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Cabinet Confidential

Responding to the Recommendations of the Scientific

Review of Hydraulic Fracturing Panel Report

ACTION PLAN

December 2019

1 Cabinet Confidential


FOREWORD

In 2018, the provincial government commissioned a three-member scientific panel to conduct an

independent Scientific Review of Hydraulic Fracturing (SRHF) in British Columbia to understand the role

of hydraulic fracturing as it relates to induced seismicity, fugitive emissions and its impacts on water

quantity and quality. In addition to the scientific review, the panel was tasked to address the following

two questions:

1. Does BC’s regulatory framework adequately manage for potential risks or impacts to

safety and the environment that may result from the practice of hydraulic fracturing?

2. How could BC’s regulatory framework be improved to better manage safety risks, risk of

induced seismicity, and potential impacts to water?

Throughout 2018, in more than 50 panel sessions, the scientific panel met with over 60 experts

representing: scientific researchers, industry and industry associations, Indigenous peoples, the

regulator, all levels of government, and environmental non-government organizations to gather

information about the state of knowledge on hydraulic fracturing in British Columbia. In writing its

report the panel considered all evidence provided in panel sessions as well as various published and

unpublished scientific literature from a broad variety of sources.

The scientific panel submitted its final report, Scientific Review of Hydraulic Fracturing in

British Columbia1, to the Honourable Michelle Mungall, Minister of Energy, Mines and Petroleum

Resources, on February 20, 2019. The panel concluded that with respect to the first question, “the

current regulations under many acts appear to be robust.” With respect to the second question, it was

the panel’s opinion that research is needed to support the responsible development of British

Columbia’s shale gas resources and that uncertainties regarding impacts can be reduced through

coordinated research focused on the unique British Columbia context.

Since the report was tabled in February 2019, government has undertaken a thorough review of the

report and its recommendations with a view to identifying opportunities for improvement in

environmental management tools and processes and in the existing regulatory framework governing

hydraulic fracturing. In June 2019, the government publicly identified a number of early actions in

response to the report (IB June 27, 2019)2 and committed to deliver a detailed long-term action plan to

the Minister in December 2019. This Action Plan is the fulfillment of that commitment.

1 The scientific panel’s report is available at: www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/natural-gas-oil/responsible-oil-gas-development/scientific_hydraulic_fracturing_review_panel_final_report.pdf

2 Information Bulletin from June 27, 2019 available at: https://news.gov.bc.ca/releases/2019EMPR0027-001344

http://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/natural-gas-oil/responsible-oil-gas-development/scientific_hydraulic_fracturing_review_panel_final_report.pdf



https://news.gov.bc.ca/releases/2019EMPR0027-001344


CONTENTS FOREWORD.................................................................................................................................................. 2

INTRODUCTION ........................................................................................................................................... 5

SECTION 1: TOPIC AREAS ........................................................................................................................... 5

Water Quantity ............................................................................................................................................ 5

Status/Recent Actions ............................................................................................................................. 6

Action Plan ............................................................................................................................................... 6

Water Quality ............................................................................................................................................... 7


Action Plan ............................................................................................................................................... 9

Induced Seismicity ...................................................................................................................................... 9


Action Plan ............................................................................................................................................. 10

Fugitive Emissions .................................................................................................................................... 11

Status/Recent Actions ........................................................................................................................... 11

Action Plan ............................................................................................................................................. 14

Other Topics............................................................................................................................................... 14

Health ..................................................................................................................................................... 14

Orphan Wells ......................................................................................................................................... 15

Cumulative Effects and First Nations ................................................................................................... 16

Action Plan ............................................................................................................................................. 17

SECTION 2: COLLABORATING FOR CONTINUOUS IMPROVEMENT ..................................................... 17

Baseline Data and Monitoring .................................................................................................................. 17

Background Discussion ......................................................................................................................... 17

Action Plan ............................................................................................................................................. 19

Strategic Research Partnerships .............................................................................................................. 19


Action Plan ............................................................................................................................................. 21

