Summary of comments on the draft agreement and draft order with Saskatchewan on the methane regulations
Official title: Report of comments and responses on the proposed Agreement on the equivalency of federal and Saskatchewan regulations respecting the release of methane from the oil and gas sector in Saskatchewan, 2025 and proposed Order declaring that the provisions of the regulations respecting reduction in the release of methane and certain volatile organic compounds (upstream oil and gas sector) do not apply in Saskatchewan.
The proposed Order declaring that the provisions of the Regulations respecting reduction in the release of methane and certain volatile organic compounds (upstream oil and gas sector) do not apply in Saskatchewan (the proposed Order), and the notice of availability of the Agreement on the equivalency of federal and Saskatchewan regulations respecting the release of methane from the oil and gas Sector in Saskatchewan, 2025 (the notice) were published on July 6, 2024, in the Canada Gazette, Part I. Both the proposed Order and the notice were published for a 60-day public comment period.
3 comments were submitted to Environment and Climate Change Canada.
A summary of comments and responses is included below, organized by topic.
Topic |
Content summary |
Response |
|---|---|---|
Support for equivalency agreement |
An expression of support for the equivalency agreement with Saskatchewan respecting the federal methane regulations was made. |
Under the Canadian Environmental Protection Act, 1999 (CEPA), the federal government may enter into equivalency agreements with provinces, when the conditions under section 10 of CEPA are met and where there are equivalent or better environmental outcomes. |
Public access to information |
Information related to clause 3.2 of the equivalency agreement should be publicly accessible. Information related to clause 3.3 of the equivalency agreement as well as information related to methodology, analysis undertaken, and results of emission reductions including direct measurements of oil facility methane emissions should be publicly accessible. Information related to measurement studies of methane emissions from province’s oil and gas facilities that are federally and or provincially funded and or supported should be publicly accessible. |
Saskatchewan publishes detailed information related to methane emissions from oil facilities. Under clause 3.3, Saskatchewan publishes on its website an annual report, which it produces under its regulations. At a minimum, this report includes actual and potential emissions for oil facilities in Saskatchewan. This information allows Environment and Climate Change Canada to assess the implementation and effectiveness of the province’s regulations to reduce methane. Environment and Climate Change Canada recognizes the importance of reporting, and will continue to work with the provinces on improving public access to information. Environment and Climate Change Canada is committed to the principle of open science, as expressed in our Science Strategy. When the department conducts or supports studies related to methane emissions, it will make efforts to ensure these studies are made available, where feasible if not publicly available through research journals. |
Enhanced opportunities for stakeholder involvement in policy development |
Saskatchewan to provide public notice of any proposed provisions to methane regulations. |
Environment and Climate Change Canada is committed to open and transparent approaches to policy and regulatory development. Draft federal regulations are posted in the Canada Gazette for public comment, and extensive engagement and consultation are undertaken. Saskatchewan also posts information about regulatory and policy changes on their public website. |
| Enhanced public engagement | The Government of Canada should provide an opportunity for the public to comment on proposed revisions to equivalency agreements as well as during Environment and Climate Change Canada’s annual review of equivalency agreements. | In accordance with CEPA, once the proposed equivalency agreement has been published, the public is invited to provide feedback during the 60-day comment period. During the annual review, Environment and Climate Change Canada reviews the information provided by Saskatchewan under the Agreement. This information includes Saskatchewan's annual report as well as other publicly available information. Stakeholders are invited to share their observations on the annual reports with the Government of Canada. |
Topic |
Content summary |
Response |
|---|---|---|
Modelling and data improvements |
The provincial regulations should be evaluated using the best available, real data while continuing to improve on model methodology. |
To determine equivalent emissions outcomes, the federal government completes an emissions assessment using the same modelling methodology for both the federal and provincial regulations. This approach involves developing detailed bottom-up emissions estimates for both sets of regulations and comparing them with Canada’s emissions baseline. For the proposed equivalency agreement, Canada’s GHG and Air Pollutant Projections: 2022, was used as the baseline for the purpose of comparing the emissions reductions resulting from the application of the provincial and federal provisions. The department is continually improving methane emission estimation techniques and considers any new, available and robust information to inform the data quality. |