A Brief Regulatory History in California
On June 22, 2023, the California Air Resources Board (CARB) approved amendments to the Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities (Oil and Gas Methane Regulation). On November 2, 2023, CARB proposed additional modifications for public review. The public comment period ends November 17, 2023.
The Oil and Gas Methane Regulation was originally adopted in 2017 to reduce emissions by requiring:
Then in 2018, this regulation was included in California’s State Implementation Plan (SIP) to address VOC control requirements from the US EPA’s 2016 Control Techniques Guidelines (CTG) for the Oil and Natural Gas Industry. In 2022, the US EPA reviewed the SIP submittal and developed a list of deficiencies. Therefore, the Oil and Gas Methane Regulation was amended to address deficiencies and avoid sanctions under the Clean Air Act.
The Oil and Gas Methane Regulation was also amended so that CARB can use remote monitoring data from approved technologies to detect methane emission plumes and then mandate correction actions.
For example, it is anticipated that CARB will start receiving satellite data in late 2023. Once notified by CARB of a remotely detected methane plume, a facility will need to conduct inspections and repairs as well as submit reports as required by the amended regulation.
Finally, additional amendments were made to clarify the regulatory language based upon CARB’s experience with implementing the regulation over the past five years. Based on this summary in California, there is more movement in other states and not just for oil & gas facilities, but many more.
What to Expect in 2024 – Nationwide
The use of satellites and Carbon Mapper are game changers. Carbon Mapper is a nonprofit entity that started flying key mission sectors and not just landfills or waste management sites. They target energy production facilities, agriculture, particularly livestock coal, mining operations, and oil and gas facilities.
The purpose is to track strong methane emissions, obviously. But the kicker is that the data is free and open to the public in the form of a methane plume overlaid on a map. The imagery usually has estimated emissions rates. Many facility owners, managers, and businesses are not aware of these monitoring events, let alone the accessibility and transparency via the Internet to the public.
Our clients reach out to us knowing that SCS has a robust drone and monitoring program – we can fly the sites and locate leak sources in hours. By using drones, our clients could respond quickly and we could identify current limitations of satellite technology for them. The resolution at a satellites high altitude does not detect and localize leak sources, but remote monitoring and control does.
Many of our clients take a proactive approach now of reoccurring drone methane inspections. We can identify areas of concern before the site is flown by manned aircraft or capture by satellites, and mitigate any potential issues ahead of making headline news. The benefit for implementing long-term operational enhancements and efficiencies prevents odors, complaints, nuisance suits, and negative headlines.
There are complementary technologies that work together, satellites, planes, drones, robot-dogs, automated wellheads, and the traditional boots on the ground. The key is combining the ones that work together to provide a more holistic view of of what’s going on at your facility. That’s where the ROI is and provides a single source to combine all data elements – so no need to move back and forth between software systems.
Additional GHG Emissions Resources