The US Environmental Protection Agency may be considering modifications to its 2016 oil and gas industry emissions control techniques guidelines (CTG). But the California Air Resources Board (CARB) staff recommended on Sept. 21 that the state submit the oil and gas methane regulation it developed in 2017 to EPA as a revision to the State Implementation Plan (SIP). CARB is expected to decide whether to follow that recommendation when it meets on Oct. 25.
SIPs are part of the federal program for meeting National Ambient Air Quality Standards. California has been known to move more aggressively than some other states because of characteristics within its borders that are more conducive to smog formation.
EPA issued its 2016 CTG with recommendations to state air quality agencies on what constitutes Reasonably Available Control Technology (RACT) for select oil and gas emissions sources, CARB’s staff said in its report. The emissions sources were chosen because of their significant amounts of volatile organic compounds (VOC).
The state’s 2017 oil and gas greenhouse gas emission standards were designed to further the 2006 California Global Warming Solutions Act, the report said. Although methane is not considered a VOC, many of its controls also reduce VOCs because both are found in field gas from oil and gas operations, it indicated.
The report said that air quality districts with ozone nonattainment areas classified as moderate to worse must submit revisions to the SIP to include RACT. In the 2015 standard, there were 19 nonattainment areas within 22 air quality management districts (AQMD). Of the 13 AQMDs with nonattainment areas, only six—Feather River, Sacramento Metropolitan, San Jaoquin Valley, South Coast, Ventura County, and Yolo-Solano—have oil and gas operations subject to CTGs.
“The Oil and Gas Methane Regulation applies to all emission sources selected in the CTG, and, in combination with local air district rules when applicable, achieves equivalent emission reductions for each source category to the RACT level controls required in ozone nonattainment areas classified as moderate or worse,” the CARB staff’s report said. “Thus, [it] will satisfy the RACT SIP requirements for this source category in California.”
Unaffected by EPA
It said that it consulted with all the state’s air districts and agencies, which agreed to present the recommendation to CARB regardless of EPA’s possibly withdrawing the CTG.
Submitting the new methane regulation to EPA as an amendment to California’s SIP “will demonstrate that additional emission reductions from the source category are not only feasible, but will be achieved in our state,” CARB’s staff said.
The board submitted a similar SIP revision in June when it approved an amendment to the Cargo Tank Vapor Recovery rule.

Nick Snow
NICK SNOW covered oil and gas in Washington for more than 30 years. He worked in several capacities for The Oil Daily and was founding editor of Petroleum Finance Week before joining OGJ as its Washington correspondent in September 2005 and becoming its full-time Washington editor in October 2007. He retired from OGJ in January 2020.