As of September 2026, NSPS OOOOb and OOOOc are still in force, but many of their compliance deadlines have been extended. Through interim final rulemaking in 2025 and further action into 2026, the EPA pushed most OOOOb compliance dates out by roughly 18 months, to January 22, 2027, and moved the OOOOc state-plan deadline to the same date. The rules were not repealed. For Texas operators the practical risk now is not a tight clock; it is confusing an extension with a cancellation and letting programs lapse. This guide lays out what changed, what still applies, and what to do about it.
What are NSPS OOOOb and OOOOc?
NSPS Quad O is the EPA's set of New Source Performance Standards for methane and volatile organic compound emissions from the oil and gas sector, at 40 CFR Part 60. The 2024 rule added two pieces:
- Subpart OOOOb applies directly to sources constructed, modified, or reconstructed after December 6, 2022. It sets the leak-monitoring, storage-vessel, process-controller, compressor, and flare requirements for those newer sources.
- Subpart OOOOc is an emissions-guideline for existing sources. It does not apply to operators directly; instead it directs states to write plans that achieve reductions at least equivalent to OOOOb.
Both were finalized in the Federal Register on March 8, 2024 and took effect May 7, 2024. For a fuller breakdown of which subpart applies to a given source, see our NSPS Quad O overview.
What did EPA change in 2025 and 2026?
Beginning with an interim final rule effective in mid-2025 and continuing into 2026, the EPA extended a large set of OOOOb compliance deadlines and the OOOOc state-plan deadline. The table below summarizes the status of the major items as of September 2026. Because the situation remains in flux, treat these as a starting point and confirm the current date for any requirement that affects you.
| Requirement | Status as of September 2026 |
|---|---|
| Most OOOOb compliance requirements: storage-vessel provisions, tank-battery legally and practically enforceable (LPE) limits, flares and enclosed combustion devices, equipment-leak repair provisions, closed-vent system and cover monitoring, and zero-bleed process controllers | Extended roughly 18 months, to January 22, 2027 |
| Super emitter program (EPA implementation) | Extended to January 22, 2027 |
| Net heating value (NHV) monitoring for flares and enclosed combustion devices | Received a much shorter extension than the other items; confirm the current date directly with the EPA |
| OOOOc state-plan submissions | Extended to January 22, 2027 (previously March 9, 2026) |
| Compliance date for existing sources under OOOOc | Unchanged: March 2029 |
What still applies right now?
The extensions moved compliance dates; they did not switch the rule off. A few things are worth stating plainly:
- Applicability is unchanged. A source built, modified, or reconstructed after December 6, 2022 is still an OOOOb source. Nothing about the extensions changes which rule you fall under.
- Existing permit and state obligations continue. Federal NSPS is only one layer. TCEQ air-permit conditions and other state requirements run in parallel and are not affected by a federal deadline extension.
- The obligations still arrive. An 18-month extension is time to build the program correctly, not a reason to stop. Component inventories, monitoring plans, and recordkeeping systems take months to stand up well.
The super emitter program
One of the more significant pieces of OOOOb is the super emitter program, aimed at the largest releases. Under it, approved third parties using remote-detection technology can identify very large methane leaks, generally 100 kilograms per hour or more, and notify the operator, who must then investigate and respond within set timeframes. EPA's implementation of the program was among the items extended to January 22, 2027, but the underlying expectation, that large releases will increasingly be detected from outside the fence line, is not going away.
What should Texas operators do now?
The extension is an opportunity, not a reprieve. The operators who use the time well will be ready when the date arrives; the ones who read the headline as a cancellation will be scrambling. A practical sequence:
- Confirm your subpart and sources. Determine which facilities are OOOOb sources and which are existing sources that will eventually be covered by a Texas state plan under OOOOc.
- Track the current deadlines. Because the dates have moved more than once, keep a single, dated record of the current compliance date for each requirement, and revisit it as the EPA acts.
- Build the monitoring program now. A defensible LDAR program, an accurate component inventory, and clean recordkeeping are not overnight jobs. The extension window is exactly when to build them.
- Coordinate with your TCEQ obligations. Make sure the federal work lines up with your state air-permit conditions rather than duplicating or contradicting them.
How Tektite helps
The hard part of the current moment is not any single deadline; it is keeping track of a set of dates that have moved, while the underlying programs still have to be built. Tektite builds and runs LDAR programs for Texas operators and coordinates the federal NSPS requirements with TCEQ air-permit obligations, so nothing falls through the gap between an extended federal date and a state requirement that did not move. If you want a clear read on which of your sources are covered and what the current deadlines are, a focused review is the place to start.
This guide reflects the regulatory status as of September 2026 and is general information, not legal or compliance advice. NSPS OOOOb and OOOOc deadlines have been amended more than once and remain subject to change. Confirm the current requirements for your facilities with the EPA, the Federal Register, or a qualified environmental professional before making compliance decisions.
Related reading
Frequently Asked Questions
Were the NSPS OOOOb and OOOOc deadlines extended?
Yes. Through interim final rulemaking in 2025 and further action into 2026, the EPA extended many NSPS OOOOb compliance deadlines by about 18 months, to January 22, 2027, and moved the OOOOc state-plan submission deadline to the same date. The rules were not repealed, and the compliance date for existing sources under OOOOc remains March 2029. Because the regulatory situation is still in flux, operators should confirm the current date for any specific requirement with the EPA or a qualified professional.
Does an extended deadline mean OOOOb no longer applies?
No. An extension moves a compliance date; it does not remove the obligation. Sources constructed, modified, or reconstructed after December 6, 2022 are still subject to NSPS OOOOb, and the underlying leak-monitoring, storage-vessel, controller, and flare requirements still apply on the current schedule. Treating an extension as a repeal is how operators end up out of compliance when the date arrives.
What is the NSPS OOOOb super emitter program?
The super emitter program is a mechanism for identifying very large methane releases, generally leaks of 100 kilograms per hour or more, using approved remote-detection technology and third-party notifications that an operator must then investigate and address. EPA's implementation of the program was among the items extended to January 22, 2027.
When must existing sources comply under OOOOc?
OOOOc is the emissions-guidelines side of the rule, implemented through state plans rather than applying to operators directly. The deadline for states to submit those plans was extended to January 22, 2027, while the compliance date for existing designated facilities remains March 2029. The specific obligations for an existing source will ultimately be set by the applicable state plan.
