S. 514 — MERP Clarifications Act of 2025

This section amends section 136 of the Clean Air Act (42 U.S.C. 7436), which establishes the Methane Emissions and Waste Reduction Incentive Program for Petroleum and Natural Gas Systems (i.e., imposes a charge on excess methane emissions from applicable facilities and provides grants for emission reductions), as follows: (1) exempting from reporting requirements and charges small upstream producers (i.e., applicable facilities generating less than 25,000 metric tons of carbon dioxide equivalent per year and employing 2,500 or fewer full-time employees, as of August 16, 2022), with EPA required to notify such facilities within 60 days of enactment and publicize the exemption; (2) exempting from charges facilities that comply with EPA methane regulations (subparts OOOOb and OOOOc of 40 C.F.R. part 60, or successors) and are located in states with compliant implementation plans; (3) delaying imposition of the charge until January 1 of the first calendar year after EPA notifies congressional committees that grants under subsections (a) and (b) are fully disbursed and revisions to subpart W of 40 C.F.R. part 98 use validated emission factors; (4) requiring a minimum 90-day public comment period for proposed rules or guidance implementing the program (except as specified in another act); (5) directing EPA to propose within 60 days of enactment an expedited dispute resolution process for challenging imposed charges; (6) terminating program authority on December 31, 2034, after which EPA must cease charges (with private right of action for enforcement and expedited court review for small facilities) and rescinding unobligated grant balances; and (7) requiring EPA, within 60 days of enactment, to issue a public Administrator's Order describing program requirements and calculations, consistent with the Plain Writing Act of 2010 and specified executive orders on regulatory planning, civil justice reform, and retrospective review.