1 At 6 of the 14 facilities, the mean of the TD method esti- mates diered by at least 2:1; i.e. one or both methods did not provide accurate estimates for nearly half of these midstream facilities. This result has a direct impact on any voluntary or regulatory reporting program focused on per-facility reporting. For example, EPA's recently proposed `super-emitter' reporting program and the `other large release event' reporting 28 would rely on approved anonymous surveillance by third parties to detect and report large release event of at least 250 mt CO 2 e per event or have a methane emission rate of 100 kg/h or greater at any point in time" 10 at oil and gas facilities, including midstream facilities such as a compressor station, or natural gas processing plant. Reported emission rates for these large emitters would be used to estimate total emissions, with emissions duration assumed to be a default of 182 days unless the operator can prove otherwise.