Calgary Oil & Gas Regulatory and Standards Day January 18th 2023

2023 Oil & Gas
Regulatory and
Standards
Workshop
Welcome message starts at
9:25 AM Calgary Time

Speaker
Jonathan
Brun
President at Nimonik inc.
Jonathan graduated in materials and
metallurgical engineering and founded Nimonik
in 2008. He has worked with companies in all
sectors of the economy to help them implement,
improve and execute their compliance
management programs with a focus on
compliance obligations and auditing.
Jonathan believes that organizations that
proactively manage their compliance will reduce
costs, risk and better protect their staff and their
stakeholders.

History
Nimonik inc.
Founded in 2008 to help Canadian businesses
comply with Federal, provincial and municipal
environmental regulations
Launched a mobile auditing solution in 2012
Acquired Toronto based Conformance Check
inc. in 2016
Acquired Shanghai based Envitool in 2017
Acquired Calgary based Media Logic in 2022
and expanded operations in Calgary and
Western Canada
Nimonik services over 30 Oil & Gas companies
in Canada

Goals
1. Networking with industry peers
1. Learn and discuss with peers
and knowledge leaders
1. Share areas of expertise
amongst participants
1. Determine potential services,
gaps and resources that could
be offered to the Oil & Gas
industry for improved
compliance

Agenda
9:25 Welcome message
9:30 CER regulated midstream operations
11:00 Coffee Break
11:20 Regulatory change management best
practices and NimonikApp
12:15 Lunch
1:00 Air emission regulatory changes
3:00 Break
3:20 Emerging methane regulations
4:45 End of day – drinks in Sheraton Bar
(cash bar)

Admin
Photos, video and recordings
Virtual people joining sessions
Knowledge sharing
Dietary restrictions
Presentations and handouts
Badges
Satisfaction survey, next event and follow-
ups

Speaker
Jesse
Diron
Regulatory Manager – Environment (Canada) at
Vertex Resource Group
Experienced project leader and management
professional with 22 years’ experience in the energy
industry. I have spent the last 19 years progressively
managing more complex projects for my clients in
energy, infrastructure, mining and government. This
role has included representing my clients and their
contractors through litigation as an expert witness,
open houses, town halls and, hearings.

CER OVERVIEW AND UPDATES
Operations and Maintenance
Presented by Joe Jesse Dirom
January 18, 2023

Canadian Energy Regulator Onshore Pipeline
Regulations (SOR/99-294)
Insert text here and fill up the whole page by writing across the text box and
waiting for the text to wrap. Insert text here and fill up the whole page by
writing across the text box and waiting for the text to wrap.
• Last amended September 2022
• Derives authority from the Canadian Energy Regulator Act
◦ Formerly the National Energy Board Act
◦ Still widely referenced as the National Energy Board Act (NEBA)
◦ Regulations made under the NEBA remain in force
◦ New regulations and updates are ongoing (phased approach)
What and when was the most recent update

The key changes that the Canadian Energy Regulator Act that impact the
operations and maintenance activities are as follows:
• Section 56 adds an obligation for the commission and designated officers
to consider any adverse effects that a decision, order or recommendation
they make may have on the rights of the Indigenous peoples of Canada
• When holding public hearings concerning the issuing, suspending or
revoking of certificates for pipelines or international or interprovincial
power lines or applications to abandon a pipeline, the regulator has the
discretion to establish processes to engage meaningfully with the public
and, in particular, Indigenous peoples and Indigenous organizations
Bill C-69

• Section 94 – Reasonable Care
• Permit Holders must take all reasonable care to ensure the
safety and security of persons, the safety and security of
regulated facilities and abandoned facilities and the protection of
property and the environment.
• Section 95-101 – Regulator Authority Expansion
• Allows regulator to craft regulations around:
• Requirements for management systems in place
• Includes cyber security systems
Bill C-69

• Opinion/non legal Section 56
• Obligation to consult has been significantly expanded and potential
to consult on exists on O&M activities
• Opinion/non legal Section 94
• Reasonable care is the caution and concern used by companies in
any given situation to prevent harm
• Essentially pay attention to what your peers are doing across the
industry as this can be considered “reasonable care”
• Opinion/non legal Section 95-101
• Regulator has been given authority to issue new regulations around
management systems that allows for an “ever-evolving” requirement
• Cyber security around pipelines will become a contentious and
auditable issue in the near future
Bill C-69

Takeaways – Up for discussion
• We have seen an increase in consultation recently with First
Nations on O&M activities as well as First Nation participation on
integrity programs
• Reasonable care clause is being used to increase standards as
technology and Best Management Practices change
• For example in order to claim reasonable care. An
environmental management system should identify, manage,
and control the risk of harm to the environment, and should
document the risks and actions taken. These need to be
recent and updated are per Section 6.5 of the OPR
• Updates to regulations will continue (phased approach as per Bill
C69)
• Regulator has ability to craft new regulations

