Emissions often follow skewed distributions, which means that a small number of high-emitting sources or sites have a disproportionate contribution to total emission. These are called super-emitters. They are rare and therefore hard to detect if surveys do not happen frequently enough. Carrying out frequent leak detection and repair (LDAR) allows to prevent these large leaks from emitting a substantial amount of methane into the atmosphere.

Currently, emissions assessments are based on quantifications. As these quantifications are typically only estimates (often based on outdated or standardized emissions factors) and not all types of estimates are accurate, emissions tend to be highly underestimated in national inventories and industry reports. Using the term ‘quantification’ in the legislation means the EU will only have insight into estimated emissions rather than actual emissions and it will be impossible to track progress with integrity.

The main goal here is for the EU not to be less ambitious than international practice. We don’t necessary push for the EU timeline to follow precisely the OGMP 2.0 one, but it should have a similar level of ambition.

We are advocating for a performance standard that should apply to all gas consumed in the EU, both produced in the EU and imported. This is important as we would like to see emissions reduced across the supply chain. The standard could be an intensity level.

A clear target will enable authorities to properly enforce this provision and provide predictability for oil and gas companies.

This standard has been self-imposed by industry already. There is precedent for the potential level of a performance standard in the 2025 methane intensity standard of ‘well below 0.2%’ set by the Oil and Gas Climate Initiative (OGCI). Leading companies in this group, including many headquartered in Europe, have committed to lower methane intensity to 0.2% by 2025 and begun deploying mitigation efforts.

EDF research shows that this threshold would be unlikely to lead to significant average increases in gas prices. Hence, this target is both ambitious and achievable.

The Inflation Reductions Act, passed in the US in August 2022, sets a methane cap of 0.2% for producing facilities, 0.05% for non-producing facilities and 0.11% for gas transmission facilities. We believe an intensity of 0.2% is a suitable standard, while keeping it consistent across all sectors of the value chain clarifies the text.

Leaks are unpredictable. Conducting monthly checks conforms to the gold standard for leak detection and repair (LDAR) programs and would capture an additional 10% of methane emissions.

OGI cameras should be the basis for leak detection and repair on which the legislation builds, as technology is both available, approved and already widely used across the oil and gas industry. However, as other technologies become available and withstand scientific rigor, they should also be considered as alternative LDAR approaches. Such potential technologies could include a combination of mobile approaches and should achieve equal or greater emission reductions than quarterly/monthly leak detection methods.

Small leaks can very quickly become large leaks, and a large number of small leaks can add up to a significant amount of emissions. Any leak that is detected above a certain threshold – we advise the OGI detection limit of about 17g/h – should therefore be repaired.

To tackle both climate and energy security, prohibition of venting should be strengthened and only allowed in case of emergency, when flaring risks the safety of operations or personnel.

The high proportion of EU operators part of the OGMP provides evidence for the availability of solutions and for the possibility to produce granular and measurement-based estimates of the emissions occurring at their facilities. Such solutions need to be implemented by as many operators as possible to create reliable and accurate global estimates and tackle methane emissions more efficiently.