Best Practices on Oil and Gas Methane Emissions Regulations

A FACTSHEET FOR POLICY-MAKERS

Addressing methane is one of the most cost- than 80 times the climate warming impact of effective ways to reduce greenhouse gas pollution carbon dioxide over a 20-year timespan. Methane is “Canada’s three from the oil and gas sector. The Government of responsible for approximately 25% of the warming Canada reaffirmed its commitment to reduce we feel today1. These facts make near-term methane major oil and gas methane emissions from the oil and gas sector reductions a necessary element of international provinces — Alberta, by 40-45% below 2012 levels by 2025 as part of efforts to battle climate change. Saskatchewan and the Pan-Canadian Framework. In April 2018, the Methane is also the primary constituent of natural B.C. — have all Canadian federal government published robust gas ⁠— a valuable product. Actions that eliminate or and comprehensive regulations intended to reduce methane losses to the atmosphere therefore written their own achieve their commitment. are highly cost-effective as fewer methane emissions rules. The federal The provinces can introduce their own translate to more product in the pipeline. The government must regulations if they achieve equivalent emissions International Energy Agency says globally the oil and now stand its ground reductions as the federal onces. Canada’s gas industry can cost-effectively reduce up to 75% three major oil and gas provinces ⁠— Alberta, of its methane emissions and 50% of global methane and ensure the Saskatchewan and B.C. — have all written their reductions can be realized at zero net cost. This level provincial rules are own rules. The federal government must now of reduction delivers the same long-term climate as effective as the stand its ground and ensure the provincial rules benefit as immediately closing all the coal plants in federal ones.” are as effective as the federal ones. China2. That’s a huge win for both the climate and the economy. Why Methane? Reducing methane emissions can also have Methane is a potent greenhouse gas with more significant air quality benefits. Actions that

1Data is from IPCC AR5 WGI 2013 Chapter 8 SM, Table 8.SM.6’ 2 https://www.iea.org/newsroom/news/2017/october/commentary-the-environmental-case-for-natural-gas.html release methane emissions, such as unintentional leaking and Given the significant opportunity to reduce greenhouse intentional venting and flaring also emit harmful air toxics and gases and achieve the committed 45% methane reduction, the smog-forming volatile organic compounds (VOCs). Therefore, federal government should not grant equivalence to any of the actions to reduce methane emissions also lead to improved provincial methane regulations in Alberta, BC or Saskatchewan public health protections as a co-benefit. Reduced flaring can unless they achieve methane emission reductions at least also reduce black carbon emissions to achieve simultaneous air equivalent to the federal regulations. quality and climate mitigation objectives. Mapping Methane Action Why Canada? National and subnational jurisdictions across the U.S. and Under the Pan-Canadian Framework, Canada has Canada have issued regulations or commited to do so to meet oil implemented a plan to reduce greenhouse gas emissions in line and gas methane reduction goals, as shown in the map below. with their Paris Agreement commitments. Part of this plan is to In August 2019, the EPA introduced proposed changes to reduce methane emissions by 40-45%, a commitment that was the US federal methane rules which are not yet reflected below. made alongside the U.S. and Mexico. The federal government The proposal must undergo consultation before a final action took a strong first step in April 2018 by finalizing regulations is issued. Industry players, environmental groups and states on methane. If implemented across Canada, these regulations will argue against rolling back federal methane rules, with a can reduce greenhouse gas emissions in Canada by 15 Mt CO2e challenge likely in federal court. Regardless, state regulations each year starting in 2023. Moreover, since methane is the major will remain in place and active campaigns are underway in component of natural gas, abating these emissions is also key for additional states so the EPA proposal does not reflect a wholesale avoiding the waste of a precious resource. shift away from oil and gas methane reductions in the U.S.

