EPA's Own Math: $45 Billion in Savings, 60 Million Tons More Methane
Trump said the methane rule is terminated; EPA's signed paper is a proposal. Its impact analysis explains the $45 billion, the 210 million barrels and the 60 million tons.
"Terminating" is a verb with a finish line, and the paper EPA Administrator Lee Zeldin signed on Tuesday, Oct. 27, does not reach it. At a Lubbock, Texas, rally for Republican Senate candidate Ken Paxton that day, President Donald Trump put it this way:
"I'm officially terminating Biden's expensive and unnecessary methane regulations to save consumers and energy producers $45 billion in costs…"
President Donald Trump, Lubbock, Texas, Oct. 27, 2026
What Zeldin signed is a proposed rule, a prepublication notice in Docket EPA-HQ-OAR-2025-0163 that has not yet appeared in the Federal Register. Comments are due 48 days after it does, according to the signed notice (EPA's web page says 45), with a virtual public hearing 15 days after publication. Trump himself added, "Statutorily it takes a little while." EPA's analysis assumes the rule takes effect by the end of 2026.
The proposal rewrites the 2024 Clean Air Act methane standards for oil and gas, known as OOOOb for new sources and OOOOc for existing ones, which states enforce through their own plans. It creates a lighter tier for low-producing "marginal" wells, rescinds the Super Emitter Program, restores flaring as the standard for associated gas, builds a repair window into cover and vent-system rules, and asks whether to repeal still more. EPA says the package will save $45 billion. Some coverage has run the verb and the paper together; they are different things.
A signed proposal, not a finished rule
The road has been long. The 2024 rule was published on March 8, 2024, and Zeldin announced reconsideration on March 12, 2025. A narrow first reconsideration was finalized in April 2026. Zeldin previewed this larger proposal on Oct. 7 in Santa Fe, 20 days before signing; the Associated Press says "last month," which is wrong.
The center of the proposal is a definition. A marginal well is one that produced "less than or equal to 15 barrels of oil equivalent per day over the prior 12-month period," which for gas is 90,000 cubic feet a day. EPA also co-proposes a second option that draws the line by well type, conventional versus unconventional, rather than output.
For marginal sites, EPA's tables show what changes. AVO is auditory, visual and olfactory inspection: a worker looks, listens and smells. OGI is optical gas imaging, an infrared camera that makes invisible methane show on a screen.
| What | 2024 rule | Proposal |
|---|---|---|
| Leak checks, large well site | Bimonthly AVO and quarterly OGI | Quarterly AVO |
| Leak checks, multi-wellhead site | Quarterly AVO and semiannual OGI | Quarterly AVO |
| Pneumatic pumps | Zero emissions | Route to existing control device |
| Process controllers | Zero emissions | Low bleed, quarterly AVO |
| Associated gas, 20+ tons methane a year | Route to sales | 95% control |
| Associated gas, under 20 tons | Route to sales | No requirement |
| Liquids unloading | Best management practices | No requirement |
EPA RIA, Table 1-2, for new-source rules (NSPS OOOOb); existing-source presumptive standards are similar but set through state plans.
The pattern is plain: the camera goes away. Quarterly AVO is a person with a nose and a clipboard, and the logic of the 2024 rule was that a nose misses what an infrared lens catches.
Two changes sit outside the table. The Super Emitter Program used certified third-party monitors to flag leaks of 100 kilograms an hour or more; EPA says it "is not effective," while the 2024 rule said such events may "contribute almost 50 percent of the methane emissions in the oil and gas sector." EPA does not quantify the loss, calling it "qualitative due to lack of specific information." And on associated gas, the gas that comes up with oil, EPA would restore "95% efficient flaring or other control devices" in place of requiring it all to reach a sales line.
Small wells, big leaks
Why carve out low producers at all? Because there are so many. EPA's fact sheet counts about 783,000 of more than 990,000 wells as marginal, 79 percent; the impact analysis, using 2023 data, finds about 76%. Yet those wells made 5.63% of U.S. oil and 5.97% of gas, and the 125,367 oil wells making under one barrel of oil equivalent a day, 37% of oil wells, produced 0.35% of the nation's oil.
The last bar is the one that matters. A Department of Energy-funded study cited by EPA puts marginal wells at roughly half of production methane, and EPA's own 2024 analysis said 47% to 53%. The preamble explains why: emissions are "not strongly correlated with production" but "most strongly correlated with major equipment count," and the top emitting sources were mostly "malfunctioning or poorly maintained equipment." A well pumping under a barrel a day can have the same tanks, valves and controllers as a bigger neighbor.
That is the whole dispute in one fact. A production cut-off lowers the bill for a tiny well, and it also exempts equipment that leaks regardless of output. As Darin Schroeder of the Clean Air Task Force told Grist:
"Just because they're a marginal producer doesn't mean they're a marginal polluter."
Darin Schroeder, methane legal and regulatory director, Clean Air Task Force
What the $45 billion measures
The figure is real, and it comes from EPA's own impact analysis. What it counts is narrower than the sentence suggests.
First, it is a present value: savings over 2027 to 2050, discounted to 2025 and stated in 2024 dollars. At EPA's 7% discount rate the same analysis gives $32 billion.
