May 28, 2018

(Signatories updated May 30, 2018)

Open letter about draft methane regulations from Alberta ENGOs

The position of 15 Alberta ENGOs on the Alberta Energy Regulator’s release of draft methane emissions reduction requirements - Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations  

The Honourable Rachel Notley
Premier of the Province of Alberta
307 Legislature Building
10800 - 97 Avenue
Edmonton, Alberta T5K 2B6

Dear Premier,

The undersigned organizations support the Government of Alberta’s methane emissions reduction target and consider it a critical element of Alberta’s Climate Leadership Plan. Regulations can contribute to reaching the target set within the Climate Leadership Plan to reduce methane emissions by 45 per cent by 2025, relative to 2014 levels.

The draft methane emissions regulations proposed by the Alberta Energy Regulator on April 24, 2018 do not compel the oil and gas industry to measure or report their methane emissions accurately. This fundamental flaw risks failing to achieve the targets set by the Climate Leadership Plan in addition to not  attaining equivalency with the federal methane regulations. 

As you are aware, recently collected data[1] shows that methane emissions are grossly underreported by industry in Alberta with emissions likely being 25 to 50 per cent higher than currently reported.

Without accurate measurement and reporting by industry, how can the Government of Alberta state with certainty that emissions are being reduced? The sad reality is that we will not be able to know. As a result, the draft methane regulations would be ineffective in driving action that meets Alberta’s emissions reduction targets.

The draft regulations don’t require companies to regularly monitor their operations for intentional and unintentional methane leaks. This approach – ignoring how much methane escapes into our air – is like driving a vehicle without a speedometer. How can you possibly know if you’re speeding? 

To have any effect, real, accurate and verifiable measurement and reporting systems for methane emissions must be developed in the regulations. Otherwise we risk continuing to not have accurate data and reporting, and therefore no way to claim reductions of methane emissions with scientific certainty.   

Respectfully, 

  • Alberta Wilderness Association
  • Calgary Climate Action Network
  • The Canadian Association of Physicians for the Environment
  • Canadian Parks and Wilderness Society Northern Alberta
  • Canadian Parks and Wilderness Society Southern Alberta
  • The Council of Canadians Edmonton Chapter
  • Crooked Creek Conservancy Society of Athabasca
  • HealthyYEG
  • Keepers of the Athabasca
  • Keepers of the Water
  • Mewassin Community Council
  • Peace River Environmental Society
  • Pembina Institute
  • Progress Alberta
  • Southern Alberta Group for the Environment

CC:     
Honourable Margaret McCuaig-Boyd, Minister of Energy
Honourable Shannon Phillips, Minister of Environment and Parks and Minister Responsible for the Climate Change Office
Mark Taylor, Executive Vice President, Operations Division, Alberta Energy Regulator
 

1. Comparisons of Airborne Measurements and Inventory Estimates of Methane Emissions in the Alberta Upstream Oil and Gas Sector; Matthew R. Johnson, David R. Tyner, Stephen Conley, Stefan Schwietzke, and Daniel Zavala-Araiza; Environmental Science & Technology 2017 51 (21), 13008-13017; https://pubs.acs.org/doi/abs/10.1021/acs.est.7b03525


March 15, 2018

Reducing methane emissions is the easiest way to protect our climate.

Alberta needs to get mandatory regulations done right and soon.

Open letter to the Government of Alberta 

Dear Premier Notley, Minister Phillips, and Minister McCuaig-Boyd,

The undersigned non-government organisations urge you to enact mandatory methane regulations as methane is a greenhouse gas 25 times more potent than CO2. The release of methane, the main constituent of natural gas is accelerating climate change. Methane is one of the easiest ways to cut huge levels of greenhouse gas emissions. It also makes our energy products cleaner and more competitive and creates new government revenue.

We applaud the Government of Alberta for its bold action in building and starting to implement the Climate Leadership Plan. This includes the commitment to reduce methane emissions from oil and gas operations, the largest contributor to methane emissions in Canada, by 45% by 2025.

We expect Alberta to implement methane regulations that require:

  • methane capture to be the default requirement
  • elimination of leaks with frequent leak detection and repair requirements
  • elimination / minimization of venting and flaring
  • methane regulations to be “equivalency-agreement-ready” with federal regulations
  • accurate, transparent, and auditable public reporting
  • legally enforceable and binding

Methane regulations are the most cost-effective way to reduce dangerous climate pollution. Industry wastes methane, a valuable non-renewable resource that belongs to Albertans. Alberta needs strong, mandatory, and effective methane regulations to maintain markets from our energy products and be a world leader in energy technology in the 21st century energy economy.

Methane regulations are the cheapest way to reduce climate emissions in the O&G sector. Cost-effective technology already exists and is in use by Albertan companies in other jurisdictions that are leading in improved methane management. These fixes do not require new technology and have minimal cost compared to other reduction opportunities. Stringent regulations will put to work 200 plus methane reduction companies to provide the needed engineering, manufacturing, and surveying to deliver this goal in Alberta.  

Industry wastes natural gas—a valuable public resource—leading to lost royalty revenues for Albertans. Lax methane regulations let industry rob Albertans of natural gas royalties that could pay for critical health, education, or other environmental protection services. We need the Government of Alberta to ensure that Alberta’s natural gas is not released to the atmosphere and oil and gas companies pay Albertans the royalties they are owed.

Others are way ahead of Alberta and we’re falling further behind. Alberta’s methane regulations must meet or surpass those of other leading jurisdictions. Already in the United States, Canada’s main competitor, six major oil and gas producing states—California, Colorado, Ohio, Pennsylvania, Utah and Wyoming—have strong methane regulations in place, and leading companies there have committed to eliminating methane emissions. Alberta can and must match and surpass these measures.

Industry agrees that methane emissions should and can be reduced. Ten international energy producers, including Exxon, Shell and BP, representing one-fifth of global oil and gas supplies, recently announced a commitment to work toward “near-zero” methane emissions. Alberta operators cannot afford to be left behind in this important goal, which requires strong methane regulations to be effective.

A majority of Albertans want mandatory methane regulations. Recent polling conducted in Alberta shows 66% favour mandatory methane regulations over a voluntary approach. 71% want Alberta’s regulations to be at least as strong as US States and 63% want to ban intentional venting of methane.

The Government of Alberta must continue to deliver their promised climate plan, and ensure that provincial regulations on methane achieve the same or better reductions as the federal rules, create clear and enforceable rules to hold the O&G sector accountable, and support the fulfillment of both the provincial and federal commitments to methane reduction from the O&G sector. With such regulations, Alberta will demonstrate a firm commitment to addressing climate change and will garner the support of Alberta environmental groups.

We are behind you in taking the measures necessary to ensure that Alberta doesn’t lose this rare and critical environmental and economic opportunity for Albertans.

Let's get methane regulations done right and soon. 

Respectfully, 

  • Alberta Wilderness Association
  • Calgary Climate Action Network
  • The Canadian Association of Physicians for the Environment
  • Canadian Parks and Wilderness Society Northern Alberta
  • Canadian Parks and Wilderness Society Southern Alberta
  • The Council of Canadians Edmonton Chapter
  • Crooked Creek Conservancy Society of Athabasca
  • HealthyYEG
  • Keepers of the Athabasca
  • Keepers of the Water
  • Mewassin Community Council
  • Peace River Environmental Society
  • Pembina Institute
  • Prairie Acid Rain Coalition
  • Progress Alberta
  • Southern Alberta Group for the Environment