General Commentary:
Based on a review of the report and our internal data analyses, we find that just like the one released in 2023 (see 2023 response here), this report is built on a similarly loose approach and contains numerous inaccuracies and mischaracterizations.
The report asserts that continuous monitors miss emission events and that individual monitors are frequently offline, aiming to undermine voluntary assessment programs and technologies that monitor Total Volatile Organic Compounds (TVOC) to comply with regulatory requirements in Colorado. However, in doing so, the report ignores numerous facts.
This response corrects the facts with respect to three key areas highlighted in the report: site certifications, Canary S unit uptime, and emissions event detections.
Site Certifications
No sites referenced in the report were ever certified by Project Canary.
Canary S Unit Uptime
Continuous emissions monitoring is a critical component of understanding and minimizing air quality impacts on surrounding communities.
- Intended Use: Canary S units are deployed to meet Regulation Number 7 (Reg 7) emissions monitoring requirements (see: Colorado Reg 7 requirements). These units do not monitor for methane or other greenhouse gases.
- Device Design: Our Canary S monitors are designed and approved to detect elevations in total volatile organic compounds and particulate matter, as Reg 7 requires. However, like other technologies, individual units can go down for various reasons, including interruption to cellular service, maintenance, unit malfunctions, sensor contamination/water intrusion, and other factors.
- Site Coverage: All sites included in the report monitored by Project Canary contain at least three or four Canary S units. Sites have multiple units to provide redundancy and ensure proper site coverage.
- Data Reporting: Notwithstanding the report’s assertions, TVOC sensor uptime for the referenced pads was nearly 80%, which is consistent with general regulatory expectations.
Emissions Event Detections
The report cites several detected emissions that were allegedly missed by Canary S devices and were not reported. It is important to note that there are permitted releases at oil and gas facilities that do not require reporting to the air regulator. These permitted releases differ from persistent leaks, which CEM devices are intended to capture and, in some cases, are required for reporting. The report fails to differentiate between these types of events and assumes that all events should be reported.
- Monitoring: As further evidence of the report’s loose nature, in one instance it claims that Canary S monitors missed an emission when the monitors in question were actually removed a month prior. (This location was excluded from our analysis below).
- Detections: Excluding the instances where sensors required maintenance, the Canary S devices detected 7 out of the 8 events.
Conclusion
Oil Change International and Earthworks have again produced a report critical of certified gas that exclusively discusses wells that were never certified.
The Canary S units, in fact, worked as designed to detect emissions in the vast majority of cases identified in the report.
Project Canary is disappointed that these groups continue to skew facts in an attempt to undermine both our technology and the many clients we work with who are seeking to better understand their operations, comply with regulations, reduce environmental impacts, and increase transparency.