Where have I seen Violations (non-compliance)
under the OPR Recently?
• Section 6.5/6.6
• Adequacy of management system processes
• Section 48
• Adequacy of environmental protection program
• Spill readiness
• Contaminated Sites Management
• Section 47
• Training Programs
• Safety management (specifically emergency situation management
programs)
• Damage prevention as per Section 16 of CER Pipeline Damage
Prevention Regulations

Takeaways – up for discussion
Non-Compliance
• Follow your internal approved documents to the letter onsite
• Example if your approved plan calls for soil to be stacked sideways
stack it sideways (extreme I know)
• Ensure that your spill readiness is constantly evolving and that staff are
trained in both process and implementation of the management plan
• Utilize web based platforms that tie site specific information to an area
so that you avoid IR’s
• When companies make positive changes internally to management
systems these changes need to be updated and reflected to CER
• Audits are going to be ongoing and become more regular

DFO MOU Updates for CER
• New MOU is due out in May
• Some changes expected around critical habitat and how the
banks and offsets to streams will be treated
• Expect more audits in its annual report to parliament DFO stated
the following
“With the modernization of the Fisheries Act, we decided to take a ‘boots
on the ground’ approach to monitoring and enforcing the fish and fish
habitat protection provisions. The hours spent by fishery officers doing
this work increased by 7,279 hours compared to the previous fiscal year.
It also helped that we hired 35 new fishery officers—and at least 35 of our
additional fish and fish habitat biologists became designated fishery
guardians under the Fisheries Act. This designation enables holders to
inspect sites such as dock construction, culvert installations or mining
operations to verify compliance”

Nimonik.com - info@nimonik.com - 1-888-608-7511 - +86 021 51720468
Oil & Gas Regulatory and Standards Workshop
In Break: Will return at 11:20
Calgary Time

Comprehensive
Compliance
Best Practices for Regulatory
Change Management and
Nimonik App workflows

About Us
Founded in 2008 with offices in Montréal,
Calgary and Shanghai. Nimonik services over
500 customers around the world, with a
focus on companies with 500 – 20,000 staff.

About Us
Nimonik is not an EHS management software
or just a content provider or simply an audit
tool.
Nimonik is an integrated
compliance solution for
regulations, standards and
internal requirements.

ISO
37301
Compliance Management
Systems Standard:
- Leadership & management
- Culture
- Systems, tools and
processes based on risk
- Reporting and identification
Upcoming webinar in March

Unique
Each organization must
design its own compliance
obligation management
program based on risk,
priorities, resources and
organizational structure.
You must own your
compliance program.

Why compliance matters
How to get there
1
2
Workflow Types
4
Agenda
Compliance Obligations
Structure
3

Minimal Management
Supervisor led
Systems are in place and training
is mandated. Most of the issues
are pushed by supervisors and
reports identify problematic
areas. General staff do not feel a
strong responsibility for
compliance.
Integrated
Team based compliance
All members of the organization
believe that compliance to
standards and regulations is good
business. Strong comprehension
by all of policies and procedures.
Easy access to data and software
that empower teams.
Reactive
Focus on putting out fires
Organization reacts to EHS, Quality
and Compliance issues as they
arise. People and teams respond
only when there is an immediate
problem.
Inconsistent
Piecemeal approach
Some processes and systems are
in place. Most facilities or business
units are independent and do not
share best practices or systems.
Compliance Maturity
Proactive
Forward thinking
Meet with stakeholders and
regulators. Conduct continuous
improvement of compliance
program.

Most organisations do not know ALL of
their obligations, leading to “surprises”...
A typical Facility has 3,000
Compliance Obligations and 200
new ones per year.

The Four Pillars of Compliance
Prevention
Risk profile
Historicals
Monitoring
Detection
Early detection
Self-reporting
Internal Audits
Response
Fast response
Data analysis
Action plans
Correction
Actions
Corrective
Effectiveness

A Comprehensive Compliance program captures all of
your Obligations across your areas of compliance:
Quality, environmental, safety, HR, OHS, product...
...and Sources:
External: Regulatory, standards,
And Internal: contracts, approvals, permits, stakeholders, customers,...
...and enables timely management of Actions and
Audits.

Actions
External actions when
regulations &
standards change.
Internal actions issued
by your team to come
into compliance.
Audits
Inspect your facilities
based on your
Obligations.
Verify for action
completion and
effectiveness of those
actions.
Obligations
External obligations
from regulations &
standards
Internal obligations
from your files, permits
and procedures.

Traditional Compliance Approaches
Shared Compliance
Obligations
● Inconsistency
● Loss of institutional knowledge
● Time consuming
In-house Shared Compliance
Obligations
● Compliance gaps
● Variability in work
● Expensive
Consultants Shared Compliance
Obligations
● Compliance gaps
● Variability in work
● Expensive
Consultants
Shared Compliance
Obligations
● Integration is complex and can
take years
● Expensive to build & maintain
Enterprise software

Clause Level
250,000 identified
obligations
Obligations in internal
documents
Web & Mobile Audits
Convert obligations and
actions into audits
Inspect & collect
evidence
Document Level
500,000 external
documents
+ Internal documents
Nimonik Solution Architecture
Action Management
Actions when obligations
change
Actions you create
Audits
Obligations Actions

