According to Alaska’s 2015 Greenhouse Gas Inventory Report , over half of the state’s total greenhouse gas emissions are generated by the oil and gas industry. By statute, the state considers any non-emergency release of oil and gas, usually in the form of venting or flaring, in excess of one hour as potential waste. Thus, better enforcement of Alaska’s oil and gas waste rules has long been viewed as Alaska’s “low hanging fruit” for reducing the state’s greenhouse gas emissions.
In the fall of 2018 Kate Troll filed a request for hearing with the AOGCC to urge the Commission to “fully enforce and strengthen existing statutes requiring Alaska’s oil and gas industry to stop all non-emergency venting and flaring from Alaska oil and gas wells”, on behalf of more than 400 Alaskan petitioners . The hearing was granted on Dec 18, 2018. Ms. Troll was joined in testimony by Lois Epstein with The Wilderness Society, Alaska and Ceal Smith with the Alaska Climate Action Network.
Figure 1. AOGCC Reported annual venting and flaring in Alaska 2012-2019, as compared to the average annual consumption by a Enstar customer (139 thousand cubic feet). About 25,000 homes could be supplied with the reported natural gas lost in flaring statewide.
Alaska Climate Action Network's review of industry reports obtained from AOGCC prior to the hearing revealed 1,468 gas releases greater than 1 hour occurred between 2012-17, in potential violation of Alaska’s waste rules ,. Kate Troll explicitly asked the commissioners for an explanation of this large number of releases and to provide evidence of enforcement action.
In their written response , Commissioners Foerster and Seamount dismissed Troll’s concerns and failed to address the releases. Instead they claimed the “root concern” of the parties requesting the hearing was climate change and that the agency had “no authority to act regarding that subject matter” despite Troll’s opening statement that she was not asking the Commission to address climate change:
To start I want you to know that while the topic of climate change will enter this hearing, we are not asking you to enlarge your mission. We do not seek mission creep, we merely ask that you urgently and competently enforce AS. 31.05.095 which prohibits the waste of oil and gas and regulation 20 ACC 25.235 (b) which defines waste as gas released, burned or permitted to escape into the air. Because that gas which escapes is mostly methane, a greenhouse gas about 30 times more potent than carbon dioxide over the long-term and almost 90 times more potent over the short-term, the matter of climate change enlarges the public interest behind your existing mission. In other word, it’s not mission creep we seek but mission urgency.In response to the AOGCC failure to address substantive issues raised during the Dec 18, the Alaska Climate Action Network, Ground Truth Trekking, and Alaska Community Action On Toxics filed a new request for a hearing  with the AOGCC on March 20, 2019 specifically lodging a complaint of waste. The request was denied.
In the interim, the group filed an information request with AOGCC in order to investigate the facts behind the releases. They found that between January 2012 and October 2018 industry flared or vented, on average 3,240,000 Mcf (thousand cubic feet) of gas per year. BP and Hilcorp were the biggest emitters. BP vented or flared 2,300,000 Mcf per year on average from its large North Slope operations and Hilcorp (with far fewer wells and infrastructure) vented or flared 400,000 Mcf per year on average between 2012 and 2019 (see Figure 1).
But that’s not the full story. A 2019, the US Department of Energy (DoE), Office of Oil & Natural Gas Regulations reported far higher levels of venting and flaring in Alaska, between 42% and 74% higher than industry reported to the AOGCC between 2013-2018  (see Table 1 and Figure 2 below).
Despite several calls to State and Federal agencies, we’ve been unable to get an explanation for the significant gap between the DoE and AOGCC reports. These discrepancies, and the AOGCC’s failure to address citizen concerns, raise far more questions than they answer.
Chart from US Department of Energy Alaska Natural Gas Flaring and Venting Regulations, May 2019
As a recent New York Time's story indicates  excessive flaring and venting are continuing unabated by major oil companies that also operate in Alaska. Often this is driven by logistical difficulties that make it quicker and more profitable to waste the gas than to bring it to market. Much of Alaska’s gas faces similar logistical difficulties.
As a prudent resource owner, it would be in the state’s best interest to ensure that gas is conserved for potential future use. Flared or vented, the gas is wasted forever, and the resulting pollution will last for generations. Our analysis and interaction with AOGCC indicate that a similar pattern of large-scale waste is happening here. Companies are burning massive amounts of natural gas unabated and with little to no oversight or enforcement whilst aggressively seeking to rollback bonding and regulatory requirements . The AOGCC needs to aggressively investigate incidences and amounts of waste, to ensure that any venting and flaring is truly a response to an emergency, rather than a matter of cost or convenience.
 Greenhouse Gas Emission Inventory, https://dec.alaska.gov/air/anpms/projects-reports/greenhouse-gas-inventory
 Gas released, burned or permitted to escape into the air constitutes waste: 20 AAC 25.235(b), and waste of oil and gas in the state is prohibited: Sec. 31.05.095.
 As required under AS 31.05.060(a)
 Graphic created by Brentwood Higman, PhD, Ground Truth Alaska.
 US Department of Energy, Office of Oil & Natural Gas Regulations, Alaska Natural Gas Flaring and Venting Regulations, May 2019, https://www.energy.gov/sites/prod/files/2019/08/f66/Alaska.pdf
 Hiroko Tabuchi, New York Times, “Despite Their Promises, Giant Energy Companies Burn Away Vast Amounts of Natural Gas”, October 16, 2019. Proposed repeal of regulations, https://www.commerce.alaska.gov/web/aogcc/Home.aspx