SECTION 3: COMMUNICATION AND INFORMATION SHARING ............................................................ 21


Action Plan ............................................................................................................................................. 22

SECTION 4: SUMMARY OF ACTIONS ....................................................................................................... 22

Table 1: Summary Table of Actions ........................................................................................................ 22



INTRODUCTION

Government is responding to the recommendations in the February 2019 report, Scientific Review of

Hydraulic Fracturing in British Columbia (Panel report) with a detailed Action Plan. The Panel report

fulfilled the independent scientific panel’s mandate to conduct a scientific review and report back to

government with its recommendations and advice. The panel determined that the regulatory

framework around hydraulic fracturing appears to be robust and throughout its report made

recommendations specific to each topic that was reviewed. The recommendations in the Panel report

are varied and in some cases are not precise, providing general advice that requires more thought and

research prior to identifying specific actions.

In responding to the recommendations in the Panel report, it should be noted that many of the

recommended improvements were underway at the time of the panel review or have since been

undertaken. The Action Plan identifies those areas where additional work would produce results aligned

with the Panel report recommendations and government policy.

The Panel report is organized under the topic areas of water quantity, water quality, induced seismicity,

fugitive emissions and a grouping of other topics. Section 1 of this Action Plan aligns with these topic

areas and begins each topic with a brief overview of the key Panel report findings and

recommendations. Following on this is a summary of recent government actions taken in this area and

then actions government is taking going forward.

Section 2 provides information on two planned enhancements of existing initiatives: enhancing baseline

monitoring and building on BC’s strategic research partnerships.

Section 3 acknowledges the recommendations that speak to building public trust and the need for

better transparency, communication and information sharing, and provides actions to address this

challenge. Section 4 concludes with a summary of all the actions found in this Action Plan.

Throughout this Action Plan, for the reader’s reference, actions taken or planned are linked to the

corresponding recommendation in the Panel report by notation of ‘SRHF’ and the page number where

the recommendation can be found in the report.

SECTION 1: TOPIC AREAS

Water Quantity

In its report, the panel discussed baseline water quantity data and examined risks to water quantity

under three topics: water use; the storage of water on land for use in hydraulic fracturing (i.e., dugouts,

dams); and wastewater disposal.

The Panel report acknowledged and affirmed recommendations from previous works that identified the

need for baseline monitoring of surface and groundwater quantity and quality along with climate data.

Baseline monitoring was identified as being necessary for detecting trends and setting guidelines for

identifying resource development–related impacts. Conversely the lack of data was seen as an

impediment to sustainable water management in Northeast BC (SRHF p. 37).


Regarding water use, the Panel report noted that the need for fresh water and fresh water storage

appears to be on the decline as operators are increasing the reuse of produced and flowback water

given advances in fluid technology. The report provided recommendations relating to how to improve

permitting processes, ensuring that adequate and appropriate data and water management tools are

used in decision making and, ensuring regulatory effectiveness.

The Panel report recognized that historical concerns regarding the permitting of water storage dams had

been corrected and the requirements for constructing dams for fresh water storage for oil and gas

activities are clearly described in the BC Oil and Gas Commission’s (Commission) Oil and Gas Activity

Application Manual (SRHF p.67). Recommendations relating to fresh water storage stressed assurance

of clarity in regulatory responsibility between agencies, transparent and effective compliance and

enforcement and, proper decommissioning of dams and structures.

Finally, capacity for wastewater disposal was raised as a concern. The Panel report recommended short

and long-term planning for future needs and inventory of current wastewater disposal amounts as well

as addressing policy and process gaps for management.

Status/Recent Actions In June 2019, the Commission initiated a project to install hydrometric stations in priority watersheds to

address data gaps regarding water quantity (SRHF pp. 36-37). The Commission is also working with

three Treaty 8 First Nations to establish stations for the collection of streamflow data over a two-year

period (SRHF pp. 37-38). Streamflow data will be integrated into the hydrometric network to inform

future water allocation and watershed management decisions in Northeast BC. In addition to the work

of the Commission, the Province continues to work with the federal government on continued

installation and maintenance of hydrometric stations with real-time data sharing.

