Bridger Photonics’ Comments on Canada’s Oil and Gas Discussion Paper

In March 2022, Environment and Climate Change Canada (ECCC) published a discussion paper titled: Reducing Methane Emissions from Canada’s Oil and Gas Sector. This discussion paper solicits comments to help inform the development of new federal regulations to achieve Canada’s goal of at least 75% reduction in methane emissions from the oil and gas sector from 2012 levels by 2030.

With many clients and projects located in Canada, Bridger Photonics was thankful for the opportunity to provide comments. The following are key takeaways from our comments submitted to ECCC on the discussion paper.

Support of Unified Alignment Among Provincial and Federal Regulations

At Bridger, we support the unified alignment of federal and provincial regulations across Canada to the extent practicable, especially concerning the acceptability and approval of technologies for methane detection. 

We believe that basin-wide or federal approval for alternative emissions detection is ideal. Applying to the Alternative Fugitive Emissions Management Program (Alt-FEMP) on an operator-by-operator basis is inefficient and burdensome for both the operators and the alternative solution providers and is a barrier for operators seeking to use alternative methods to further reduce their emissions and expenses.

Additionally, alignment between the U.S. and Canada would streamline regulatory compliance for both solution providers and operators, especially those who have infrastructure in both countries. 

Inclusion of Performance Reporting for an Emissions Detection Technology 

Regardless of the scale of regulatory approval for a given emissions detection technology, there are critical elements of performance reporting that must be included along with the emission rate detection sensitivity to make the metric meaningful: 

1. A Probability of Detection

We urge the ECCC to require the detection sensitivity value to be coupled with a probability of detection (e.g. 10 kg/hr with a required >50% probability of detection).

2. Conditions Under Which Performance is Achieved 

No matter the detection technology, there will be conditions under which the technology performs better or performs worse. We urge the ECCC to require that the specified detection sensitivity be achieved under “typical” conditions for which the alternative work practice is applied. This can be rigorously tested (and audited by regulators) by analysis of the aggregate data on detected leaks in a basin by a detection technology.

Support of Performance-Based Regulations

Bridger supports performance-based regulations that achieve the proposed 75% emissions reduction. For a comprehensive emissions reduction estimate, the emissions reduction based on scan frequency and the probability of detection must be combined. For example, if a technology is used where the emission rate detection sensitivity is such that 90% of emissions are captured during a given scan, and monthly scans are used, this 90% probability of detection must be multiplied by the 90% reduction factor (i.e. 90% reduction factor based on the U.S. EPA’s estimate of methane reduction corresponding to 12 scans per year) and would result in an estimated 81% emissions reduction.

Bridger supports the inclusion of an emission rate detection sensitivity metric, probability of detection, and operational conditions under which the metric is achieved as essential elements for an acceptable performance-based monitoring program. Additionally, agencies, operators, and third parties need assurance that the intended sites were actually scanned by the aerial technology and that the scans met the detection sensitivity performance metric from a statistical standpoint.

We, therefore, urge the ECCC to require reporting of an auditable scan swath with GPS ground coordinates that document the actual coverage area of the aerial scan. In addition to the documented scan swath to verify that valid data was acquired from the sites, we urge the ECCC to require that aggregate emissions data from each aerial scanning solution provider pass a simple and objective audit to prove that the detection sensitivity performance metric is achieved by the technology (a) prior to the approval of the technology as an approved work practice, and (b) periodically during application of the work practice. Our full comment letter describes the simple Aggregate Emissions Distribution Test that can be used to ensure a technology’s actual performance in the field meets its stated emission rate detection sensitivity.