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.
Questions? Contact our professionals at for immediate assistance.
Additional GHG Emissions Resources
Meet SCS Engineers professionals at the A&WMA/ASME Waste Information Exchange, April 11-12, 2023, at the Doubletree Hilton Washington DC-Crystal City Hotel, in Arlington, Virginia.
This conference will cover the latest on a broad range of waste-related topics including regulations and research in an interactive, discussion-focused format. This is an excellent learning and networking opportunity to hear directly from experts at EPA, NGOs, industry, and academia who are working together to develop solutions to creating a cleaner and healthier environment. The technical program will cover policy updates and regulatory changes, as well as current and late-breaking research on hot topics such as:
• Solid Waste
• Biosolids
• Landfill Issues and Greenhouse Gas Emissions Monitoring
• Reuse/Recycling
• Resource Management
• Waste-to-Energy
• PFAS Emissions and Controls
• Environmental Justice
• RCRA Requirements for Open Burning
Managers, practitioners, policymakers, and researchers involved in waste management, public works, operations, maintenance, manufacturing, transportation, technology, compliance, collections, and other environmental roles will benefit from the technical content and networking available at this conference.
Sponsorship and display opportunities are available at this conference! Discover how your company can maximize exposure, generate leads, and support the industry.
Visit www.awma.org/waste for registration information and evolving conference details.
Article published in the January 2020 edition of Waste Advantage Magazine.
At the Federal level, GHG emission reporting has become part of the standard regulatory requirements; however, on the west coast, GHG programs continue to develop and evolve from reporting to reduction programs beyond federal requirements. Solid waste facilities can be impacted by all of these reporting mechanisms directly as a landfill located in the state in question, opting in for C&T as part of the LCFS in California, or in limbo, as the courts work out the legality of Washington’s Clean Air Act. More stringent federal GHG requirements are unlikely with the current administration, however, that could change with the 2020 election. In general, GHG rules and legislation keep developing and updating to account for and reduce GHG emissions.
Read, share, or download the full article here.
Cassandra Drotman Farrant is Project Manager with SCS Engineers. She has nine years of experience in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. Cassandra has participated in many GHG verification projects throughout the U.S. and has completed approximately 70 Phase I Environmental Assessments (ESAs) in California, Oregon, and Washington. Phase I projects included research and review of geologic and hydrogeologic conditions at project sites and in the surrounding areas and evaluating the potential for soil and groundwater contamination from on and offsite sources. Cassandra has completed emissions estimates and inventories and has prepared numerous permit-to-construct/operate permit applications. She prepares compliance reports, which includes reviewing and maintaining records and regulatory deadlines.
SCS Engineers provides engineering, consulting, operations and monitoring services to report and reduce greenhouse gas emissions. Select a service category to learn more.
In August 2019, SCS Energy broke ground on construction of a 4,000-scfm landfill gas to renewable natural gas (RNG) plant in Indianapolis. Indy High Btu, LLC engaged SCS Energy to build the RNG plant under an engineer/procure/construct (EPC) agreement. Indy High Btu, LLC is jointly owned by Kinetrex Energy, Southside Landfill, and EDL Energy.
The RNG plant employs an iron redox scrubber for hydrogen sulfide removal, membranes for carbon dioxide removal and pressure swing adsorption for nitrogen removal. The plant is on schedule to achieve commercial operation in February 2020.
Kinetrex, as a major distributor of LNG, intends to convert the RNG into LNG. RNG from the plant will fuel trucks replacing nearly 8 million gallons of diesel a year. RNG is less expensive than diesel and significantly reduces the emission of methane and other greenhouse gases.
The Indy High Btu RNG plant is the third landfill gas-to-RNG plant designed by SCS to employ nitrogen removal, meeting pipeline specifications and maximizing gas recovery. Two other plants, including a 5,000-scfm project in Kentucky, which commenced operation in March 2018, and a 5,000-scfm project in Texas, which is currently under construction and scheduled to begin operations in November 2019, are both SCS Energy designs.
SCS Energy is a practice of SCS Engineers specializing in Biogas, Anaerobic Digestion, Renewable Natural Gas and Energy Systems for industrial and agricultural operations.