The Commission has also updated its technical guidance manual, Supplementary Information for Water

Source Wells, to clarify that hydrogeological assessments must be overseen by a qualified professional

with competency in hydrogeology, consistent with the requirements of the BC Engineers and

Geoscientists Act (S.22) (SRHF p. 59).

Recommendations related to water quantity research and data collection will be advanced through

enhanced baseline monitoring and strategic research partnerships as discussed in Section 2 of this

document. In addition to recent actions noted above, government commits to the actions outlined

below in response to the Panel report’s recommendations on water quantity.

Action Plan

In response to the recommendations of the Panel report, the following actions will be implemented:

1.1. Identify and advance next steps to require water use reporting of water sales on private land

(SRHF p. 58) (FLNR3).

3 FLNR is the Ministry of Forests, Lands, Natural Resource Operations and Rural Development

Action Area #1

Improve regulatory and policy tools for water quantity management.


1.2. Ensure that the outreach and education initiative to landowners with dams continues and is

expanded as resources are available (SRHF p. 59) (FLNR).

1.3. Improve transparency by ensuring timely publication of quarterly water use reports

(SRHF p. 59) (Commission).

1.4. Develop a mechanism for tracking alternative fluid use and the reuse and recycling of fluids for

hydraulic fracturing (SRHF p. 59) (Commission).

1.5. Assess further options, including regulations, to advance hydraulic fracturing water reuse and

recycling (SRHF p. 59) (EMPR4, Commission).

1.6. Review industry-submitted data with respect to water use, to track water use and ensure

compliance with license-specific conditions. The Commission will engage their External Audit

team to undertake audits of submitted data (SRHF p. 60) (Commission).

1.7. Complete a progress report on the Mattison recommendations 5(SRHF p. 60) (FLNR).

1.8. Ensure the dams and dugouts spatial layering through the Commission’s website and BC data

catalogue are up-to-date and publicly available (SRHF p. 68) (Commission).

1.9. Advance work initiated on requirements for decommissioning and reclamation plans to be

submitted for large fresh water storage dams for oil and gas activity. Ensure that the

Commission’s Comprehensive Liability Management Plan accounts for all oil and gas

infrastructure, including dams, to ensure restoration costs are born by industry (SRHF p. 68)

(Commission).

Water Quality

The panel in its report examined baseline water quality data and threats to water quality from three

sources: direct pathways from the deep subsurface; handling and storage of flowback water; and

wastewater disposal wells. The panel also reviewed the topic of naturally occurring radioactive material

(NORM).

The Panel report found that regional baseline studies on surface water quality were lacking for

Northeast BC and recommended that long-term surface water quality monitoring sites be established to

examine trends related not only to potential impacts from the oil and gas industry, but from other

industries, agriculture and notably climate change (SRHF p. 81). Surface water quality sampling was

recommended for five priority watersheds as was an increase in the water quality sampling frequency

(SRHF p. 81).

The Panel report included a recommendation for more research and analysis on the potential for

vertical fluid migration; enhanced monitoring around sites where hydraulic fracturing fluids, flowback

and produced water are handled or stored; geochemical modelling to examine transport and fate of

contaminants; and reporting of spills. Also included were recommendations on managing wastewater

disposal and more research on NORM.

4 EMPR is the Ministry of Energy, Mines and Petroleum Resources 5 Mattison, J.S., Report on Managing Dugouts in Northeast British Columbia, (2017), https://www2.gov.bc.ca/assets/gov/environment/air-land-water/water/dam-safety/dugouts_mattison_july_final.pdf.

https://www2.gov.bc.ca/assets/gov/environment/air-land-water/water/dam-safety/dugouts_mattison_july_final.pdf

https://www2.gov.bc.ca/assets/gov/environment/air-land-water/water/dam-safety/dugouts_mattison_july_final.pdf


Status/Recent Actions Several water research and data collection initiatives receiving Provincial support are presently

underway. One project led by the University of British Columbia’s (UBC's) Energy and Environment

Research Initiative (EERI) aligns with panel recommendations that groundwater monitoring wells be

placed in a diversity of hydrogeological settings, monitored for geochemistry and used to supplement

the Provincial Groundwater Observation Well Network (SRHF pp. 81-82). Other projects are being led

by researchers from academic institutions in BC and across Canada and in addition to government-led

water monitoring programs and initiatives. Once completed and synthesized, these projects will

collectively provide important information regarding water quality in Northeast BC in the context of oil

and gas development. Learnings from these existing initiatives will further provide a foundation for

moving forward with strategic focused research and baseline water monitoring in response to the

recommendations of the report. New data from monitoring can then be integrated into water use

decision-making tools.