Continuous Comprehensive Compliance: Nimonik Implementation
Select obligations &
personalize the
system
Map to responsible
teams
Establish your process
Monitor for changes
Follow-up on
compliance findings
Identify Obligations with
Questionnaire
Audit compliance on a
regular basis
Continuous
Improvement
Plan
Do
Check
Act

Elements for Success: Nimonik Implementation
Management
Understands proactive
compliance is an
investment
Project Lead
Can prioritize
implementation and has
the necessary support
Team
Recognizes the benefit of
a compliance system and
has time for training
Comprehensive
Compliance with
Nimonik

Speaker
Luz
Gomez
Customer Success Expert at Nimonik inc.
Luz Gomez has a master’s degree in
Environmental Assessment (MEnv) from
Concordia University. As a Customer Success
Expert at Nimonik, she implements new
accounts and guides customers to achieve
regulatory compliance.
Luz has over 5 years of experience in the
Environmental sector and 2 years of experience
in the Health and Safety sector. Throughout her
career, she has been involved with many
companies and non-profit organizations in
Canada and South America. She is also the
President of Net Impact Montréal, a volunteer-
led non-profit organization that helps connect,
engage, and inspire the local community to take
sustainability action.

Robust and mature program
A program with room for
improvement
1
2
Poll
Little to no program
3

Key Definitions
Facility: They represent your physical sites, or business operations, and can be thought
of as folders that contain and organize all of your Audits, Compliance Obligations, and
other account items.
Compliance Obligations: Obligations include both the requirements that your
organization must comply with and the requirements your organization chooses to
comply with. These can include laws and regulations, contracts, codes of practice, and
voluntary commitments like industry standards.
Audits: Lists of questions created from templates, that can be used to evaluate
compliance on an item-by-item level at your facilities.

Key Definitions
External Documents & Actions: Documents that may apply to your organization and that
are issued by an external party such as a regulator, government or standards body.
External Actions are created by Nimonik when documents are issued or modified.
Internal Documents & Actions: Documents that are specific to your organization and
have bene issued by you or through an interaction with an external party (agency, …).
Internal Actions are action items that your orgnization issues to itself.

General Structure Overview
Facilities
Compliance
Obligations Module
Audits Module
Document Level
Compliance
Obligations
Clause Level
Compliance
Obligations
Comprehensive
Compliance
Audits Templates
Audits

Identify your physical operations and
outline Obligations, Actions and
Audits for each location.
Control access by business unit,
region or facility.
Facilities

● Tags help tie the elements in your account
together - by business unit, by product line or
by anything that you wish to report by.
● Tags can be created and edited by account
administrators.
● They can be associated to facilities, audits,
internal actions and (soon) obligations.
● They can be used to filter reports.
Tags

Lists of documents from the Library,
that you are tracking for changes.
Compliance Obligations Registers
can be associated to a Facility or to
multiple Facilities

The Compliance Obligations Register
contains the following fields
(columns):
● Category
● Document
● Track
● Status
● Published Date
● Modified Date
● Obligations
● Assessment Status
● Responsible Party
● Notes
● Assessment History
● Internal Actions
● Custom Fields
Registers

● Help group the documents in CO registers
● Can be used to filter the information
● Are editable and can vary from one CO to
another
Categories

● Provide additional context and information
● Editable types ‘Custom Fields’ (Text, Date, User, Multiple Choice, & Risk)
● Use custom fields to link Compliance Obligations to control measures
and internal policies
Custom Fields

● Category
● Document
● Track
● Status
● Published Date
● Modified Date
● Obligations
● Notes
● Custom Fields
Registers
The Compliance Obligations Register
(columns):

Compliance Obligations where you
can view and assess each clause of
a document individually.
(Abbreviation: CLCO)
Clause Level
● Clause
● Original Text
● Track
● Assessment
● Custom Fields
● Full clause text
Clause Classifications:
Obligation – Contains information about what a non government entity must or must not do
Applicability – Contains information about the applicability of the document, or a subsection of the document
Obligation for Government – Contains information about what the government may or may not do
Information – Contains information that does not fall into any of the categories above

Actions created by Nimonik when
documents are added or updated in
your Compliance Obligations.
External Actions
There are 4 types of external actions:
New CO Document - A new document that matches your
compliance obligations’ settings has been published
New CLCO Clause - A new clause has been added to a document in
your compliance obligations
Updated CO Document - A document that you are tracking has been
updated
Updated CLCO Clause – A clause that you are tracking has been
updated

The compliance obligations register
(columns):
● Category
● Document
● Track
● Status
● Published Date
● Modified Date
● Obligations
● Notes
● Custom Fields
Registers

Actions created by Users in your
account.
Specifically, they can be created for:
● Scheduling Audits
● Documents and Clauses in
● Independently
Internal Actions

Not too
hot, not
too cold…
Considerations
• Reporting and audit
trails
• Internal resources to
review regulatory
changes
• Subject Matter Experts

