…Our concerns are highlighted in our recently published report Certified Disaster, which is targeted at the gas certification concept broadly but includes fieldwork data assessing the efficacy of fenceline air quality monitoring conducted by operators during pre-production activities at upstream oil and gas sites per a program adopted by the AQCC in 2020. This program does not prescribe certain technologies or standards and instead allows operators a high degree of flexibility to design and implement monitoring plans that achieve the program objectives. The result, as indicated by our report findings, is monitoring that in many cases is failing to detect emissions from many of the primary sources of emissions during pre-production.
Much like the rationale described by the MSC in preferring a performance-based approach, the rationale in allowing operators flexibility for fenceline monitoring during pre-production was to encourage innovation and iteration, and to help expedite implementation of the program. This is all reasonable, but in practice it means that the data actually produced by the monitoring is unreliable at best. We would prefer a similar fate not befall the midstream emissions reductions program and the APCD, should it proceed with a performance-based approach as the MSC recommends, must consider how to guarantee proper oversight over program implementation.
