MERP Clarifications Act of 2025

The MERP Clarifications Act of 2025 would modify the Clean Air Act’s Methane Emissions Reduction Program (MERP) by adding protections and exemptions for small upstream oil and gas producers, delaying when charges can be imposed, and increasing transparency and public participation. It creates eligibility criteria for small facilities to be exempt from MERP reporting and charges, requires certain producers to be exempt while they are in compliance with other federal/state regulations, and ties the imposition of any MERP charge to specific preconditions (such as fully disbursing grants and finalizing updated emission factors). The bill also adds new requirements for public notice, an administrator’s order explaining calculation methods, a public-comment process for implementation rules, an expedited dispute-resolution process for charges, and a sunset provision ending the program (and charges) on December 31, 2034 unless Congress reauthorizes it. If the act sunsets, there are provisions for potential financial compensation to facilities harmed by continued federal actions and for expedited court relief for small facilities. In short, the bill aims to (1) narrow MERP applicability to small producers, (2) require more transparency and public participation in how MERP calculations and charges are developed, (3) delay and condition the imposition of any charges, and (4) create a hard sunset with a mechanism to address harms if the program is not renewed.