The Government of Alberta made recent amendments to the TIER Regulation, effective January 1, 2023, with implications for both new and existing aggregates in the 2023 compliance year.
Key TIER amendments & important deadlines
The changes introduced in these amended regulations are as follows:
- Emission scope: The inclusion of flaring emissions in the category of regulated emissions for aggregate oil and gas facilities.
- Opt-In threshold: The adjustment of the opt-in threshold for emissions-intensive and trade-exposed industries to 2,000 tonnes CO2e/year.
While the TIER Conventional Oil and Gas website specifies that applications are due by September 1, 2023, we have received confirmation that the Government of Alberta will continue to accept applications until December 1, 2023. Additionally, the deadline to add facilities to existing aggregates or create new aggregate facilities for 2023 compliance is November 15, 2023.
What this means for operators
These changes may significantly impact compliance obligations and offer additional optionality, beginning with the 2023 compliance year. Our team of regulatory experts strongly encourages operators, the "person responsible" for an aggregate, to evaluate the materiality of these impacts and to adopt an optimized approach to TIER compliance.
How Validere can help
In response to these regulatory amendments, we have been diligently assisting many of our clients in leveraging mechanisms established by the Government of Alberta. This includes requests for a review of facility-specific benchmarks for 2023, such as re-assessments of benchmark units, benchmarks themselves, and benchmark reference years.
Through these assessments, our clients have realized significant compliance cost avoidances exceeding $100,000 annually, all while ensuring maximum coverage under the Federal Fuel Charge.
To aid our clients, as well as those committed to complying with the TIER Regulation, Validere is offering a TIER Compliance Strategy Optimization service. This service not only evaluates the impact of recent regulatory changes but also employs modeling techniques to identify strategies that minimize compliance costs while aligning with the overarching principles of the regulation.
Contact us to learn more.
Corey Wood is the VP, Emissions, Regulatory & Carbon Strategy at Validere and an industry leader in regulatory compliance for the upstream oil and gas industry. His experience and thorough understanding of the regulatory landscape forms a unique perspective of how challenges related to emission limits, reduction targets and costs on carbon intertwine and cascade across all departments of an organization.