U.S. National Methane Standards Canada’s National Methane Standards (U.S. EPA) (Environment and Climate Change Canada)

States with additional Provinces that have proposed alternative standards or permits standards How Do the Federal and Provincial In these five key areas, we compare the methane regulations Regulations Measure Up? from the federal government and provinces of Alberta, Increasingly, countries, provinces and states are Saskatchewan and B.C. with best practices. implementing regulations to reduce methane emissions. The strength of regulations varies from one jurisdiction to the next. How does the Federal Regulation Measure Up? Some regulate methane directly, while others address VOCs, The federal regulations include broad coverage and tackle which reduces methane as a co-benefit. Key aspects that should all major sources of emissions effective across the oil and be addressed by effective regulations include: natural gas supply chain from new and existing sources. Federal 1. Achieving ambitious methane emission reductions across regulations will result in reduced leaks and venting due to multiple segments of the oil and gas sector and from all comprehensive, frequent leak inspections coupled with robust significant emission sources, new and existing; venting limits for compressors, pneumatic devices, pumps 2. Reducing designed and intentional equipment venting and storage tanks. Federal regulations allow operators to use from pneumatics and compressors; emerging leak detection methods to conduct leak inspections, 3. Reducing venting and flaring from storage tanks and oil thereby encouraging innovation that could enhance the well-heads; effectiveness and reduce the cost of inspections. 4. Requiring leak detection and repair (LDAR); and 5. Establishing reliable record-keeping, reporting and measurement procedures.

Comparative Analysis

Follows best practices Needs minor improvements Needs major improvements

Key Aspects Best Practices Federal Alberta British Columbia Saskatchewan

1. Achieve ambitious 1.1 Mandatory, performance-based standards methane emission reductions across 1.2 Effectively targets largest emissions sources multiple segments of the oil and gas sector 1.3 Limited, and clearly circumscribed, exceptions and from all significant emission sources, new and existing. 2. Reduce designed 2.1 Engineer and design new pneumatic devices and pumps to and intentional be zero or near zero emitting (e.g. use electricity or instrument equipment venting from air in lieu of natural gas as power source) pneumatics and 2.2 Retrofit existing pneumatic devices and pumps to be zero or compressors. near zero emitting (e.g. replace high-bleed pneumatic devices with low or zero-bleeds) 2.3 Reduce intentional venting from compressors 3. Reduce flaring 3.1 Reduce venting of gas from tanks and gas venting from 3.2 Reduce venting of gas from oil well-heads storage tanks and oil well-heads. 3.3. Limit flaring of gas; only allow where capture isn’t feasible 3.4 Require use of high efficiency flares and combustors

4. Regular leak 4.1 Quarterly/triannual inspections of well sites, gas processing detection and repair plants, compressor stations, tank batteries (LDAR). 4.2 Comprehensive inspections that apply to all sources with the potential to leak, unintentionally vent or abnormally operate 4.3 Include robust alternative compliance pathway that allows for the use of emerging technologies that are as effective in reducing emissions as allowable instruments and is subject to public input and regulatory review 5. Record-keeping, 5.1 Include robust, detailed, site-specific record-keeping reporting and provisions, demonstrating compliance with each of the measurement. mandatory methane reduction measures 5.2 Require annual public reporting demonstrating compliance 5.3 Reliable measurement requirements

1 Includes solution and associated gas Comparing Alberta and Federal Oil and Gas Methane Emissions Regulations A FACT SHEET FOR POLICY-MAKERS

This fact sheet presents the results of a comprehensive review comparing Alberta’s methane Alberta is also relying on achieving reductions regulations to those of the federal government. through its carbon pricing system. However this Alberta’s methane regulations were finalized in late system is not designed for methane and does “Alberta’s rules will 2018 in Directive 060 and Directive 017 by the Alberta not have the strong measurement and reporting fail to meet the Energy Regulator. Analysis from the Clean Air Task requirements for methane emissions which are province’s 45% oil Force shows that Alberta’s rules will fail to meet the necessary to succeed. province’s 45% oil and gas methane reduction target1. Using five key areas of methane oil and gas and gas methane Alberta’s rules also fall short of the federal standard, regulation best practices, we compared Alberta’s reduction target.” achieving only a 32% reduction from 2012 baseline rules to best practices. This comparison identifies emissions compared to the federal rules which improvement opportunities that could be achieve a 43% reduction. Alberta’s rules are weaker implemented to align with such practices in order than the federal rules in several key areas: for Alberta to achieve the same or better emissions 1. inadequate leak detection and repair (LDAR) reductions as the federal regulation. requirements and venting limits that are higher than the federal limits; 2. no controls on existing pneumatic pumps; 3. inaccurate and outdated measurement 1 CATF, 2018. A Comparative Assessment of Alberta’s Oil and reporting requirements, especially for and Gas Methane Emissions Under the ECCC rules and AER’S Draft Directive 060. Available online at: https:// solution gas venting, which has shown to be www.catf.us/resource/albertas-oil-gas-methane-emis- significantly underestimated. sions-eccc-aers/ Consulted March 22nd, 2019.

