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Summary of the CIPA Comment Letter on Leak Detection RFI Introduction 



The California Independent Petroleum Association (CIPA) responded to the California Department of Conservation's Request for Information (RFI) on leak detection technologies for oil and gas operations. In their letter, CIPA expressed concerns that additional regulations by the California Geologic Energy Management Division (CalGEM) might be redundant given the existing regulatory framework.


CIPA highlighted that CalGEM's pursuit of new rules and regulations on emissions from production facilities seems unnecessary, as California already has extensive regulations. In 2017, the California Air Resources Board (CARB) adopted comprehensive regulations to control oil and gas methane emissions. These regulations focus on reducing fugitive and vented emissions from oil and gas production and storage facilities, covering the facilities' equipment and components. This regulatory framework includes a Leak Detection and Repair (LDAR) Program and mandates daily audio and visual inspections to ensure compliance.


Moreover, CARB has entered a public-private partnership to deploy satellites with groundbreaking hyperspectral technology. This innovative technology can precisely pinpoint and quantify large sources of methane and carbon dioxide (CO2) and detect other significant environmental indicators. The partnership plans to launch two satellites in 2024, enhancing the ability to quickly detect, quantify, and visualize high-emission sources of methane and CO2.


Instead of creating new regulations that might overlap or conflict with existing ones, CIPA recommends that CalGEM work on memorandums of agreement (MOA) with members of the Methane Task Force. These MOAs would help effectively coordinate and delineate the roles and responsibilities of various regulatory agencies regarding leak detection and monitoring. By doing so, CalGEM would utilize science-based standards already designed to protect public health and safety, as implemented by CARB and local air districts, California's leading agencies for all air pollution control efforts.


For more information, contact Sean Wallentine.

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