A PARENT Facility/CO receives ALL New &
Updated Documents/Clauses, and then link
the New Documents to the CHILD
Facility/CO.
Each facility receives ALL New & Updated
Documents/Clauses in their Compliance
Obligations (COs) separated.
OR
ONE facility receives ALL New Documents
in their Compliance Obligations (COs). And
then the documents are duplicated in the
applicable registers.
Unique Compliance
Obligations
Shared Compliance
Obligations
All facilities use the SAME COs, which
receive ALL New & Updated
Documents/Clauses.
Connected Compliance
Obligations
Shared Compliance
Obligations
Facility 1 Facility 2
COs 1
COs 2
COs 1
COs 2
COs 1
COs 2
Facility 1
Parent COs 1
Child COs 1 Child COs 1
New / Updated Document
New / Updated
Document
New / Updated
Document

Unique Compliance Obligations
Pros Cons Best for
All registers receive New &
Updated Documents/Clauses
Duplicated work throughout the
registers
Companies who preferred that
their teams oversee their
obligations independently, and
have enough capacity to invest
time reviewing the registers
Each register can be setup to
receive documents related to
specific sectors & topics
Same documents in different
registers
Each Responsible Party oversees
their registers
Filtering process will be slower

Shared Compliance Obligations
Pros Cons Best for
Centralized registers used by all
facilities
Can get messy if too many facilities
are using the same registers
Small companies or teams that
want to have visibility of ALL
facilities’ compliance obligations
All users will have visibility on the
compliance obligations of the
company
Difficulty in closing actions as they
might be applicable to other
facilities using the register
Saves time if the team is small Will receive a high number of
documents, since ALL applicable
sectors & topics are selected
Information concerning
applicability might have to me
completed in other fields

A PARENT Facility/CO receives ALL New &
Updated Documents/Clauses, and then link
Facility/CO.
Each facility receives ALL New & Updated
Documents/Clauses in their Compliance
Obligations (COs) separated.
OR
ONE facility receives ALL New Documents
in their Compliance Obligations (COs). And
then the documents are duplicated in the
applicable registers.
Unique Compliance
Obligations (2 Approaches)
Shared Compliance
Obligations
All facilities use the SAME COs, which
receive ALL New & Updated
Documents/Clauses.
Obligations
Shared Compliance
Obligations
COs 1
COs 2
COs 1
COs 2
COs 1
COs 2
Facility 1
Parent COs 1
Child COs 1 Child COs 1
New / Updated
Document
New / Updated
Document

Connected Compliance Obligations
Pros Cons Best for
It is a centralized first review
approach
More responsibility to one
party/team
Companies that want to have a
centralized register without
document duplication and with the
team capacity to review & connect
the applicable documents
Notes and custom fields can be
connected to the child registers to
maintain continuity
Will receive a high number of
documents, since ALL applicable
sectors & topics are selected
The Parent-Child relationship will
keep the registers organized and
avoid document duplication
The responsible party of the Parent
register must understand the
operations of all facilties
Independent review of the actions
at the Child-Level

Each facility receives ALL
New & Updated
Documents/Clauses
Unique Compliance
Obligations
Start
ALL COs in ALL Facilities
receive ‘External Actions’
published by Nimonik
New & Updated
Documents/Clauses
Responsible Party of each CO
reviews the ‘External Actions’
and closes non-relevant
actions
Responsible Party set the
‘Assessment Status’ to ‘Review’
Are the ‘External Actions’
relevant to the Facility’s
operations?
Responsible Party reviews the
remaining ‘External Actions’
NO
YES
Change the ‘Assessment
Status’ to ‘Applicable’
Status’ to ‘Non-Applicable’
Un-track the document if no
further monitoring is required
Update ‘Assessment Status’ to
‘Complying’
Once the ‘Internal Actions’ are
completed, record closure
notes and close the action
Assign ‘Internal Actions’ & due
date to the Responsible Party
End
Does the New & Updated
Documents/Clauses require
‘Internal Actions’ to achieve
compliance?
Determine the ‘Internal Actions’
required
YES
NO

Obligations
Start
A MAIN Facility/CO receives
ALL ‘New Documents’
published by Nimonik
Responsible Party of that CO
reviews the New Documents
and closes non-relevant
External actions
Responsible Party of each CO
reviews the New Documents
and all related ‘External
Actions’
relevant to the Facility’s
operations?
NO
YES
A PARENT Facility/CO receives
ALL New & Updated
Documents/Clauses, and then link
Facility/CO.
ONE facility receives ALL New
Documents. And then the
documents are duplicated in
the applicable registers.
Unique Compliance
Obligations
Responsible Party of that CO
duplicates the document in the
applicable COs
‘Complying’
End
compliance?
required
YES
NO

All facilities use the SAME COs,
which receive ALL New & Updated
Documents/Clauses.
Shared Compliance
Obligations
Start
The COs shared by ALL
Facilities receive ‘External
Actions’ published by Nimonik
New & Updated
Documents/Clauses
The Responsible Party of the
shared COs reviews the
‘External Actions’ and closes
non-relevant actions
COs set the ‘Assessment
Status’ to ‘Review’
relevant to the Facilities’
operations?
The Responsible Party of EACH
Facility reviews the remaining
‘External Actions’
NO
YES
In a ‘Custom Field’ note which
Facilities these documents
apply to
Add a ‘Note’ (Or use a ‘Custom
Field’) to indicate the Facility
that has completed the review
‘Complying’
End
compliance?
The Responsible Party of EACH
Facility determines the ‘Internal
Actions’ required
YES
IF the ‘External Actions’ are
NOT relevant to any Facility,
the Responsible Party of the
shared COs can change the
‘Assessment Status’ to ‘Non-
Applicable’
shared COs closes the
remaining ‘External Actions’
NO