3.2 Reduce venting of gas from oil Federal regulation sets an annual Regulation sets a fleet average Needs major Set a venting limit for wellheads. venting limit for facility that is venting limit for crude bitumen, improvement crude bitumen batteries ambitious and aims to reduce which is the major source of that aligns with best venting of gas from major sources solution gas venting, but it is not practices such as in the including solution gas venting. ambitious in comparison with the federal rule. Fleet best practices. averaging can provide 3. Reduce operator with flexibility, venting and but the limit must then be flaring from lower as a result. storage tanks and oil well- 3.3. Limit flaring of gas; only Federal regulation doesn’t estab- Flaring is allowed. Section 1.3 Needs minor Establish an explicit heads. allow where capture is lish a requirement limiting flaring includes a consideration to eliminate improvement requirement to limit infeasible. of gas. or reduce flaring when possible. flaring of gas; only Section 5.2. establishes a limit for allow where capture is disposed gas at gas infeasible. processing plants. If an annual provincial limit is exceeded (Section 2.1) a stricter limit can apply. 3.4. Require use of high Federal regulation doesn't Section 7 establishes Needs major Require a 98% efficiency flares and establish a requirement to use performance requirements for improvement destruction removal combusters. high efficiency flares but advises flaring, but it doesn’t establish a efficiency for flares and following provincial rules (Section minimum for flare efficiency. combustion. 9). Such rules don't require the use of high efficiency flares. 4.1. Quarterly inspections of well Federal regulation requires Regulation requires 3 times/ Needs major Increasing the inspection sites, gas processing plants, inspections three times per year year inspections at some gas improvement frequency at all facilities compressor stations, tank batteries. for all but single well heads plants, compressor stations and except for single well- (Sections 30 (3); 52). controlled tanks once per year at head sites to three times other sites, and no inspections per year. at wells. 4.2. Comprehensive inspections Federal regulation requires LDAR Regulation requires LDAR Follows best 4. Regular that apply to all sources with the inspections on all sources inspections on all sources practices leak detection potential to leak, unintentionally vent including thief hatches and including thief hatches and and repair or abnormally operate. pneumatic devices. pneumatic devices. (LDAR). 4.3. Include robust alternative Federal regulation establishes Regulation includes an Follows best compliance pathway that allows for robust alternative compliance Alternative Fugitive Emissions practices the use of emerging technologies pathway (Sections; 29; 35; 50). Management (Section 8.10.6). that are as effective in reducing emissions as allowable instruments and subject to public input and regulatory review. 5.1 Include robust, detailed, Federal regulation requires Regulation requires site level Needs minor Require records from site-specific record keeping provi- comprehensive site level record records and calculations by improvement venting by detailed sions, demonstrating compliance keeping by source type source type but doesn’t require source category. with each of the mandatory methane (Sections 6; 7; 10; 12; 19; 25; 27; records from individual venting reduction measures. 36; 38; 45; 48; 51; 53; 56). sources. 5. Record 5.2. Require annual public reporting Federal regulation doesn't require Regulation requires reporting Needs major Include comprehensive keeping, demonstrating compliance. annual public reporting demon- for venting and fugitives, but no improvement reporting and a reporting and strating compliance. comprehensive report and no requirement to make measurement. commitment to making reports reports public. public. 5.3. Reliable measurement Federal regulation establishes Regulations set measurement Needs major Improve protocols for requirements. reliable measurement require- requirements but have not improvement measurement of solution ments (Section 15, 16 and 17). addressed known flaws in esti- gas venting. mation of solution gas venting. Comparing British Columbia and Federal Oil and Gas Methane Emissions Regulations A FACT SHEET FOR POLICY-MAKERS

“BC regulations have strong elements, This fact sheet presents the results of a and leak detection and repair. Comprehensive leak comprehensive review comparing British Columbia’s detection should be required in the regulations, representing best methane emissions rules to the federal regulations. not guidance documents which don’t have strong practices and in some BC finalized their methane regulations in early 2019. enforcement requirements. Storage tank venting cases exceeding the BC regulations have strong elements, representing limits are also much higher than the federal rule. federal rules.” best practices and in some cases exceeding the Using five key areas of methane oil and gas federal rules. In particular, BC rules require new regulation best practices, we compared BC rules pneumatic devices and some existing ones to be to best practices. This comparison identifies zero emitting. BC also include a three times per year improvement opportunities that could be inspection requirement for gas processing plants, implemented to align with such practices in order to compressor stations, and some batteries. However, achieve the same or better emissions reductions as there is room for improvement on tank venting limits the federal regulation.

