TIER Aggregate Reporting & Webinar Update Summary

This year, the industry engaged in a 30-day discussion period to assess the potential inclusion of flaring emissions methodology proposed by the AEP. As a result of these discussions, changes were made to Chapter 15 of the AQM, specifically in section 15.3.

On September 15th, the AEP conducted a webinar to provide detailed information about the recent changes to the AQM and the benchmarking process. Below is a summary of the key highlights from the webinar.

Changes to Chapter 15:

1. New Flaring Emission Methodologies:

1. 1. Method 15-11 (CO2 and CH4 Flaring Emissions with Default Factors): Relies on default emission factors based on pre-selected flaring gas compositions (sales gas, rich gas, acid gas) and considers three default flaring efficiencies: 98% for unassisted flaring, 99.5% for assisted flaring, and 100% for incinerators.
   2. Method 15-12 (CO2 and CH4 Flaring Emissions with Gas Analysis): This method requires a minimum requirement that the flared gas stream must measure 60% of the total flared gas volumes. It is suitable for multiple flare streams with variable compositions. Like Method 15-11, it also has three default flaring efficiencies. It's important to note that, as of now, industrial-specific efficiencies are not permitted.
   3. Method 15-13 (N2O Flaring Emissions): This method assumes independence of flare combustion efficiencies and dependence on flare gas type when calculating N2O flaring emissions.
2.  Inclusion of Emission Factor for Acid gas and N2O
3. Shift from Monthly to Quarterly Sampling requirements for flares. If no samples are available for the benchmark years, you should use the sales gas emission factor for benchmarking purposes.
4. A revised Facility Specific Benchmark application form that accommodates multiple years has been made available on the TIER website.

Benchmark Application Form Changes:

1. New Columns for Flaring in Section B1 of the facility Specific Benchmark form.
2. The facility Specific benchmark application form has been updated to accept data from multiple years.
3. Flaring Section (Section B3) added to the facility specific benchmark form. This section is designed to collect information on emissions by gas and flaring technology.
4. Benchmark unit assessment is simplified with a focus on correlation coefficients.
5. A dedicated section for justification has been added to the Aggregate Facility Benchmark Unit request form and the Aggregate Facility Reference Years notification form. This allows emitters to provide context and reasoning for their benchmark unit selections and reference years.

Benchmark Tightening Rate:

Reduction targets for 2023 include a 12% reduction in stationary fuel combustion emissions and a 10% reduction in flaring emissions, with 2% annual tightening rates.

Things to consider when submitting a benchmark.

1. GWPs (Global Warming Potentials) for Methane and N2O have changed for 2023 onwards, leading to adjustments in previously reported SFC (Stationary Fuel Combustion) emissions to ensure fair comparisons.
2. In some cases, flaring emissions may not be relevant to a facility's production accounting metrics. In such situations, it is possible to exclude flaring emissions from the analysis. This ensures that the benchmarking process is tailored to the specific needs of the facility. The AEP does want emitters to try to include the flaring emissions because the correlation analysis should be done for the total regulatory emissions first and then if emitters find reasons not to include the flaring then the correlation coefficient for the SFC and flaring need to be provided separately.
3. The 2023 approved aggregate list must be used and applied to all baseline years. The deadline for submitting the aggregate list is November 15, 2023, but industry is recommended to submit this list earlier, if possible, to ensure time to complete the benchmark application and calculations.
4. If companies choose to not calculate and submit a benchmark application, AEP will assign a facility specific benchmark based on data available from Petrinex and the Director’s default. The Director’s default is to use the TIER Rich Gas composition and a flare efficiency of 98% applied to all flare volumes.

Verification of Facility Specific Benchmark Applications:

• Application must include all Stationary Fuel Combustion and Flaring emissions for the benchmark years.
• Any reconciliation and correction in Petrinex must be included in the benchmark application.
• Verification is mandatory for all new data that has not been previously verified.
• If a benchmark submission is done, then the benchmark application needs to be verified.

Application Deadlines for 2023:

• November 15th, 2023, for adding facilities to an existing aggregate for 2023 or creating a new aggregate facility for 2023.
• December 1^st, 2023, for volumetric data (Including Flaring) submission to inform the 2023 Facility Specific Benchmark. Aggregate facilities can make other changes to their FSB as part of the December 1^st submission for example, change methodologies, removal of a facility from an existing aggregate facility or revocation for 2024, changing benchmark unit.

New Process: 

TEIR Aggregate ID and Person Responsible will be added to the Petrinex database for transparency. Industry will not provide these IDs to Petrinex; the AEP will share them directly.

We strongly encourage you to provide your feedback and contact us with any questions on how you may be affected by the proposed changes.

Related:

Alberta greenhouse gas quantification methodologies. Version 2