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From the comments:

We wish to also incorporate by reference, Earthworks comments on this proposed regulation from July 21, 2016.2 Overall, Earthworks supports this rule because it helps raise the standard for oil and gas emissions regulation around the country. We also commend CARB for eliminating the proposed “step-down” provision, which can reduce inspection frequency as facilities age.

These comments will focus primarily upon CARB’s Leak Detection and Repair (LDAR) provisions.4 In particular, we wish to use this opportunity to describe the programmatic value third party verifiers can add to California’s LDAR program. If conducted well, a robust third party verification system can ease the regulatory burden on CARB and local Air Resources Boards (ARB), save the industry time and money by preserving the resource they wish to sell to market, and protect communities and the climate.