A case study in competing methane regulations: Will Canada's and Alberta's contrasting regulations achieve equivalent reductions?

The Canadian federal government and the Province of Alberta (the dominant oil and gas producing province) have released competing methane regulations for the oil and gas sector intended to take effect between January 2020-2023. Provisions in Canadian law could allow the provincial regulations to take precedent, but only if they are deemed to be equivalent in effect. This paper presents a comprehensive technical comparison of these upcoming regulations by considering potential site-by-site mitigation impacts on active oil and gas facilities in Alberta in 2018. This analysis was made possible by first creating a detailed inventory using recent pneumatic device count data and current production and activity data, which allowed detailed site-level calculations of regulatory impacts on a monthly basis as required by the regulations. The federal regulations are found to be stronger, achieving similar to 26% more methane mitigation at full implementation. Key differences are in limits on pneumatic pump emissions, vented emissions, and expected reductions in fugitive emissions through leak detection and repair surveys. The full analysis was repeated using production and inventory data for 2012 and 2017 to examine sensitivities to changing production patterns and facilitate comparisons to the 2012 baseline referenced in federal policy targets for methane reduction. The results were robust in all scenarios. Through a Potential to Emit threshold, the federal regulations also impact slightly fewer sites overall by exempting small sites handling limited gas volumes, while achieving greater overall methane reductions. Relative to a 2012 baseline, if fully implemented in 2018 the federal regulations would just reach the bottom of the 40-45% methane reduction target through a combination of past reductions (13%) and additional regulated mitigation (27%). However, recent trends in emissions from mined oil sands operations in particular (which are not affected by these regulations) suggests the 40-45% reduction goal for the overall sector may not be achieved by the 2025 target. Different scenarios to make the regulations equivalent are briefly discussed where the contrast in achieved mitigations for different key sources is important case study data for design of effective and efficient methane regulations.