryville Loop, Compressor Station 200 In Chester, Lancaster Counties [PaEN]

-- DEP Posted 58 Pages Of Permit-Related Notices In August 15 PA Bulletin [PaEN]

-- Public Utility Commission Sets Oct. 29 Prehearing On Transource Pennsylvania, LLC 230kV Project 9A West Transmission Line In Franklin County [PaEN]

-- DEP Invites Comments On Stormwater Permit For PPL Electric Stanton Summit Transmission Line Rebuild In Lackawanna, Luzerne Counties [PaEN]