The Province continues to work with the federal government and First Nations on water quality

sampling in lakes and streams and to advance the Canadian Aquatic Benthic Invertebrate Network

(CABIN). CABIN involves a Federal-Provincial collaboration to model cumulative effects from water

quality disturbance in bottom dwelling aquatic insects. CABIN has recently developed models for

Northeast BC in both the Liard and Peace Watersheds. All data is openly available to the public online.

The CABIN program addresses some of the panel recommendations about baseline, trends and

understanding cumulative effects (SRHF p. 81). In 2019, CABIN work in Northeast BC included:

• Ongoing partnering work with First Nations (Kaska Dena and Fort Nelson) to sample eight

reference sites to support maintenance of the Northeast BC CABIN Model.

• Sampling at eight reference sites in the Peace River drainage to support maintenance of the

Peace CABIN Model.

• Completing development of the Peace Model.

The Commission continued the independent stream health assessment program launched in 2017 to

evaluate the condition of specific streams in Northeast BC. This program followed the standard FREP

(Forest and Range Evaluation Program) riparian protocol, and over the last three years, the Commission

has evaluated 89 streams in several watersheds. This information will be used to validate the

Commission’s decision support tools.

In relation to water quality work, information sharing and disclosure have also improved by actioning

the recommendation to publish private well survey information as found on EcoCat6 (SRHF p. 82).

With respect to wastewater, the Province has considered the classification of hydraulic fracturing

wastewater as hazardous waste and determined the current definitions within Federal legislation to be

inclusive and robust. Hydraulic fracturing wastewater as hazardous waste is also appropriately included

6 EcoCat Ecological Reports Catalogue provides access to reports on ecological activities in British Columbia, plus

related files such as maps, datasets and published inventories and can be publicly accessed at

http://a100.gov.bc.ca/pub/acat/public/welcome.do

http://a100.gov.bc.ca/pub/acat/public/welcome.do


within the Environmental Management Act and covered under the Oil and Gas Waste Regulation (SRHF

p. 102).

Recommendations related to water quality research and data collection will be advanced through

enhanced baseline monitoring and strategic research partnerships as discussed in Section 2 of this

document. In addition to recent actions noted above, government commits to the actions outlined

below in response to the Panel report’s recommendations on water quality.

Action Plan


2.1. Collect and analyze samples of flowback water and establish a joint Commission/ENV7 working

group to address toxicity assessment and evaluate regulatory thresholds (SRHF p. 96)

(Commission, ENV).

2.2. Expand the Commission’s website mapping interface to include all reported spills in addition to

reporting incidents related to pipelines (SRHF p. 97) (Commission).

2.3. Review and assess regulatory policies for risk-based groundwater monitoring requirements for

oil and gas activities, with consideration of existing regulatory requirements and processes,

existing data, and insights gained from ongoing research (SRHF pp. 96, 102, 178) (Commission).

Induced Seismicity

Induced seismicity refers to seismic events caused by human actions. Hydraulic fracturing and

wastewater disposal are two oil and gas activities that under certain conditions can induce seismicity.

The panel in its report reviewed the history of induced seismic events in Northeast BC and then provided

a comprehensive overview of the state of knowledge on this topic. The Panel report reviewed and

discussed research on susceptibility to anomalous induced seismicity, seismic hazard assessment, ways

to mitigate induced seismicity and seismicity monitoring. The Panel report’s recommendations included

better data sharing, increasing research capacity, increased monitoring and opportunities to enhance

the regulatory and policy tools pertaining to induced seismicity.

Status/Recent Actions

Better Data Sharing and Increased Monitoring

The Commission in partnership with Natural Resources Canada (NRCAN), Geoscience BC (GBC) and BC

Oil and Gas Research and Innovation Society8 (BC OGRIS) have added 18 completely open data seismic

stations in Northeast BC since initiating this work in 2013. Through a partnership with BC Hydro, two

more open data stations were added in the summer of 2019. This has improved the availability of

7 ENV is the Ministry of Environment and Climate Change Strategy 8 BC OGRIS is a BC based not-for-profit society with membership from the Commission, Canadian Association of Petroleum Producers (CAPP), and The Explorers and Producers Association of Canada (EPAC).

Action Area #2

Improve regulatory and policy tools to ensure protection of water quality.


seismic data in Northeast BC from two stations to 20 stations. Additionally, through a partnership with

NRCAN and McGill University, a nine-station array was deployed in Northeast BC in 2017. To support

better data sharing, this data is streamed directly to McGill University for research purposes. All the

data collected will be available publicly at the end of McGill’s research period. NRCAN, the Commission

and McGill University are actively working towards funding to keep this array in place and to have all

data streamed openly, so that the regulator, industry and researchers will have direct, immediate data

access beginning in the summer of 2020. This work ties in with the need for further research with

additional data from denser network coverage (SRHF p. 122) by increasing the number of open data

stations in Northeast BC to 29 by the summer of 2020.

Through special project orders and permit conditions, the Commission requires accelerometers to be

deployed throughout the seismically active portions of the Montney trend. If there are significant

seismic events (felt events or measured accelerations above 0.8%g), the event data is then submitted

and published by the Commission via the Commission’s eLibrary, which is publicly accessible.

In addition, industry currently has approximately 75 stations through the Montney trend that oversee

both fracturing operations and disposal wells. The Commission is modeling the existing open data

coverage in Northeast BC and is exploring additional options to increase sensor density where

necessary. Sensor quality is an important consideration when contemplating seismic deployments. The

Commission has added, and continues to add, more sensors to address Induced Seismicity susceptibility

(SRHF p. 122), and this is an ongoing body of work.

Research Consortium

The Commission, together with the BC Seismic Research Consortium, has initiated work to develop a

guideline for standardized magnitude calculation and calculation of ground motion parameters

(SRHF p. 145). Currently NRCAN provides public facing data and its magnitude standardization is used.

It is acknowledged that there may be better methodologies and the Commission has initiated work in

this area by presenting to industry an initial magnitude calculation standard based upon the work

completed by Mahani and Kao (2018). The Canadian Association of Petroleum Producers (CAPP) has

formed a sub-committee to continue this work on magnitude standardization.

Additional research recommendations will be actioned through research partnerships discussed in

Section 2. In addition to recent actions noted above, government commits to the actions outlined

below in response to the Panel report’s recommendations on induced seismicity.

Action Plan


3.1. Launch the “Development of an Induced Seismicity Susceptibility Framework and Map for

Northeast BC using an Integrated Machine Learning and Mechanistic Validation Approach”

project through government funded Geoscience BC (GBC) (SRHF p. 122) (Commission, GBC).

Action Area #3

Enhance regulatory and policy tools to reduce the frequency of induced seismicity.


3.2. Engage with industry, partner agencies and academia to grant access to additional seismic

arrays for public consumption and revisit the current policy for accelerometer data (SRHF p.

122) (Commission).

3.3. Add the relevant induced seismicity components of the Kiskatinaw Seismic Monitoring and

Mitigation Area (KSMMA) special project order, including the pre-assessment requirement, to

the Drilling and Production Regulation with spatial boundaries that match the northern ground

motion monitoring area and the KSMMA special project order boundary (SRHF pp. 122, 129,

134) (Commission).

3.4. Review research on fault slip potential as well as pre-assessments received to date from

KSMMA special project order activities and create a template outlining the minimum content

required in a pre-assessment (SRHF pp. 122, 129, 134) (Commission).

3.5. Continually evaluate submitted pre-assessments after completion operations to assess the

validity of the information supplied and the mitigation outcomes (SRHF pp. 122, 129, 134)

(Commission).

3.6. Finalize a draft pre-assessment template and proposed regulatory enhancements.

(Commission)

3.7. Complete work to develop a guideline for standardized magnitude calculation and calculation

of ground motion parameters and have all event data posted to a public facing website using

optimal magnitude calculation (SRHF p. 145) (Commission).

Fugitive Emissions

Fugitive emissions are those emissions that occur when gases, primarily methane, leak from equipment

and facilities. Controlling fugitive emissions is important to reduce greenhouse gas (GHG) emissions and

to avoid impacts to air and groundwater quality. Two specific fugitive emissions sources were examined

in more detail in the Panel report: surface casing vent flow (SCVF) and gas migration. The Panel report

recommendations focused on the need for targeted research to address knowledge gaps in these areas

as well as for emissions data to be made publicly available, including detection, monitoring and

mitigation measures.

Status/Recent Actions

New Regulations

British Columbia has committed to reducing methane emissions from upstream oil and gas operations

by 45 percent by 2025, relative to 2014 levels. In addition, the federal government deposited the

Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds

(Upstream Oil and Gas Sector) outlining national commitments to reduce methane emissions by 45

percent by 2025.

As noted in the Panel report, in late 2018, the Province implemented regulatory changes to reduce methane emissions from the upstream oil and gas sector including regulations covering fugitive emissions. These changes are encompassed within amendments to the Drilling and Production Regulation and come into effect on January 1, 2020. The Province is currently pursuing an equivalency agreement with the federal government for its methane emission regulations.


Throughout 2019 the Province worked with the federal government to support federal modelling

exercises to determine an estimated emissions reduction impact from the BC regulations and created a

draft agreement that would acknowledge BC regulations as being equivalent to federal regulations.

Based on the federal estimates, the BC regulations result in cumulative emission reductions of 3.1 Mt

CO2e from 2020-2024, which exceeds the federal regulations (2.77 Mt CO2e). When modelled, the BC

regulations also achieved greater emission reductions than the federal regulations beyond 2024.

In order to obtain regulatory equivalency, the federal government requires that BC have a public

complaint mechanism. On June 17, 2019, BC Reg 134/19 (OIC 314) was deposited under the Oil and Gas

Activities Amendment Act 2018 and the Oil and Gas Activities Act. Effective January 1, 2020, it brings

the Oil and Gas Activities Act investigation provisions into force and makes up the Investigations

Regulation. This creates a citizen’s right to request investigation of methane emissions that are

suspected of occurring in contravention of the regulations.

A draft equivalency agreement and the modelling methodology were posted for comment in Canada

Gazette, Part 1 in March 2019 and subsequently in June 2019 a draft order-in-council package with a

regulatory impact assessment statement were posted for public comment. The Province and federal

government will continue to advance the equivalency agreement process into early 2020.

In 2019 the Commission further advanced work to update and develop guidelines for industry to comply

with the methane emission requirements of the Drilling and Production Regulation. These include:

• Fugitive Emission Management Program Guidelines finalized in July 2019 - clarifies regulatory

requirements and provides guidance for fugitive emissions management in BC.

• Leak Detection and Repair Data collection forms (currently in consultation). Work is also

underway with ENV’s Climate Action Secretariat to streamline methane emissions tracking and

reporting standards and minimize the need for additional reporting.

• Updated Flaring and Venting Reduction Guidelines (currently in consultation).

• Program to Reduce Benzene Emissions from Glycol Dehydrators and Annual Inventory Form.

Other Tools

Compliance and enforcement activities as well as inspections, monitoring and requirements to repair

SCVF and gas migration, ensure fugitive emissions associated with well integrity issues a well as other

sources are minimized. The Commission performed approximately 4,400 inspections in 2018 on oil and

gas infrastructure. Any leaks identified during inspections are noted and repaired.

The Province recognizes the importance of encouraging early action prior to methane regulations

coming into force and reducing emissions as soon as possible. To achieve early reductions the Province

advanced the Clean Growth Infrastructure Royalty Program in 2019, partnering with industry in

methane and other GHG emission reduction projects using royalty deductions. Projects under

development from this program (and from the two iterations of the previous program9) are expected to

significantly contribute to methane emission reductions. Additionally, in 2019 the Province launched

the CleanBC Industry Fund which has accepted methane reduction projects as part of the CleanBC

Industrial Incentive Program.

9 The Clean Infrastructure Royalty Credit Program approved projects for emission reductions in 2016 and 2018.


Surface Casing Vent Flows

SCVF comprise about one percent of upstream fugitive methane emissions. In 2019, regulatory

requirements were reviewed and updated by the Commission to require submission of all SCVF tests

conducted by permit holders (SRHF, p. 156).

The Commission has regulations and guidance in place requiring ongoing SCVF testing throughout the

life of a well. The Commission’s compliance and enforcement inspection program includes checking for

the presence of SCVFs, which when found, results in a requirement for the permit holder to conduct

follow-up testing and reporting. The Commission additionally has a program in place to verify industry-

submitted SCVF data. Data is now available via the Commission’s website (SRHF, p. 156).

Methane Emissions Research

In April 2019, the BC Oil & Gas Methane Emissions Research Collaborative (MERC), a joint initiative

between industry, government, the Commission and environmental non-governmental organizations,

was launched through a memorandum of understanding to advance research on methane emissions

from oil and gas activity.

Comprised of ENV, EMPR, the Commission, CAPP, the Explorers and Producers Association of Canada

(EPAC), GBC, and the Pembina Institute, MERC members work together to ensure that methane

emissions reductions initiatives are based on a solid foundation of science and research. A Technical

Advisory Committee of experts assesses the research needs, manages projects and provides

recommendations to a Steering Committee that oversees and guides the work of MERC.

MERC will investigate leading technology and identify best practices including those to address the

detection, measurement and repair of leaks in the natural gas sector with the goal to reduce fugitive

emissions. Data and information gained through research projects will be made publicly available.

Through the work of MERC, the Province will address knowledge gaps to help achieve a 45 per cent

reduction in methane emissions from upstream oil and gas operations by 2025.

New provincial regulations combined with the research initiatives of MERC are responsive to

recommendations of the Panel report (SRHF pp. 155-156).

In July 2019, the Commission conducted an annual aerial survey of 104 decommissioned gas wells east

of Fort Nelson and identified four well sites where methane was detected. Companies have been

directed to make repairs under the Drilling and Production Regulation. This is the third year the

Commission has undertaken this innovative leak detection method. The previous two surveys were

mainly focused on the Fort St. John area. The collected data will provide an updated and scientific basis

for continued regulatory and process enhancements related to well integrity.

Gas Migration Research

Gas migration occurs when fugitive emissions flow outside the surface casing of a well. The panel found

that in relation to gas migration that has been detected at the well head, BC’s oil and gas sector is

reasonably well regulated and that these regulations should be accompanied by enforcement and

transparency of data. The panel recommended that industry data regarding gas migration be made

publicly available, including detection, monitoring, and mitigation measures taken. The Commission is

currently assessing different methods of making this data available. Additional research was

recommended by the panel for gas migration that occurs away from the wellbore (SRHF p.165).


The Province is supporting research to better understand gas migration. UBC has established the EERI, a

research consortium supported by EMPR, the Commission and GBC amongst others. EERI operates a

multi-disciplinary field research station in the Peace Region of Northeast BC (Hudson’s Hope Field

Research Station mentioned on SRHF pp. 161-162), at which various controlled natural gas release

experiments are taking place. Through controlled gas release investigations, direct field observations of

fugitive gas migration impact and fate can be made, and various sensors and monitoring technologies

tested. EERI is also leading investigations which, through the installation of a regional scale

groundwater monitoring network across the Peace Region of Northeast BC, is working to increase

understanding of regional hydrogeology and to monitor groundwater quality against a backdrop of

historic and ongoing energy resource development. Additionally, EERI is performing geospatial data

investigations with respect to energy well construction and potential for gas migration. The research

initiatives through EERI address several recommendations of the Panel report (SRHF pp. 165-166).