Connect the New Documents to
the applicable CHILD COs
Obligations
Start
The PARENT CO receives ALL
‘External Actions’ published by
Nimonik
New & Updated
Documents/Clauses
‘External Actions’ and closes
non-relevant actions
New Documents in the
PARENT CO
Are the New Documents
applicable to the CHILD
Facilities/CO?
NO
YES
‘Complying’
End
Does the Updated
compliance?
A PARENT Facility/CO receives
ALL New & Updated
Documents/Clauses, and then link
Facility/CO.
The CHILD COs will receive the
same updates to
Documents/Clauses as the
PARENT CO
required
YES
NO

Conclusion
There is no turn-key
solution.
Each organization must
design its own
compliance obligation
management tool based
on organizational
constraints and
operational realities.

In Break: will return at
1:00 PM Calgary Time

Speaker
Hillary
Yeung
Co-Founder of Horizon Compliance, Managing
Partner, Emissions & Sustainability, B.A.Sc.,
P.Eng
Hillary is a co-founder and managing partner of
Horizon Compliance Group, a consulting company
that provides comprehensive solutions for air,
emissions and regulatory compliance.
At Horizon Compliance, she is the subject matter
expert in emissions quantification for regulated
reporting programs, including greenhouse gas pricing
programs and methane reduction. Throughout her
career, Hillary has been heavily involved in guiding
industry in managing and reducing their carbon
liabilities.
Hillary is a Professional Engineer and holds a
Bachelor of Applied Sciences in Chemical
Engineering from the University of Waterloo.

Presented By: Hillary Yeung, B.A.Sc.,
P.Eng.
Co-Founder, Managing
Partner
Horizon Compliance Group
Inc.
Overview of Recent Regulatory Changes
Updates to Industrial Carbon
Pollution Pricing
Alberta TIER & Saskatchewan OBPS

▪ Alberta TIER and Saskatchewan OBPS documents were
released at the end of 2022.
▪ Not all documents have been released
▪ Some documents still in draft
▪ Information sessions are planned:
▪ Saskatchewan OBPS – Thurs Jan 19, 8am
▪ Alberta TIER – Mon Jan 23, 1:30pm
▪ Information summarized in this presentation are subject to
change
Disclaimer
76

▪ Regulatory drivers
▪ Common updates
▪ Alberta TIER review
▪ Saskatchewan OBPS review
▪ Discussion
Overview
77

▪ Aug 2021 – updates made to the Pan-Canadian Approach to
Carbon Pollution Pricing (2023-2030)
▪ Increase reductions to meet Canada’s 2030 and 2050 targets
▪ 2030 – 40% below 2005 levels
▪ 2050 – net-zero
▪ Maintain the carbon pollution price signal by adjusting the
stringency of output-based pricing systems
▪ Ensure carbon pollution pricing systems are comparable across
Canada
▪ Provinces had until Sept 2022 to align with strengthened
benchmark requirements to maintain equivalency with federal
program
▪ Updated benchmark will apply for 2023-2030 period
Regulatory Drivers
78

▪ Global Warming Potential update
CH4 = 28 (previously 25)
N2O = 265 (previously 298)
▪ Applicable to the 2022 reporting year
▪ Confirmed in SK OBPS, Federal OBPS
▪ Not yet confirmed in AB TIER, updates to be made to Standard for completing
greenhouse gas compliance and forecasting reports
▪ Carbon Pricing Update (Schedule 4 GHGPPA, excess emissions charge)
▪ Confirmed in AB TIER, SK OBPS
▪ Schedule 2 GHGPPA, Fuel Charge Rates, has not been amended
▪ Rates of charge applicable after March 31, 2022 remain applicable in 2023, for now?
Common Updates
79
Product 2022 2023 2024 2025 2026 2027 2028 2029 2030
Carbon Price $50 $65 $80 $95 $110 $125 $150 $155 $170

▪ Tightening rates are listed in the Standard for Developing
Benchmarks, which has not yet been updated
▪ Currently unclear if 2% tightening rate is applied to the Aggregate
Tightening
Benchmark Type Old Tightening Rate
New Tightening
Rate
LFE/Opt-in Facility Specific
Benchmark
1% annually 2% annually
High Performance Benchmark Fixed 2% annually
Aggregate Facility Specific
Benchmark
Fixed at 10% ?
81

