Navigating TIER flaring regulations: Why taking control of your benchmark matters
As part of Alberta's ongoing efforts to meet carbon reduction targets, Alberta Environment and Protected Areas (AEP) has introduced a significant amendment to the aggregate facilities section (Chapter 15) of the Alberta Quantification Methodology. This amendment includes flaring as part of the total emissions considered under the Technology Innovation and Emissions Reduction (TIER) program.
Starting with your 2023 compliance report, organizations with TIER aggregates will have two options to comply with this regulatory change:
Option 1: Let AEP assign you a new facility specific benchmark (FSB)
Option 2: Submit your own FSB application to AEP
While Option 1 may initially seem cost-effective, and could work perfectly fine for small-scale, straightforward operations, there are a few factors that warrant careful consideration.
Knowledge of Calculation Methodology:
If you choose to let AEP assign you an FSB, your organization sacrifices a degree of control and understanding of calculation inputs. For your benchmark, it is unlikely that you will have the opportunity to review the calculations before they are assigned to you, and consequently, when submitting your annual compliance report, you may encounter challenges in reproducing AEP's calculations, which could complicate the verification process.
Flare Types and Efficiencies:
When quantifying flaring activities, the AEP does not have access to some crucial pieces of the puzzle, such as what types of flares or incinerators you have onsite. The difference between a simple, unassisted flare and a highly turbulent, multi-streamed, acid gas incinerator can offer a considerable opportunity to reduce emissions and achieve cost-saving results. For example, when comparing a flare with a 98% combustion efficiency to an incinerator with 100% combustion efficiency, you can potentially achieve a CO2e reduction of 12% when using the default emission factors, considerably more than the apparent 2% efficiency boost. The AEP has no way of knowing if you have an incinerator vs a flare onsite just by looking at your Petrinex data, and if you choose to correct the equipment type later, you may end up needing to re-benchmarking anyways.
Your site's gas compositions are another valuable source of information and present a significant opportunity for emissions reduction. Again, the AEP will not be able to know what you use onsite, and as a result, will be required to make assumptions. Generic and conservative estimates could end up overestimating your organizations actual flaring emissions and compliance costs. For example, if a gas plant operating an unassisted emergency flare that is primarily burning a sales gas composition is assigned the default RICH gas composition instead of the sales gas, you can expect a 16% increase in your CO2e emissions. Across your entire operations, 16% quickly adds up to significant additional emissions. By taking matters into your own hands and using the correct default gas types (or even more accurately, by using your site’s actual gas composition), you will ensure that your calculations closely align with your actual site’s emissions and avoid any over-estimations.
Ultimately, having control over your benchmark and understanding the data sources that go into it is essential. More than just meeting compliance requirements; it's about setting your organization up for long-term success and efficiency. What gets measured gets improved, and when you take the time to understand all the factors at play, you will be well informed to make a decision about your flaring operations.
Data submissions for re-benchmarking are normally due September 1, however, the AEP has stated in their public webinars that they will be accepting third-party verified submissions for the updated flaring FSBs up until December 1st for this year only. Submissions will be made using the new (yet to be released) multi-year TIER aggregate forms, which will be available on their website following the engagement period ending July 17.