From the comments
Overall, these proposals represent an important step forward in controlling methane emissions from oil and gas facilities. We especially appreciate CARB’s leadership in proposing standards simultaneously for both new and existing sources. Other essential components include robust programs for Leak Detection and Repair (LDAR) as well as inspections and replacements.
CARB should make some improvements to this proposal to ease public participation in the regulatory process, especially with respect to the LDAR program as described below.
In addition, CARB should maintain a consistent standard for inspection frequency. Under this proposal, failing to discover leaks can form the basis for less frequent inspections. This approach is flawed for two reasons. First, the absence of a leak reveals nothing about the probability of a future leak. Second, reducing inspections for failure to discover emissions may inadvertently encourage shoddy inspection work. Operators may find it easier not to find leaks rather than repair them. This approach also sets a poor regulatory precedent.
In general, Earthworks supports the implementation of LDAR requirements (95669) to the listed 95668 facilities.
Videos of California methane pollution
Chevron Cahn Plant, Lost Hills, CA (taken May 2015)
Murphy Oil Field (taken May 2015)
Inglewood Oil Field (taken October 2015)