What New Rules for the Direct Measurement of Methane Emissions Mean for Colorado Operators
Author: Dave Levy
Updates to Colorado Regulation 7 require the direct measurement of methane to provide a more accurate accounting of methane emissions.
The new rule allows operators to develop an operator-specific program for creating an emissions inventory.
Continuous monitoring systems can cost-effectively meet these newly passed monitoring and reporting requirements under Colorado Regulation 7.
Background
The Colorado Air Quality Control Commission recently adopted a rule that will require direct measurement of oil and gas methane emissions to verify regulatory compliance with Regulation 7. The rule builds on the State’s 2021 intensity standard that required oil and gas operators to accurately account for their greenhouse gas (GHG) emissions.
Currently, oil and gas operators report emissions based on calculations, not actual measurements. This new rule requires the direct measurement of methane to provide a more accurate accounting of methane emissions.
The GHG intensity program applies to upstream oil and gas operations. The new regulatory program includes two main parts: the new verification rule and greenhouse gas intensity standards.
The new verification rule will ensure facilities adhere to the GHG intensity standards adopted in 2021, which calls for the oil and gas industry to achieve a 36% reduction in emissions by 2025 and a 60% reduction by 2030. In effect, the new rule ties the amount of oil and gas that companies can produce to how well they measure and reduce methane emissions from their operations.
New protocols for verifying emissions are central to the new rule. The Air Pollution Control Division (“the Division”) proposed GHG Intensity Verification Plan allows for operator flexibility and the ability to incorporate new technologies as they emerge. In the Division’s proposal, operators will have the flexibility to choose one of two options for attaining a measurement-informed inventory: (1) a state-derived default intensity verification factor; or (2) utilize an operator-specific program.
High Standards for Operator-Specific Measurement Programs
Starting in 2027, intensity operators may use a Division-approved operator-specific measurement strategy. Operator-specific programs have two main requirements for developing a measurement-informed inventory: (1) a measurement strategy that includes the direct measurement of methane emissions; and (2) a third-party audit. The Division’s proposed Verification Plan lays out requirements for both elements.
There are several notable requirements for operator-specific programs. The required measurement strategy must define how direct measurement and parametric measurement informs the reporting of emissions, considering: (1) the appropriateness of the selected measurement technology or methodology, including the minimum detection limit; (2) the representativeness of the monitoring sites; (3) the variability of emissions over time; and (4) other reasonable and necessary monitoring considerations as determined by the Division.
The measurement strategy used in an operator-specific program must also include direct measurements at the site level, and the direct measurement technology used must be fit for purpose, capture a significant portion of the expected emission, and be validated with appropriate testing.
The direct measurement strategy must include an operations and maintenance plan, and the direct measurement strategy must be reviewed annually.
How Qube’s Continuous Monitoring Platform Can Satisfy Requirements for Operator-Specific Measurement Programs
The Division requires monitoring solutions to take readings and report data every fifteen minutes, capture relevant weather data such as wind speed and direction, report any responsive actions within 48 hours to the Commission and local governments, and store data for three years, among other mandated and preferred system performance criteria.
Qube’s continuous monitoring (CM) system can cost-effectively meet current and newly passed monitoring and reporting requirements under Colorado Regulation 7.
Qube’s IIoT detection devices are calibrated to <1ppm resolution, which far exceeds Regulation 7 detection limit standards. Qube’s devices provide time-synchronized emissions and environmental data every fifteen minutes in the cloud, where it is analyzed to infer emissions location, flow rate rate, and classification.
This data is visualized through our dashboard in real-time, which enables operators to find and fix leaks quickly and significantly reduce emissions. Qube’s analytics platform also has the ability to roll up emissions by equipment or site to see emissions trends over time - a key reporting requirement of the new rule.
The new Colorado rules will strengthen over time, which will come at an expense to operators. However, Qube has developed a proprietary ML-based analytics approach that enables operators to monitor a larger area while maintaining the highest detection performance standards and keeping monitoring costs low.
Conclusion
The Colorado Air Pollution Control Division aims to finalize verification protocols for the new rule with stakeholders by the end of 2023. Although the verification protocols are still being determined, and the type of monitoring technologies permitted are still being negotiated by stakeholders, it is clear that operators will be required to have some form of ground monitoring system in place. Qube offers a cost-effective continuous monitoring solution that can help Colorado operators meet current and future methane emissions monitoring, verification, and reduction standards.