By: Nigel Bankes
Document Commented On: Draft Quantification Protocol for CO2 Capture and Permanent Geologic Sequestration v2.0, November 1, 2024
PDF Version: The Draft Alberta Quantification Protocol for CO2 Capture and Permanent Geologic Sequestration, Version 2
Nearly ten years ago I posted an ABlawg comment on a draft of the first version of this Offset Quantification Protocol. The Quantification Protocol (QP) was developed at that time so as to be ready for when Shell’s Quest Project came on stream. A QP is designed to establish the circumstances under which a project, in this case a carbon capture and storage (CCS) project, might generate offset credits under Alberta’s CO2 emissions legislation and regulations, which could then be used to meet the compliance obligations of a regulated emitter. At that time, the relevant regulation was the Specified Gas Emitter Regulation, Alta Reg 139/2007 (SGER); the current regulation is the Technology Innovation and Emissions Reduction Regulation, Alta Reg 133/2019 (TIER Regulation). My earlier post identified a number of issues that remain pertinent today, including the transparency of the process, issues of liability in the event of a reversal, and a question as to the apportionment of regulatory responsibilities between the mechanisms of the QP and the responsibility of the energy regulator (then the Energy Resources Conservation Board, now the Alberta Energy Regulator (AER)) for scheme approvals for injection activities. This latter point continues to present some difficulties in the current draft of Version 2.0, particularly with respect to monitoring for containment assurance, which is explicitly dealt with in s 5.1.6 and Appendix C of the Draft QP (but also relevant to the sections of the QP dealing with reversals). I explore these issues in more detail below.