Will Trump Mend or End Federal Methane Rules?

Carrie Jenks co-authors timely analysis of Trump Administration’s options for methane policy
Jan 29, 2025

Carrie Jenks, Executive Director of Harvard Law School’s Environmental & Energy Law Program, and a faculty participant in the Harvard Salata Initiative on Reducing Global Methane Emissions, has co-authored a new policy paper reviewing recent U.S. regulations aimed at reducing methane emissions and the Trump Administration’s major options for modifying or reversing these regulations. The paper is titled “Will Trump Mend or End Federal Methane Rules?” and was released by the Center for Energy and Environmental Systems Analysis, Cockrell School of Engineering, University of Texas at Austin in January 2025. Jenks’ co-authors are Kevin Book (ClearView Energy Partners); Ben Cahill (University of Texas at Austin); Kyle Danish (Van Ness Feldman LLP); and Bob Stout (Duke University and University of Texas at Austin).

The paper may be downloaded here.

The paper reviews in some detail recent U.S. regulations; complexities associated with attempts to repeal these regulations; options for modifying the rules; the impact of the emerging international regulatory regime – especially European Union rules on imports of liquefied natural gas (LNG) – on U.S. rulemaking; and industry’s attitudes toward methane regulations and their possible repeal or modification.

From the paper’s introduction:

“…a number of Congressional Republicans have criticized the Biden administration’s methane regulations. These include the Inflation Reduction Act Waste Emissions Charge (WEC) and its implementation rule, updated reporting requirements under Subpart W of the Environmental Protection Agency (EPA) Greenhouse Gas Reporting Program, and requirements for managing and mitigating emissions of methane and volatile organic compounds from new and existing oil and natural gas production sources (the OOOOb and OOOOc regulations). Some in the Trump administration and new Congress may want to end these three methane rules… However, such an approach would be at odds with the efforts and commitments of many oil and gas companies to reduce methane emissions.

“This paper explores the considerations that the Trump administration will face in deciding whether to rescind the regulations altogether or in substantial part (effectively ending them) or to make more surgical changes to the rules (mending them). The paper outlines several possible legislative and regulatory scenarios, and highlights key decision points to monitor. The paper also analyzes the broader context for federal methane regulations. Corporate commitments and investor pressure suggest that oil and gas companies will continue to prioritize methane reductions and may favor retaining a rules-based framework. New regulations in the European Union (EU) and emerging buyer demands have the potential to create incentives for natural gas producers, midstream companies, and LNG sellers to provide data on emissions intensity across natural gas supply chains. These external demands suggest that mending rather than ending federal methane regulations could align better with the interests of US oil and gas companies.”

The paper may be downloaded here.