Got approval from EHP for my CSG development, whew! Hang on, what on Earth am I going to do with these oddball conditions?
This was the conundrum that Katestone’s Principal Consultant Air Quality, Natalie Shaw, explored with gas industry participants at the firm’s seminar, ‘CSG and the Air Environment – from Approval to Compliance’ held July 31, 2013.
Nat shared what she had learned from meeting with Environment and Heritage Protection (EHP) department representatives in preparing her talk.
“Under the new Greentape Reduction regime, if a company indicates that it can meet a draft condition, EHP will accept a company’s word and will not challenge the company’s ability to meet the condition,” Natalie said.
The rapid growth of the gas industry hasn’t made it easy for the regulations to keep up. The onus rests with proponents to negotiate viable and reasonable conditions. “What’s more, there are no standard conditions yet for activities that release emissions to air for the petroleum industry under Greentape Reduction”, Natalie said. Some of the vexing requirements that Nat dug up in her research included:
- Monitoring stack emissions apparently for the sake of monitoring, with no release limits for comparison
- Having to redo modelling if monitoring shows that original modelling under-predicted actual concentrations, even by a negligible amount
- Annual monitoring of an auxiliary generator, that is not intended to be used
- Unclear actions like applying “pro-active and reactive” mitigation and management measures
“Not only are some conditions nonsensical, but the number and complexity of recent conditions is inconsistent among similar facilities,” Natalie said. Nat’s research found that three similar, recently approved CSG plants received 13, 23 and 36 air conditions respectively. “We’ve estimated that the cost for these facilities to comply with their air conditions would range from $6000 a year for one facility, to as much as $455,000 up front and $80,000 per year for another,” Natalie said. The research suggests that companies can de-risk projects and remove recurrent costs if they have the nous to attend to the detail of environmental conditions and, in some cases, partly renegotiate them.
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