We are piloting a new way of collecting feedback on draft regulatory requirements. We invite you to fill in the online comment form for each directive below.
Helpful background information can be found on the Reports and Studies page or in the important topics section below.
You can save your progress and return to the survey at a later date. The survey closes on May 28, 2018. Questions about the survey or the draft requirements can be sent to Methane.Reduction@aer.ca.
Draft Directive 060: Online Feedback Form
Draft Directive 017: Online Feedback Form
The AER is also collecting feedback via the traditional form. Instructions on how to submit the form can be found on the draft directive landing pages:
Environment and Climate Change Canada (ECCC) regulations are designed for all of Canada (including offshore), whereas the AER’s proposed requirements are for Alberta only. Equivalency discussions will be held between the Government of Alberta and ECCC. Please contact Alberta Energy for questions related to federal equivalency.
The estimated cost of the requirements is $780 million (2018-2025). The AER estimates ECCC’s methane regulations will cost $1.66 billion (2018-2025). We used extensive modelling to inform the regulatory design in order to minimize the economic impact of the requirements. For information about ECCC’s methane reduction regulations, including cost, visit ECCC’s website.
Scope of the Requirements
The proposed requirements apply to AER regulated:
- upstream oil, gas and bitumen wells,
- oil and gas facilities,
- gas plants,
- pipeline installations,
- storage facilities, and
- tank terminals (i.e., production and injection wells, batteries, and central processing facilities within thermal in-situ oil sands schemes)
The proposed requirements do not apply to:
- oil sands mining schemes,
- midstream facilities,
- midstream meter stations,
- midstream pipelines,
- processing plants for removing bitumen from oil sands at mines including upgraders,
- rail car loading facilities,
- downstream distribution pipelines,
- downstream facilities, and
- AER regulated facilities that are not related to oil, gas or bitumen production (such as coal, water wells, brine wells, or NEB regulated facilities).
Measurement, monitoring and reporting are important elements of the draft requirements. Improved reporting and measurement will help to better quantify and track Alberta’s progress towards methane emissions reduction.
Once the requirements take effect, the measurement system will allow us to collect enough information to track our progress toward the 45 per cent target and at the same time we will continue to advance research and development programs intended to improve emissions quantification and reduction technologies. Because the methane reduction requirements are an addition to the AERs regulatory framework, we think it’s important to step back and review how effectively they are reducing methane in light of this additional information.
The review itself is planned for 2022, which is when we will have enough reported emissions data to update our model and most of the research programs will be complete. Prior to the review, we will meet with a stakeholder committee to identify any potential data gaps, review annually reported data, and review research outcomes that may be available.
Although the AER reviews its directives on an ongoing basis this is the first time a review of a directive has been embedded into the text of the directive itself. The process for this review is in draft and is based on best-practices from other jurisdictions.
To enforce the new requirements, the measurement system will collect emissions data from oil and gas facilities and compare them with our requirements to determine which facilities may be out of compliance. Depending on the type of noncompliance detected, companies will either be sent a noncompliance letter immediately or we will first audit the data to better understand the nature of the noncompliance. We will also do inspections to identify noncompliant facilities. Inspections can be triggered by potential risk, a public complaint, or abnormal reported data.
Noncompliances will be dealt with in accordance with Manual 013: Compliance and Enforcement Program and may include enforcement tools ranging from warnings and administrative penalties to orders imposing conditions and prosecution. More specific information about compliance can be found in the draft requirements.
The AER is planning to submit a final set of requirements to the Government of Alberta for approval later in 2018. The requirements will begin taking effect in 2019—a full summary of in-effect dates is listed in Table 4 on page 76 of Draft Directive 060.