Response to the questionnaire on LDAR minimum detection limits and first step underground leak thresholds in the EU Methane Regulation
21 May 2025
This document presents MARCOGAZ’s response to the European Commission’s questionnaire on Leak Detection and Repair (LDAR) practices under the Methane Regulation. It underscores the industry’s commitment to methane emission reduction while supporting a practical, technologically neutral, and field-proven approach to leak detection.
MARCOGAZ highlights that LDAR efforts should prioritize the detection of repairable leaks—those above the regulatory threshold—as these provide the most impactful emission reductions. The response cautions against adopting overly sensitive Minimum Detection Limits (MDLs) that may drive inefficient inspections without tangible environmental benefit.
The organization supports flexibility in detection technologies and methods, emphasizing that field performance, measurement uncertainty, and environmental conditions must guide MDL definitions. MARCOGAZ calls for a framework that allows operators to adapt LDAR practices to specific infrastructure, operational contexts, and local conditions.
MARCOGAZ also calls for harmonization in regulatory definitions and stresses the importance of delegating standardization work to competent bodies such as CEN. It discourages prescriptive technology mandates and rigid thresholds, recommending a balanced, evidence-based regulatory approach that enables innovation and aligns with industry best practices.