Second, it is lumpy. Of roughly $42 billion in compliance savings, about $16 billion is equipment and plan costs operators will not have to buy, and about $30 billion is yearly operating cost avoided. EPA subtracts $4.2 billion because operators would capture less gas to sell, then adds $3 billion in energy-market effects. Undiscounted, the savings are $310 million in each of 2027 and 2028, then $15 billion in 2029, when the model has existing-source controls coming due. After that it is $1.9 billion to $2.4 billion a year.
Third, and this is what the headlines skip, the ledger has one column. EPA writes: "We do not monetize costs of the proposed action; however, we quantify the emission increases of methane, VOC, and HAP for which we would anticipate there being unquantified costs resulting from negative health outcomes and environmental damages."
The administration has a fair reply. The Biden rule's benefit figure, $98 billion by 2034 per AP, came from the "social cost" of greenhouse gases, a method AP says Trump's EPA rejected, and EPA says the regulations "were estimated at the time to cost $18 billion" and were underestimated. But that figure covers 2024 to 2038 in 2019 dollars, not 2027 to 2050 in 2024 dollars, so the two are not a clean pair. The opposing point is simpler: a rule's costs belong beside its benefits, and EPA chose not to put them there.
The 210 million barrels deserve the same unpacking. Adding the analysis's yearly production rows gives 209.8 million barrels of oil and 1,410 billion cubic feet of gas over 24 years. That is about 8.75 million barrels a year against projected 2027 U.S. production of 5.1 billion, roughly 0.2%. AP put the total at about 10 days of U.S. petroleum consumption.
The price effect is smaller still. EPA projects crude falling $0.11 to $0.24 a barrel; divided by 42 gallons, that is a quarter to a little over half a cent per gallon of crude cost. That is not a pump-price forecast, and how crude moves reach the pump involves more steps. EPA itself says the impacts "are small in magnitude for both markets, typically a fraction of a percent in all years." Zeldin framed the case as household economics:
"Americans must be able to afford to heat their homes in the winter and fill up their car and drive to work. They can't do that when the people producing the energy are weighed down by unnecessary burdens."
EPA Administrator Lee Zeldin, Oct. 7, 2026
The documents show help for a producer's balance sheet. They do not show a family noticing it.
The methane nobody priced
The unpriced column has numbers. EPA projects 60 million short tons more methane from 2027 to 2050, about 54.4 million metric tons, along with 17 million tons of smog-forming volatile organic compounds and 2.3 million tons of hazardous air pollutants. Methane traps about 80 times as much heat as carbon dioxide over 20 years, which makes it a lever on near-term warming. The VOCs are ozone precursors, and the analysis lists ozone-related health effects among outcomes it does not monetize; Grist adds benzene, a known carcinogen. The 60 million is not split by provision, so the Super Emitter rescission cannot be read off it.
EPA also doubts its own number. It has "serious doubts" the reductions would be as significant as its estimates suggest, because state programs and company commitments are not in the baseline, associated-gas data are thin, and its model does not allow operators to change equipment configurations, so it may overstate reductions. A closed well, in the model, emits nothing.
The cost side is just as real, and just as hedged. EPA's model has the 2024 rule closing almost 200,000 marginal wells in 2029 in its deterministic version (it warns that may overstate closures), against 25,032 under the proposal. The National Stripper Well Association says compliance costs $5,000 to $15,000 a year for wells netting $5,000 to $10,000, and warns that "the costs associated with complying with these regulations will make the wells uneconomical to operate." The Independent Petroleum Association of America adds: "Our country should be doing everything we can to extend the productive life of these wells vs. prematurely shut them in." Yet the closures rest on a $3,000-a-year fixed-cost assumption that EPA itself holds with "a low degree of confidence."
Who owns these wells? EPA's release says "many are family-owned wells." Its own ownership table splits the story. Firms with 10 or fewer wells are over 65% of firms but own 3.2% of marginal wells. Meanwhile 127 firms with 1,000 or more wells operate 51.3%, and 903 firms with 100 or more own 80.6%. Both are true: most firms are tiny, most wells are not theirs. Grist reports Hilcorp is thought to own nearly 19,000 low-producing wells and Diversified Energy more than 50,000.
Whether the federal change bites depends on the state. Colorado voted unanimously on Sept. 18 to finish adopting the 2024 existing-source standards, and Oil & Gas Journal reports its rules can continue to apply even if EPA weakens the federal ones. New Mexico's hearing on a state rule, with a statewide super-emitter program, begins Dec. 1. Texas is the open question: Grist reports about 136,000 stripper wells there and repeatedly delayed state plans.
The methane fee was not "repealed," as AP says. Congress disapproved EPA's implementing rule, and a July 4, 2025 budget law moved the statutory charge to 2034, at $1,500 per metric ton, according to the Congressional Research Service. The charge carries a conditional exemption if EPA's methane standards are in effect, so this rule's shape matters to it.
Anyone can comment through the docket on regulations.gov, and EPA's proposal page will post the deadline. It cannot post one yet. The Federal Register has not scheduled publication, so the 48 days have not started, the hearing has no date, and the Jan. 22, 2027 state-plan deadline sits in the background. The document both sides will quote, as the Associated Press reported the argument forming, is a table EPA wrote itself.
