Timeline
We review submissions in the order we receive them. Once the proposal completeness review is complete (the proposal has all the data in the submission checklist), our estimated processing time for the proposal is 60 days (includes 30 days for the public notice for comment).
Purpose of the Proposal
Under Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting, a duty holder can request to use an alternative fugitive emission management program (FEMP) by submitting a proposal for our review. As per section 8.10.6(2), the AER must approve the proposal.
Alternative FEMPs typically use new and emerging technologies to detect fugitive emissions. These technologies may be capable of detecting emissions at a lower cost than the standard methods used today.
Proposal Types
Proposals can fall into 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.
Applications for a full-scale program proposal should include information on the performance of a comparable pilot and extensive technology testing data. - Pilot program – Critical information is not available but could be collected through the implementation of a pilot program. This information may be related to technology performance, operational effects, cost data, emissions reductions, etc. The absence of this information would limit the ability of a duty holder to complete a full evaluation of the overall program performance. The AER expects to issue two-year approvals for these programs. Pilot programs may not encompass the entire asset base of a given operator. At least 10% of the asset base should implement standard survey methods as a comparable control against the alternative program.
Proposal Development
The following elements are to 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 before implementation. These assessments can explore a range of possible alternative FEMP configurations, forecast reductions over extended periods, and develop programs using 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
Complete the appropriate alternative fugitive emissions management plan application form, which will be used for the 30-day public notice of application:
Proposals should also include the information 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
Proposal Review and Publication
- Proposals received by the AER undergo a completeness review to determine if all elements of the submission checklist are present. If deemed complete, the proposal will progress to a technical review.
- Once the proposal is deemed complete, we will post on our website for a 30-day public notice (see public notice of application).
- In the technical review, proposals will be evaluated for their ability to achieve comparable (i.e., equal or better than) emissions reductions to the standard method requirements in Directive 060. Any program information received by the AER may be published. We may request additional information to complete the technical review and will provide a deadline for this information. We may close the proposal if we do not receive the requested information before the deadline.
See the Alternative Fugitive Emission Management Program Approvals methane performance webpage for program summaries and performance reports.
Approval Renewal Process
Operators may apply to renew an alt-FEMP approval.
- Contact us at methane.reduction@aer.ca 60 days before the expiry of the approval and notify us of the next steps before the program to ensure its timely and efficient renewal.
- The AER will review the program’s performance 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 any additional information requested. If the intended next step is to revert back to the requirements listed in section 8.10 of Directive 060, no further action is required.