Key Aspects Best Practices Federal Regulation Provincial Regulation How it Improvement Compares Opportunity 1.1. Mandatory, performance- Federal regulation establishes Regulation establishes mandatory Meets best based standards. mandatory performance-based performance-based standards practices 1. Achieves standards. (Sections 44 and 52). ambitious methane emission reductions across multiple segments of 1.2. Effectively targets largest Federal regulation effectively Regulation targets largest Needs minor Set lower tank venting limits the oil and gas emissions sources. targets largest emission sources. emission sources but venting improvement and require frequent LDAR at sector and limits, LDAR survey requirements conventional facilities. from all need improvement. significant emission 1.3. Limited, and clearly Federal regulation establishes Regulation establishes limited and Meets best sources, new circumscribed, exceptions. limited and clearly clearly circumscribed exceptions. practices and existing. circumscribed exceptions maintaining strict limits for the largest emissions sources. 2.1. Engineer and design new Federal regulation sets venting Regulation requires new Meets best pneumatic devices and pumps limits for new devices. (Section pneumatic devices and pumps to practices to be zero or near zero 37.1) No emissions are allowed be zero emitting (Sections 52.05, emitting. (e.g. use electricity or from new pneumatic pumps 52.06, 52.07). instrument air in lieu of (Section 39.1) with exceptions natural gas as power source) for infrequently used pumps. 2. Reduce 2.2. Retrofit existing Federal regulation sets a Regulation requires some Needs minor Require existing pumps to be designed and pneumatic devices and pumps venting limit for existing existing pneumatic devices to be improvement low or non-emitting. intentional to be zero or near zero pneumatic devices (Section non-emitting, and sets a venting equipment emitting (e.g. replace high- 37.1) and requires no limit on others. No rules for venting from bleed pneumatic devices with emissions from existing existing pneumatic pumps. pneumatics low or zero-bleeds). pneumatic pumps with and exceptions for infrequently used compressors. pumps (Section 39.1). 2.3. Reduce intentional venting Federal regulation establishes Regulation sets limits on venting Meets best from compressors. a venting limit for compressors from compressors (Section practices that is ambitious and aims to 52.04). reduce intentional venting. (Section 18 and Section 50) 3.1. Reduces venting of gas Federal regulation establishes Regulation establishes a venting Needs minor Reduce venting limit for tanks from tanks. an annual venting limit for limit for tanks but it is not improvement to align with best practices facility that is ambitious and ambitious in comparison with best such as in the federal rule. aims to reduce venting of gas practices. from major sources including tanks. 3.2 Reduce venting of gas Federal regulation sets an Regulation doesn’t establish Needs minor While establishing a limit is from oil wellheads annual venting limit for facility venting limits aiming to reduce improvement best practice, based on 3. Reduce (Includes solution and that is ambitious and aims to emissions from well-heads. current inventory, well- venting and associated gas). reduce venting of gas from headsnot a significant source flaring from major sources including of emissions in BC due to low storage tanks solution gas venting. oil production. and oil wellheads. 3.3. Limit flaring of gas; only Federal regulation doesn’t BC flaring and venting reduction Meets best allow where capture is establish a requirement limiting guidelines only allow flaring when practices infeasible. flaring of gas. capture is not economic. 3.4. Require use of high Federal regulation doesn't Regulation includes flare Needs major Require a 98% destruction efficiency flares and establish a requirement to use performance requirements but improvement efficiency for flares and combusters. high efficiency flares but advises doesn't establish a minimum flare combustors. following provincial rules efficiency. (Section 9) which don't require the use of high efficiency flares. 4.1. Quarterly inspections of Federal regulation requires Regulation requires 3 times/year Needs minor Include inspection well sites, gas processing inspections three times per year surveys at gas plants, compressor improvement requirements for co-located plants, compressor stations, for all but single well heads stations, multilwell batteries and facilities in regulation, not just tank batteries. (Sections 30 (3); 52). single well batteries with controlled guidance materials. tanks. Most single well batteries and tight gas wells only require 1 time/year LDAR, while conventional wells only require screening. 4.2. Comprehensive Federal regulation requires Regulation requires LDAR for all Meets best 4. Regular leak inspections that apply to all LDAR inspections on all sources sources with potential to leak practices detection and sources with the potential to including thief hatches and including pneumatics. repair (LDAR). leak, unintentionally vent or pneumatic devices. abnormally operate. 4.3. Include robust alternative Federal regulation establishes Regulation does not include Needs major Include alternate compliance compliance pathway that robust alternative compliance robust alternative compliance improvement pathways in the regulations. allows for the use of emerging pathway (Sections ; 29; 35; 50). pathway. technologies that are as effective in reducing emissions as allowable instruments and that is subject to public input and regulatory review. 5.1 Include robust, detailed, Federal regulation requires Regulation and guidance Meets best site-specific record keeping comprehensive site level record materials establish practices provisions, demonstrating keeping by source type comprehensive requirements for compliance with each of the (Sections 6; 7; 10; 12; 19; 25; record keeping. mandatory methane reduction 27; 36; 38; 45; 48; 51; 53; 56). measures. 5. Record keeping, 5.2. Require annual public Federal regulation doesn't Regulation doesn't commit to a Needs major Include a commitment to reporting and reporting demonstrating require annual public reporting comprehensive annual report or improvement comprehensive and public measurement compliance. demonstrating compliance. public reporting. annual reporting.