▪ New high performance benchmarks for electricity, hydrogen,
industrial heat
▪ Other high performance benchmarks are repealed:
High Performance Benchmarks
• Ammonia
• Ammonium nitrate
• Bituminous coal
• Cement
• Ethylene glycol
• Hardwood kraft pump
82
Product 2022 2023 2024 2025 2026 2027 2028 2029 2030
Electricity
(tCO2e/MWh)
0.3700 0.3626 0.3552 0.3478 0.3404 0.330 0.3256 0.3182 0.3108
Hydrogen
(tCO2e/tH2)
9.068 8.993 8.919 8.844 8.769 8.694 8.620 8.525 8.470
Industrial Heat
(tCO2e/GJ)
0.06299 0.06173 0.06047 0.05921 0.05795 0.05669 0.05543 0.05417 0.05291

▪ Types of credits available
▪ Credit usage limit
Credit Usage
Credit Type
Previous
Expiration
Proposed
Expiration
Emission Performance Credits (EPC) 8 years 5 years
Emission Offsets (EO) 8 years 5 years
Sequestration Credit (SC) NEW! N/A 5 years
Years Credit Use Limit
2023 or earlier 60%
2024 70%
2025 80%
2025 and subsequent 90%
83

▪ Large final emitter definition
▪ Exceeds over 100,000 tCO2e, or;
▪ Import more than 10,000 tonnes of hydrogen NEW!
▪ Emissions intensive trade exposed (EITE) sector
▪ Opt-in threshold reduced to 2,000 tCO2e (previously 10,000 tCO2e)
Large Final Emitters & Opt-In Facilities
84

▪ Large emitters and opted-in facilities that utilize carbon capture
can claim reductions by the following:
▪ Generate emission offset (EO) credit from geologically sequestering
CO2
▪ Offset projects have 8-year crediting period (possibility of extension)
▪ Convert EO to a sequestration credit (SC) (sequestration occurs 2022
or later)
▪ Enable recognition under Clean Fuel Regulations
▪ Convert SC to a carbon reduction tonne (CRT) (sequestration occurs
2023 or later)
▪ Only if sequestration occurred at the TIER site in question.
▪ CRTs reduce total regulated emissions (TRE)
TRE = DE – ICO2 + ECO2 + UCO2 - CRT
Carbon Capture & Storage
85

▪ Total Regulated Emissions
▪ Stationary Fuel Combustion, and;
▪ Flaring NEW!
TRE = ESFC + EF + ECO2A
▪ Re-benchmarking and quantification requirements TBD
▪ Deadlines:
▪ New aggregate applications – due Nov 15th of the requested
compliance year NEW!
▪ Additions to aggregate facilities – due Nov 15th of the requested
compliance year NEW!
▪ Removals to aggregate facilities – due Dec 1st prior to the requested
compliance year (no change)
Aggregate Facilities
86

▪ Updates:
▪ Management and Reduction of Greenhouse Gases (Standards
and Compliance) Regulations
▪ (Baselines, Returns and Verification) Standard
▪ (Upstream Oil and Gas Aggregate Facility) Standard
▪ Performance Credit Standard
▪ New:
▪ (Electricity Compliance and Verification) Standard
▪ (Quantification, Measurement and Sampling) Standard
▪ Carbon Capture Utilization and Storage (CCUS) Credit
Standard
▪ CCUS Credit Plan
▪ CCUS Credit Report
Program Documents
88

▪ Gross electricity generation as a product/sector is a new
addition
▪ Two emissions options:
▪ Gas to power electricity emissions
▪ Generated by associated gas (gas produced from a well)
▪ Regulated electricity emissions
▪ All other electricity generation
▪ Two facility options:
▪ Electricity generation facility
▪ Industrial facility with integrated electricity generation
Electricity
89

Electricity Emissions Intensity Standards
Compliance
Year
Electricity (tCO2e/GWh)
Heat
(tCO2e/GJ)
Solid Fuel
Existing
Gaseous
Fuel1
New &
Expanded
Gaseous
Fuel2
Liquid Fuel Sold Heat
2023 556 370 288 550 0.058
2024 538 370 247 550 0.058
2025 510 370 206 550 0.058
2026 482 370 164 550 0.058
2027 454 370 123 550 0.058
2028 426 370 82 550 0.058
2029 398 370 41 550 0.058
2030 370 370 0 550 0.058
1 applies to existing units (before January 1, 2023)
2 applies to new and expanded units (on or after January 1, 2023)
90

▪ Opt-in threshold lowered to 0 tCO2e, except for
electricity generation
▪ Large Emitter Definition
▪ Regulated electricity sector = 10,000 tCO2e NEW!
▪ All other sectors = 100,000 tCO2e (no change)
▪ Upstream Oil & Gas sector emissions sources:
▪ Stationary fuel combustion
▪ Includes gas to power and regulated electricity NEW!
▪ Flaring NEW!
▪ On-site transportation NEW!
▪ Industrial product usage NEW!
Large Final Emitters & Opt-in Facilities
91

▪ Upstream Oil & Gas sector emissions sources:
▪ Stationary fuel combustion
▪ Includes gas to power and regulated electricity NEW!
▪ Includes drilling operations (optional) NEW!
▪ Flaring NEW!
▪ On-site transportation NEW!
▪ Industrial product usage NEW!
▪ Change in definition of Part 2 and Part 3 (does not include
drilling emissions)
▪ Part 2 aggregate <15,000 tCO2e (previously <10,000 tCO2e)
▪ Part 3 aggregate ≥15,000 tCO2e (previously ≥10,000 tCO2e)
Aggregate Facilities
92

