April 24, 2022
One of the first issues I have with this is the short, medium, and long term. In terms of the long term, every company knows the issues that affect the environment. In terms of the short term, it almost sounds like you are asking companies to disclose the minor issues that the company has slapped a bandaid on to resolve an issue. As time passes, at what point does the long term become medium-term. If a company says by 2030, we will have no location venting to the atmosphere anymore, so we are no longer affecting the environment. As an investor, now things look more promising to jump on board. If someone is unfamiliar with what proper venting is, it may open up a can of more issues to look into. Most people look at venting as the release of gas. Venting is a controlled release of unburned gases, such as natural gas or other hydrocarbon vapours, water vapour, or other gases. Venting may occur during several processes, including well completion and well maintenance. Odors may be associated with venting. Then the critical meaning is during well maintenance .So what does that mean ? If I go and change an orifice plate, I have to bypass the meter run, block in the meter run and blow down the meter run to the atmosphere. Well maintenance because I am essentially venting gas. No, that is at a small scale, but then someone realizes that 1000s of companies do the same process, which could probably add up to venting through a flare line for an hr. As an investor, they would never get that information because right now, no company keeps track of how much well maintenance is exposing methane to the atmosphere. So, now there is a hole in actual data vs. projected data. While the long term offers a long-term solution, it does not offer unintended misinformation. I do like the fact that the rule gives investors more information. I would like to see more clarification from a field perspective, not an administration perspective.