We assess this based on a framework of measurement, reporting and adjustment, including the following:
External Approach — Regulatory Reporting Framework
The following table illustrates the significant reporting and regulatory bodies under which we operate:
Reporting and Action Activities
All Business Units
CDP Climate Change and CDP Water Security
We initiated reporting under CDP Climate in 2014 with a base year of 2012, and CDP Water in 2020 with a base year of 2019.
All Business Units
We have phased out Freon-22 in our C3 cooling plants in Netherlands to reduce the risk that this substance could be released.
Greenhouse Gas Reporting and National Pollutant Release Inventory reporting under the Canadian Environmental Protection Act
Federal Greenhouse gas reporting regulated by Environment and Climate Change Canada for facilities over 10,000 tonnes CO2e per year. Vermilion has around 10 facilities reporting into this regulation, dependant on facility production and activity levels.
Greenhouse Gas Pollution Pricing Act
Vermilion has opted-in to both the Alberta TIER program and to the Saskatchewan Carbon Tax output-based pricing system, which directly interact with the Federal GGPPA
Alberta’s Directive 060 Methane Regulations
Regulation aimed at reducing vented emissions from process equipment, tanks, and other field related sources, also requiring upgrades to low or no emission process equipment. Fugitive emission leaks are also addressed in this regulation for all production.
Alberta’s Directive 039
Regulation directed at reducing and eliminating the release of benzene emissions from glycol dehydrators
Alberta’s Environmental Protection and Enhancement Act
Regulates large facilities under a formal approval process, and outlines requirements for conservation, water management, substance release, and waste management
Saskatchewan’s Directive PNG036 & PNG-017
Formerly Directive S-10, this provides regulatory requirements for reducing flaring, incinerating and venting of associated gas, including financial penalties for methane emissions in excess of defined limits.
European Union Emissions Trading Scheme
Our European operations fall under the European Union Emissions Trading Scheme; however, due to the size of our facilities we exceed the reporting threshold (total thermal rated input capacity greater than 20MW), only in Ireland. Under the revised EU ETS Directive in effect 2021-2030, it is anticipated that there will be an active market and consumers for the offset credits generated at some of Vermilion’s sustainability initiatives around the world. This upcoming shift in the cap and trade scheme may provide opportunities for Vermilion to generate certified energy reduction/offset credits through our activities related to renewable energy.
Register and the Annual Reporting of Emissions and Transfers of Pollutants and Waste
We report operations water, waste and greenhouse gas (GHG) information annually.
Agreement to End Routine Flaring by 2030
Projects are being identified on an ongoing basis that will result in increased operational efficiency and a reduction in methane and VOCs once implemented.
Netherlands Long-term Agreements with Industry (MJA3)
We reported operations energy efficiency and emissions information annually. Vermilion participated in the MJA3 program in our Netherlands business unit while it was in effect, resulting in project and initiatives that have reduced our operations energy intensity by 75.7%.
National Greenhouse and Energy Reporting Act (2007)
We report under the robust emissions accounting required by this Act, and have examined three potential carbon taxation pricing scenarios and budgeted the costs associated with compliance. No carbon tax applies to Australian production at this time.
Environmental Protection Act (EPA)
Vermilion’s United States operations comply with the EPA requirements associated with stationary engines and holds permits to operate which includes emissions testing, inspections and triennial reporting requirements across our operation.