▪ Total Regulated Emissions (TE) =
Direct Emissions (DE) + Drilling Emissions (Di)
▪ Drilling operations benchmark (BD): 0.0255 tCO2e/metres
drilled
Aggregate Facilities - Drilling
93

Performance Standards Allocation
Reductio
n Period
Upstream Oil and Gas
Previous PSA Proposed PSA
1 1.25% 1.67%
2 2.50% 3.33%
3 3.75% 5.00%
4 5.00% 6.67%
5 6.25% 8.33%
6 7.50% 10.00%
7 8.75% 11.67%
8 10.00% 13.33%
9 11.25% 15.00%
10 12.50% 16.67%
11 13.75% 18.33%
12 15.00% 20.00%
Reductio
n Period
Gas to Power
Proposed PSA
1 0.62%
2 1.25%
3 1.87%
4 2.50%
5 3.12%
6 3.75%
7 4.37%
8 5.00%
9 5.00% (assumed)
10 5.00% (assumed)
11 5.00% (assumed)
12 5.00% (assumed)
94

▪ Quantification methodology for stationary fuel combustion, on-site
transportation, and flaring
▪ Generally align with AB TIER, ECCC GHGRP
▪ Measurement and fuel sampling requirements for:
▪ Fossil fuel use in regulated electricity generating units
▪ Marketable natural gas
▪ Liquid fuels
▪ Solid fuels
▪ Drilling operations
Quantification, Measurement, Sampling
95

▪ CCUS credits can be generated by:
▪ CCUS Credit Plan – project registration
▪ CCUS Credit Report – credit serialization
▪ CCUS credits may only be used for OBPS compliance by
regulated emitter that generated the credits
▪ CCUS credits cannot be sold or transferred to other regulated
emitters.
Carbon Capture Utilization & Storage
96

▪ CCUS
▪ Implication of third-party carbon hubs on compliance
▪ Aggregate facilities
▪ Addition of flaring source – how will this impact compliance?
▪ How will this affect benchmarking?
▪ Alberta TIER
▪ How can we forecast compliance with tightening rates? Aggregate vs.
LFE/Opt-in
▪ Repealed HPBs, will these facilities have to establish FSBs?
▪ Saskatchewan OBPS
▪ Gas to Power operations with associated gas – does this heavily
impact compliance?
Suggested Discussion Topics
98

Contact: Hillary Yeung, B.A.Sc., P.Eng.
Co-Founder, Managing Partner
Horizon Compliance Group Inc.
hillary.yeung@horizoncompliance.com
www.horizoncompliance.com
Questions?

In Break: Will return at 3:30
Calgary Time

Presented By: Hillary Yeung, B.A.Sc.,
P.Eng.
Co-Founder, Managing
Partner
Horizon Compliance Group
Inc.
Overview of Upcoming Regulatory Changes
Methane Reduction Requirements
Federal, Alberta and Saskatchewan

▪ Regulatory drivers
▪ Current regulations and timelines
▪ Review of proposed changes
▪ Discussion
Overview
102

▪ Nov 2022– proposed regulatory framework for reducing
oil and gas methane emissions to achieve 2030 target
▪ Previous target: 40-45% reduction below 2012 levels by 2025
▪ New target: at least 75% reduction below 2012 levels by 2030
▪ Proposed amendments expand the scope of existing
regulations:
▪ Apply to more sources
▪ Eliminate exclusions
▪ Require zero emissions as much as possible
Regulatory Drivers
103

Federal
▪ Regulations Respecting Reduction in the Release of Methane and Certain
Volatile Organic Compounds (Upstream Oil and Gas Sector)
▪ Reduction in the Release of Volatile Organic Compounds Regulations
(Petroleum Sector)
▪ Proposed: A proposed approach to control volatile organic compounds
(VOC) emissions from the storage and loading of petroleum liquids
Alberta
▪ Alberta Directive 060 Upstream Petroleum Industry Flaring, Incinerating,
and Venting: Chapter 8
Saskatchewan
▪ Saskatchewan Oil and Gas Emissions Management Regulations
▪ Saskatchewan Directive PNG036: Venting and Flaring Requirements
Current Regulations
104

▪ Alberta and Saskatchewan currently have equivalency
with federal methane regulations
▪ Equivalency can be terminated earlier by either government
with at least 3 months written notice
▪ AER expects draft federal regulations to be released by
Q1/Q2 2023.
▪ Alberta stakeholder engagement is planned to begin shortly
after
Timeline
105

