Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations

The Canadian Association of Physicians for the Environment (CAPE) submitted comments on May 27, 2018, regarding the Alberta Energy Regulator's (AER) Draft Directive 060 and Directive 017. CAPE argues that Alberta's proposed methane regulations are generally less stringent and less enforceable than federal regulations, potentially leading to higher emissions and associated public health risks from co-pollutants.

• CAPE asserts that Alberta's Draft Directive 60 is generally less stringent and less enforceable than federal methane regulations, which could result in increased methane releases from the oil and gas sector via venting and leaking.
• The document highlights significant discrepancies in emission limits: Directive 60 allows up to 900 cubic meters of methane per day for combined venting and flaring, which is 4.5 times the annual venting limit of 15,000 cubic meters set by federal regulations.
• While methane itself is not typically harmful to human health except in confined spaces, the co-pollutants found in natural gas—such as hydrogen sulphide (H2S), volatile organic compounds (VOCs), and the BTEX family (benzene, toluene, ethyl-benzene, and xylene)—pose serious health risks, including cancer and respiratory issues.
• Evidence suggests that actual methane emissions from Alberta's upstream oil and gas sector are significantly higher than reported or estimated. In the Lloydminster region, airborne measurements were 3 to 5 times greater than inventory estimates.
• A 2017 study by Ramboll Environ estimated that upstream oil and gas facilities in Central Alberta contributed substantial portions of regional air pollutants in 2010, including 47% of nitrogen oxides (567 tonnes/day), 61% of total organic gases (757 tonnes/day), and 48% of VOCs (332 tonnes/day).
• CAPE recommends that Alberta adopt a new 2014 baseline for methane emissions that reflects current research, establish standardized monitoring, and make results publicly accessible to address measurement uncertainties.

APA

Canadian Association of Physicians for the Environment (2018). Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations. https://cape.ca/wp-content/uploads/2018/05/CAPE-Methane-AB-May-27.pdf#new_tab

Chicago

Canadian Association of Physicians for the Environment. Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations. 2018. https://cape.ca/wp-content/uploads/2018/05/CAPE-Methane-AB-May-27.pdf#new_tab.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations |date=27 May 2018 |url=https://cape.ca/wp-content/uploads/2018/05/CAPE-Methane-AB-May-27.pdf#new_tab |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2018comments, author = {{Canadian Association of Physicians for the Environment}}, title = {{Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2018}, month = may, url = {https://cape.ca/wp-content/uploads/2018/05/CAPE-Methane-AB-May-27.pdf#new_tab}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }