Measurement & Evaluation
Internal Approach
We assess this based on a framework of measurement, reporting and adjustment, including the following:
- A comprehensive climate and environmental risk matrix analysis
- Key performance indicators on environmental stewardship that we monitor monthly and report on annually
- Technology and process assessments, conducting operational and engineering reviews aimed at increasing efficiency, and reducing the emissions and expenditure requirements at major facilities
- Anticipated and actual legislative and regulatory change assessments, with potential impacts, and
- Emissions Long-Range Planning tool
External Approach — Regulatory Reporting Framework
The following table illustrates the significant reporting and regulatory bodies under which we operate:
Business Unit | Reporting Body | 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.
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All Business Units | Montreal Protocol | We have phased out Freon-22 in our C3 cooling plants in Netherlands to reduce the risk that this substance could be released. |
Canada | 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.
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Canada | 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 |
Canada | 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
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Canada
| 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. |
Europe | 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. |
France | Register and the Annual Reporting of Emissions and Transfers of Pollutants and Waste
| We report operations water, waste and greenhouse gas (GHG) information annually.
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France | 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 | 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%. |
Australia | 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.
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United States
| 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.
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