With the first ever AMEL application under Quad Oa announced by ExxonMobil, there have been a lot of questions surrounding what it means for the industry, so we’re answering the most frequently asked questions we've been receiving.
If you don't see your question answered here, feel free to reach out to the Bridger Photonics team.
An AMEL is an Alternate Means of Emission Limitation and is defined in the Clean Air Act (section 111(h)(3)). This provision allows an entity to petition the EPA to allow an alternative compliance approach to a federal air standard provided that the proposed alternative achieves equivalent or greater emissions reduction relative to the existing standard.
EPA specifically identified these provisions as the vehicle to include emergent gas detection technologies into oil and gas leak detection and repair programs in its New Source Performance Standard for Crude Oil and Natural Gas Facilities (40 CFR, Part 60, Subpart OOOOa, “Quad Oa”).
The first AMEL requesting approval to satisfy the requirements for Leak Detection and Repair under NSPS OOOOa using new technology was submitted in March 2021 by XTO Energy, a subsidiary of ExxonMobil. ExxonMobil made the announcement in April 2021. This is a particularly exciting breakthrough since industry has spent years trying to figure out how to demonstrate equivalency with new technology for an AMEL in order to fix emissions sources from oil and gas facilities.
ExxonMobil’s AMEL application requests the use of LiDAR technology from aircraft to detect and estimate the emission rate of leaks at XTO facilities across the Midland portion of the Permian Basin to satisfy its federal requirements for Leak Detection and Repair at those facilities.
Scanning oil and gas facilities from the air is significantly more efficient than scanning with ground crews and handheld instruments. Bridger’s LiDAR technology allows for these aerial scans to quickly survey all of the facility over a matter of days, which enables crews to prioritize and fix the largest leaks first.
ExxonMobil’s AMEL is an important step, paving the way for ExxonMobil, and the broader oil and gas industry, to deploy modern technology to tackle methane leaks. The application provides a framework by which to assess equivalent emissions reductions from very different leak detection approaches. This framework will guide other operators in making similar applications, spark further innovation across the technology ecosystem with this concrete demonstration of operationalization, and provides a first pass at streamlining for regulatory applications.
No, each oil and gas operator must submit its own AMEL for its facilities. However, ExxonMobil’s application will go through public notice and comment, so the processes will be adaptable for other operators’ facilities. This offers the hope of significant streamlining for future AMEL submissions.
EPA will review the application and discuss with the applicant, potentially seeking additional clarifications or supplemental information. When EPA is ready to approve the application, a formal notice and comment rulemaking will occur. As described in 42 U.S.C. §7411(h)(3):
If after notice and opportunity for public hearing, any person establishes to the satisfaction of the Administrator that an alternative means of emission limitation will achieve a reduction in emissions of any air pollutant at least equivalent to the reduction in emissions of such air pollutant achieved under the requirements of paragraph (1), the Administrator shall permit the use of such alternative by the source for purposes of compliance with this section with respect to such pollutant.
No. The AMEL would specifically satisfy obligations for the listed assets under US EPA federal air rules. However, the framework for assessing equivalency is useful for other operators applying for similar programs in other jurisdictions. Also Bridger’s Gas Mapping LiDAR has been included in many analogous Alternative Fugitive Emissions Management Program (Alt-FEMP) applications in Canada.
Here is a resource that explains the importance of ExxonMobil’s AMEL submission. If you missed our press release on ExxonMobil’s AMEL submission, click here.