Comment Log Display

•	The burden of maintaining on-call status with a third-party
contractor or internal staff who may conduct a method 21 survey in
the given timeframe triggered by a notification under this rule is
immense. We believe the financial and logistic burden of this
section may adversely affect compliance rates of operators.  
•	We are deeply concerned that this section poses a threat of abuse
by third parties. The proposed text does very little to outline the
QA/QC process of data validation or procedure used to correlate an
emission event to a facility. A third party intent on causing an
outsized administrative burden on operators could selectively
report emissions events to target given operators.
•	The nature of narrow lease spacing in the oil fields of
California are likely to result in mis-identified facilities, or
worse, CARB notifying multiple adjacent operators of the same
emission event. There is no language to prevent a scatter-shot of
reports to lock down entire fields
•	The proposed text does not set a leak rate threshold for
reporting, thus allowing for any and all remotely detected
emissions events to be reported to an operator. Further, if there
is no threshold for reporting, operators may be mobilizing survey
teams for marginal emissions events from protracted distances to
respond leaks of lesser impact than the scope 2 emissions created
by vehicle mobilization.