5.3. Reliable measurement Federal regulation establishes Comprehensive measurement Needs minor Publish comprehensive requirements. reliable measurement requirements for fugitive sources. improvement measurement requirements requirements. Venting measurement requirements for venting. (Section 15, 16 and 17). not yet released. Comparing Saskatchewan and Federal Oil and Gas Methane Emissions Regulations A FACT SHEET FOR POLICY-MAKERS

“Saskatchewan has This fact sheet presents the results of a operators flexibility in finding the most cost- chosen an outcome- comprehensive review comparing Saskatchewan effective reductions. For this approach to succeed, based regulatory rules to federal regulations. Saskatchewan finalized the province needs to implement accurate and their methane regulations in late 2018. detailed measurement and reporting along with approach that doesn’t Saskatchewan has chosen an outcome-based strong enforcement. follow best practices regulatory approach that doesn’t follow best Using five key areas of methane oil and for managing practices for managing methane emissions. gas regulation best practices, we compared It ignores sources accounting for 40% of the Saskatchewan’s rules to best practices. This methane emissions.” province’s methane emissions including comparison identifies improvement opportunities pneumatics, compressors, and leaks. However, that could be implemented to align with such they have targeted their largest source of practices in order to meet the level of ambition set emissions – venting and flaring from oil facilities. out by the federal regulation. Saskatchewan’s outcome-based approach gives

