CIPA Begin Technical Discussions with CARB on SB 1137 Regulations

CIPA met with the California Air Resources Board (CARB) last week for the first in a series of technical discussions focused on the agency’s development of regulations implementing SB 1137.

The meeting follows CARB’s July workshops and the August 31 deadline for comments on the agency’s initial Discussion Draft. CIPA submitted detailed comments identifying areas where the proposed requirements could be improved to provide a workable regulatory framework while meeting the objectives of SB 1137.

CARB reported receiving more than 16 comment submissions and is now reviewing that feedback as it develops alternatives and revised regulatory language. Formal rulemaking is currently expected to begin in the second quarter of 2027, giving CIPA and other stakeholders an important opportunity to work with the agency before the formal administrative process begins.

Several technical issues raised by CIPA and industry representatives received substantial discussion.

One of the most important issues involved establishing baseline environmental conditions for continuous monitoring systems. CARB clarified that an alert threshold would be added to an established baseline rather than applied as a standalone concentration. This distinction is important because methane can originate from numerous sources unrelated to an oil and gas facility, including natural seeps, landfills and agricultural activities.

Participants also discussed development of a more dynamic baseline capable of accounting for changes by season or time of day. CARB indicated it is receptive to additional industry feedback as it develops the baseline framework and works to minimize false-positive alerts.

Air dispersion modeling was another major focus. Industry representatives have raised concerns about requiring complex modeling at every regulated location and requested a standardized methodology that would provide consistency among facilities and air districts. CARB acknowledged that modeling was a recurring issue in stakeholder comments and said its technical team is evaluating potential alternatives, including simpler tools such as lookup tables that could help establish alert thresholds and sensor placement. Industry representatives offered to share their extensive modeling experience with CARB as that work continues.

The meeting also addressed third-party auditing requirements. An alternative approach was offered under which operators could annually certify that monitoring systems comply with their CARB-approved Leak Detection and Response Plan, supported by required performance testing, calibration and quality assurance and quality control records. CARB and CalGEM would retain authority to inspect records and facilities and require additional testing when appropriate.

The parties anticipate meeting again in approximately three weeks, with the next discussion expected to focus on site definitions, monitoring technologies, meteorological stations, and QA/QC requirements. Industry representatives will also continue working with CARB on potential air-modeling protocols.

The meeting represents another step in CIPA’s ongoing engagement on implementation of SB 1137. With formal rulemaking expected next year, CIPA will continue working closely with CARB, CalGEM, WSPA and member companies to provide technical expertise and advocate for regulations that are clear, practical, and workable for California operators.