We review submissions in the order we receive them. Our estimated processing time for this proposal is 60 days.
Purpose of the Proposal
Under Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting, a duty holder can request the use of an alternative fugitive emission management program (FEMP) by submitting a proposal for our review. As per section 8.10.6(2), these proposals must be approved by the AER.
Alternative FEMPs typically use new and emerging technologies to detect fugitive emissions. These technologies may be useful at detecting emissions at a lower cost than the standard methods used today.
Proposals can fall under two categories:
- Full-scale program - Information is available to support a comprehensive evaluation of program performance. These proposals would have sufficient performance data associated with the selected technologies to support a comprehensive evaluation of emission reductions. The AER expects to issue three- to five-year approvals for these programs.
- Pilot program - A critical piece of information is not available but could be collected through implementation of a pilot program. This information may be related to technology performance, operational impacts, cost data, emissions reductions, etc. The lack of this information would limit the ability for a duty holder to fully evaluate the overall performance of the program. The AER expects to issue two-year approvals for these programs. Given the uncertainty in emission reductions of pilot programs, we may limit coverage of pilot programs.
The following elements must be in place for us to review a full-scale program proposal. If either element is unavailable, implementation of a pilot program could be considered. A pilot program may collect data that would support a full-scale program.
- Extensive technology testing - Before a new technology or method is used in an alternative FEMP, its ability to detect fugitive emissions must be evaluated. Single-blind controlled field testing, administered by independent experts, should be used to develop performance metrics for each technology or method.
- Program performance assessment - A program performance assessment is a way to evaluate programs prior to implementation. These assessments can explore a range of possible FEMP configurations, forecast reductions over extended periods, and develop programs that use multiple methods across differing assets to maximize cost-effectiveness. Assessments can be completed using a variety of means (see the submission checklist below), but modelling is considered a more comprehensive method.
Submit a Proposal
Proposals should include the documentation outlined in the Submission Checklist for Alternative Fugitive Emission Management Program Proposals.
Email the proposal and any supporting documentation to Directive060Inbox@aer.ca and identify the company or group name and type of proposal in the email subject line. For example:
- [Company name], Alternative FEMP Proposal – Single-Operator Pilot Program
- For every proposal we receive, we will publicly share information on this page, including the following:
- area of program implementation
- technologies selected for use in the program
- performance data that will be collected during program implementation
- emission reduction assessment results
- We may request additional information to complete our review, and we will provide a deadline for this information. We will close the proposal if we do not receive the requested information before the deadline.
- Performance data from these programs may be summarized by the AER and made publicly available in a statistical report, published annually.
- To ensure the program renewal process is timely and efficient, please contact us at email@example.com 60 days prior to expiry of the approval and provide advance notice of what the intended next steps will be.
- The AER will review the performance of the individual program to determine if it should be renewed.
- A new proposal is not required to renew or extend a program. However, to assist our review, justification for further data collection (i.e., pilot program extension) or details of satisfactory program performance (i.e., full scale program extension) should be provided.
- Submit the new proposal as instructed above. If the intended next step is to revert back to the requirements listed in section 8.10 of Directive 060, no further information is required.