California SB 1137: Why Early Planning is Crucial for Oil and Gas Operators

• Early sampling and modeling are critical to understanding project scope, technology selection and budget
• Teams should plan for the full technology lifecycle not just initial equipment purchase and installation
• Connecting modeling, monitoring, data and response creates the visibility and confidence to ensure the program will work as intended

For operators impacted by California Senate Bill 1137 (SB 1137), selecting and implementing monitoring equipment will undoubtedly be a significant endeavor, but should not be the first step. Long before technology is ever discussed, operators need the right data early to ensure compliance, operations and public reporting are aligned from the beginning, not bolted on as they go.

SB 1137 officially took effect in June 2024, establishing Health Protection Zones (HPZs) around sensitive receptors, creating new requirements for existing oil and gas production facilities within those zones, and requiring operators to develop and implement Leak Detection and Response Plans (LDRP) that include continuous operating Emissions Detection Systems (EDS).

However, the detailed performance standards governing how these EDS operate and how operators will demonstrate compliance are still under development.

Planning and implementation for a change of this size require time. Using this planning window well can give operators more control over the technology, resources and capital the program will ultimately require.

Early movers will also demonstrate a proactive approach that builds positive reputational momentum as California continues to emphasize community transparency.

For operators looking for a summary of what implementation might look like, we’ve organized the SB 1137 requirements and developing CARB standards into four phases:

1. Characterize site emissions through third-party sampling: Identify site-specific compounds of highest concern and related exposure risk
2. Conduct air dispersion modeling: Using the Office of Environmental Health Hazards Assessment’s (OEHHA) Air Toxics Hot Spots Program Guidance Manual, perform modeling at each facility to understand site configuration and determine where EDS is needed and inform appropriate detection and alarm thresholds
3. Develop the LDRP: Translate site characterization and modeling into the monitoring and response program, including EDS selection and siting, alert thresholds, data quality plans, operating procedures, performance testing and maintenance and repair plans
4. Ongoing quality assurance and reporting: Annual reports to CalGEM must include a variety of data that will become publicly available beginning in 2030

While there is no existing precedent for the LDRP process, teams should anticipate more than a typical regulatory submission. This process will define how the monitoring program operates, meaning the decisions made during the initial sampling and modeling will shape what goes into the plan and the overall success of the plan.

As teams transition from largely internal operational data to sharing it with regulatory bodies and communities, monitoring technology selection will be central to SB 1137 implementation, but selecting equipment too early can create avoidable cost and complexity later.

Pausing to evaluate your monitoring program as a lifecycle system, not a single equipment purchase, can help teams make more informed decisions from the start. In this step, operators need to understand key aspects of facility configuration, including site configuration, monitor placement, procurement options, installation costs, data management, alert and response protocols and eventual equipment replacement.

Taking this system-level view ensures the technology fit aligns for compliance today and helps operators look beyond initial requirements to build a program able to adapt as regulatory and community expectations continue to evolve.

There are several practical steps operators can take today to reduce uncertainty and build a clearer picture of site-specific requirements before larger implementation decisions come into play:

By using the time we have available to fully understand assets, emission profiles, existing capabilities and data, as well as the remaining gaps, teams will have the necessary operational insights to avoid making major capital decisions under compressed timelines.

Operators that act now also have an opportunity to become leaders in the space by being among the first to take steps toward creating a mature environmental program that has the visibility, connectivity and defensible data to manage what comes next.