Hydrocarbon Gas Conservation and
Destruction Equipment
Jurisdiction Approach
Proposed Federal
▪ Destruction = 99%+ control efficiency
▪ Conservation = 98%+ efficiency
▪ Fuel combustion = 95% control efficiency
Current Federal
▪ Destruction = must satisfy requirements from AB D060,
SK S-20, BCOGC Flaring & Venting Guideline
▪ Conservation = 95%+ efficiency
▪ Fuel combustion if using conserved gas = 95% control
efficiency
Alberta
▪ Flares and incinerators must be properly designed
▪ Incinerators ≥ 99%, otherwise treated as a flare
Saskatchewan
▪ Flares and incinerators must be properly designed
▪ Incinerators ≥ 99%, otherwise treated as a flare
106

▪ Flare conversion efficiency adopted from USEPA studies
and summarized in TIER AQM (Ver 2.2)
▪ 98% for unassisted flares (typically in remote oil and gas
production operations)
▪ 99.5% for properly-operated, highly turbulent, air-or steam-
assisted flares (typically in gas plants, upgraders, refineries,
chemical plants)
▪ Minimum incinerator conversion efficiency defined and
as required by D060 and PNG036
▪ 99% for all incinerators
Conversion Efficiency
107

Flaring
Proposed Federal
▪ Prohibited at all oil sites
▪ Enclosed combustion must have auto-igniter
▪ Operators required to ensure equipment is working
Current Federal ▪ N/A
Alberta
▪ Routine or continuous flaring at oil facilities can flare
within the parameters of facility licenses
Saskatchewan
▪ Routine or continuous flaring at oil facilities can flare
within the parameters of facility licenses
108

General Facility Venting & Flaring
Proposed Federal
▪ No conditional requirements
▪ Oil facilities >5 m3/day (flare + vent volume) required to
eliminate venting (gas conservation)
▪ Surface casing vents required to be controlled
(conservation/destruction)
Current Federal
▪ Upstream oil and gas facility must not vent >15
e3m3/year (excludes liquids unloading from gas well,
blowdown, glycol dehy, pneumatics, compressor vent,
start up/shut down, well completion, emergencies)
Alberta ▪ Overall vent gas limit – 15 e3m3/month
Saskatchewan
▪ Oil facilities >900 m3/day must flare non-conserved gas
(except for emergencies)
▪ Oil facilities (corporately) must not exceed OGEMR
emissions intensity limit per production class
109

Pneumatic Devices
Proposed Federal ▪ All pneumatics required to be non-emitting or captured
Current Federal
▪ Pneumatic controllers – 0.17 m3/h
▪ Pneumatic pumps cannot vent unless permit is approved
Alberta
▪ New pneumatic devices and pumps (after Jan 1, 2022)
cannot vent
▪ Existing pneumatic devices – 0.17 m3/h
Saskatchewan
▪ Oil facilities >900 m3/day must flare non-conserved gas
(except for emergencies)
▪ Oil facilities (corporately) must not exceed OGEMR
emissions intensity limit per production class
110

Fugitive Emissions
Proposed Federal
▪ All facilities required to have monthly inspections
▪ Leak repair must be completed immediately, or request
extension
▪ Non-producing wells required to have annual inspections
Current Federal
▪ Triannual inspections required
▪ Single wellhead sites excluded
▪ Leak repair within 30 days
Alberta
▪ Triannual or annual inspections based on facility type
▪ Well-sites require annual screenings
▪ Leak repair within 30 days
Saskatchewan
▪ Semi-annual inspections for gas facilities based on
subtype
111

Compressor Engine Exhaust
Proposed Federal
▪ Compressor engines would be required to achieve
complete combustion and reliable ignition
▪ Methane emissions cannot exceed 1 g/kWh methane
▪ Smaller compressors would be included in vent limits
Current Federal ▪ Compressor venting limits for units ≥ 75kW
Alberta ▪ Compressor venting limits for units ≥ 75kW
Saskatchewan ▪ N/A
112

Planned Blowdowns
Proposed Federal
▪ Planned pipeline blowdown activities required to be
controlled (conservation, destruction, or re-routing)
Alberta ▪ Blowdown activities allowed to vent (some limitations)
Saskatchewan ▪ Blowdown activities allowed to vent (some limitations)
113

Distribution Pipelines
Proposed Federal
▪ Fugitive management, pneumatic device and blowdown
rules would be applied.
Alberta
▪ Must follow Chapter 6 and 7 in D060: Venting events
cannot exceed 2 e3m3 and must not exceed 24 hours.
Saskatchewan ▪ General limitations for non-routine venting.
114

Liquids Unloading
Proposed Federal
▪ Well liquids unloading activities required to use
capture/recovery or install control device (minimum
95%).
Alberta ▪ Short-term venting for well unloading allowed
Saskatchewan
▪ Short-term venting for well unloading allowed as long as
corporate OGEMR venting limits are met
115

Glycol Dehydrators
Proposed Federal
▪ Required to reduce emissions by at least 95%, or
emissions need to be captured
Alberta ▪ Methane and benzene emissions limits apply
Saskatchewan ▪ Benzene limits apply
116

▪ How will this impact current provincial requirements?
▪ Feasibility of proposed changes:
▪ Flaring elimination – what is the impact to operations?
▪ Venting elimination – what is the impact to operations?
▪ Availability of service providers
▪ Ability of current technology
Suggested Discussion Topics
118

Wrap-Up
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