Key Aspects Best Practices Federal Regulation Provincial Regulation How it Improvement Compares Opportunity 1.1. Mandatory, performance- Federal regulation establishes Outcome based regulation sets Needs major Strong measurement and based standards. mandatory performance-based gas conservation limit by for oil improvement reporting standards are standards. facilities by region but doesn’t required for outcome- 1. Achieves update outdated measurement based regulations to ambitious and reporting systems. succeed. Known flaws in methane measurement of emission solution gas venting have reductions not been addressed. across multiple 1.2. Effectively targets largest Federal regulation Regulations target venting from oil Needs minor Include rules on segments of the emissions sources. effectively targets largest production, which is improvement pneumatics for new oil and gas sector emission sources. Saskatchewan’s largest source of facilities. and from all methane emissions. significant emission sources, 1.3. Limited, and clearly Federal regulation establishes SK regulation includes exceptions Needs major These exceptions will new and existing. circumscribed, exceptions. limited and clearly allowing the government to set improvement have a large impact on circumscribed exceptions emission factors, waive payments, the effectiveness of the maintaining strict limits for the and allow business associates to regulation that are difficult largest emissions sources. merge. to quantify. 2.1. Engineer and design Federal regulation sets venting Regulation doesn’t set rules Needs major Require new pneumatic new pneumatic devices and limits for new devices. (Section for new pneumatic devices or improvement pumps and devices to be pumps to be zero or near zero 37.1) No emissions are allowed pumps. non-emitting or controlled. emitting (e.g. use electricity or from new pneumatic pumps instrument air in lieu of natural (Section 39.1) with exceptions gas as power source). for infrequently used pumps. 2. Reduce 2.2. Retrofit existing Federal regulation sets a Regulation doesn’t set rules for Needs major Set venting limits for designed and pneumatic devices and pumps venting limit for existing existing pneumatic devices or improvement existing pneumatic intentional to be zero or near zero pneumatic devices (Section pumps. devices and pumps. equipment emitting (e.g. replace high- 37.1) and requires no emissions venting from bleed pneumatic devices with from existing pneumatic pumps pneumatics and low or zero-bleeds). with exceptions for infrequently compressors. used pumps (Section 39.1). 2.3. Reduce intentional venting Federal regulation establishes Regulation doesn’t set rules for Needs major Set venting limits for new from compressors. a venting limit for compressors venting from compressors. improvement and existing compressors. that is ambitious and aims to reduce intentional venting (Section 18 and Section 50). 3.1. Reduces venting of gas Federal regulation establishes from tanks. an annual venting limit for facility that is ambitious and aims to reduce venting of gas A site venting limit is more from major sources including Regulation sets a limit on the efficient than a tanks. percentage of vented gas that Needs minor conservation requirement must be conserved or destroyed improvement 3.2 Reduce venting of gas Federal regulation sets an annu- because it doesn’t target by region. from oil wellheads1. al venting limit for facility that is the smallest emitters. ambitious and aims to reduce venting of gas from 3. Reduce major sources including venting and solution gas venting. flaring from storage tanks and oil 3.3. Limit flaring of gas; only Federal regulation doesn’t Regulation promotes Follows best wellheads. allow where capture is establish a requirement limiting conservation of gas and doesn't practices infeasible. flaring of gas consider flaring as an acceptable alternative (Directive S-10. Section 3 and 4). 3.4. Require use of high Federal regulation doesn't Regulation makes mandatory Needs major Require a 98% destruction efficiency flares and establish a requirement to use that all allowed flaring should be improvement and reduction efficiency of combusters. high efficiency flares but points conducted with efficient flares flare and combustion. out to follow provincial rules encouraging the use of (Section 9) which don't require incinerators with a conversion the use of high efficiency flares. efficiency of more than 99% (Directive S-20. Section 3.3). 4.1. Quarterly inspections of Federal regulation requires The regulation doesn’t have any Needs major Require comprehensive well sites, gas processing inspections three times per year leak detection and repair improvement leak surveys at all plants, compressor stations, for all but single well heads requirements. facilities three times per tank batteries. (Sections 30 (3); 52). year. 4.2. Comprehensive Federal regulation requires The regulation doesn’t have any Needs major Require comprehensive inspections that apply to all LDAR inspections on all sources leak detection and repair improvement inspections that apply to sources with the potential to including thief hatches and requirements. all sources. 4. Regular leak leak, unintentionally vent or pneumatic devices. detection and abnormally operate. repair (LDAR). 4.3. Include robust alternative Federal regulation establishes The regulation doesn’t have any Needs major Include alternate compliance pathway that robust alternative compliance leak detection and repair improvement compliance pathways. allows for the use of emerging pathway (Sections ; 29; 35; 50). requirements. technologies that are as effective in reducing emissions as allowable instruments and that is subject to public input and regulatory review. 5.1 Include robust, detailed, Federal regulation requires Regulation does not require Needs major Require detailed record site-specific record keeping comprehensive site level record any record keeping on methane improvement keeping for all sources of provisions, demonstrating keeping by source type emissions from venting or other methane emissions. compliance with each of the (Sections 6; 7; 10; 12; 19; 25; sources. mandatory methane reduction 27; 36; 38; 45; 48; 51; 53; 56). measures. 5. Record keeping, 5.2. Require annual public Federal regulation doesn't Regulation requires no public Needs major Include comprehensive reporting and reporting demonstrating require annual public reporting reporting of methane emissions. improvement reporting and a measurement compliance. demonstrating compliance. requirement to make reports public. 5.3. Reliable measurement Federal regulation establishes Regulations set measurement Needs major Improve requirements for requirements. reliable measurement requirements but have not improvement measurement of solution requirements (Section 15, 16 addressed known flaws in gas venting. and 17). estimation of solution gas venting.