Re: Regulations Amending the Regulation Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector)

The achievability of the proposed cap is heavily contingent upon the feasibility, the success, and reductions achieved by the draft methane amendments. [...] Estimated cost of compliance CAPP has reviewed the cost estimates in the RIAS and the Techno-Economic Assessment of Methane Pathways for the Upstream Oil & Gas Sector in Canada completed by Process Ecology.11 The Process Ecology report is frequently cited in the RIAS as a primary source supporting its economic impact analysis. [...] Definitions and scope Application of regulation to non-producing wells Although it is not clearly specified in the draft amendments, it is clear in the RIAS that the draft amendments are expected to apply to non-producing wells, including leak inspection requirements. [...] A shutdown for the purpose of leak repair is only required if the emissions from the leaking components would exceed the emissions associated with the shutdown. [...] The soap test is used by those installing commercial, industrial, and residential natural gas to ensure there are not natural gas leaks in peoples’ homes, a high standard for safety and reliability.17 A requirement to confirm repair with the equipment used for comprehensive survey is unnecessary and removes that equipment – and the experts capable of its effective use – from conducting other surve.