In addition to recent actions noted above, government commits to the actions outlined below in

response to the Panel report’s recommendations on fugitive emissions.

Action Plan


4.1. Advance research through MERC and other opportunities. The results of this research will be

reviewed to consider approaches and directions for further targeted research priorities (see

research partnership section) (SRHF pp. 165-166) (Commission, EMPR, ENV).

4.2. Conduct a mid-point regulatory review of the methane emission reduction regulations to

ensure the Province is on track to reach a 45 percent reduction in methane emissions by 2025

(SRHF p. 156) (Commission, EMPR, ENV).

4.3. Complete a review of gas migration data submitted by industry and publish data in the

Commission’s existing data base (SRHF, p. 165) (Commission).

Other Topics Health Human health and the potential for human exposure were not included in the panel review’s terms of

reference. The panel, however, considered human health to be implicit in environmental impacts and

gathered input from experts in toxicology and public health to provide some advice on this topic in its

report. The Panel report noted that reducing exposure to chemicals is key to reducing risks to health

and advised that industry should be encouraged to use the least hazardous chemicals in hydraulic

fracturing and that discrete chemicals should be listed on FracFocus.

Robust regulations are in place to prevent the release of hazardous substances to the environment and

potential receptors. To further reduce the potential for exposure and health impacts in the event of a

release, all companies must report hydraulic fracturing fluid ingredients to the Commission and provide

Action Area #4

Advance research on leading leak detection technologies and identify best practices for reducing fugitive

emissions.


the information publicly through FracFocus. The disclosure of hydraulic fracturing fluid ingredients will

aid health authorities and health professionals in accessing information about fluid ingredients, without

compromising confidential business information. Moreover, industry is actively engaged in removing or

finding safer substitutions for the chemicals used in hydraulic fracturing.

Other advice from the panel related to health included changing thresholds for spill reporting and site-

specific requirements for groundwater monitoring (including baseline and pre-drilling testing). These

topics are discussed and actioned under the Water Quality section of the Action Plan. The panel also

raised the possibility of conducting a limited human health risk assessment (HHRA) on specific

chemicals. The panel recognized that a full HHRA would likely result in inconclusive results since from a

scientific perspective there are significant hindrances to conducting one (i.e., quantification of exposure,

point sample sizes, weak association).

While recognizing there is concern about potential impacts on health, results from enhanced baseline

monitoring and research is needed before the Province can determine further action on monitoring

activities and HHRAs - including contaminant sources, exposure pathways, and exposure doses to

human receptors. The potential impacts on health could be incorporated into the monitoring actions

described in Section 1 of the Action Plan with the comparison of surface water and groundwater quality

monitoring results to BC’s Source Drinking Water Quality Guidelines and air quality to BC’s Ambient Air

Quality Objectives. The Ministry of Health’s draft British Columbia Guidance for Prospective Human

Health Risk Assessment, which will be finalized in 2020, would be used to establish the HRRA

methodology in the case one is pursued.

Orphan Wells

An oil and gas site or well is given the designation “orphan” when the responsible oil and gas company is

declared bankrupt or cannot be located. As an orphan, site cleanup and restoration work can begin (or

continue) and is organized by the Commission and paid for out of the industry-funded Orphan Site

Reclamation Fund (OSRF). The Panel report raised concerns as to whether the Commission’s liability

management rating system and OSRF would be sufficient to cover future liabilities associated with

orphan sites. The panel recommended a transparent accounting of the potential liabilities, how

liabilities would be managed and consideration of including other major oil and gas infrastructure that

could likewise result in significant costs for reclamation and restoration.

In May 2019 the Commission launched a new Comprehensive Liability Management Plan (CLMP) that

holds industry accountable, addresses unrestored oil and gas sites and protects the environment and

public safety. Current legislation already allows for all permitted oil and gas infrastructure to be

designated as an orphan site if the permit holder is insolvent or cannot be located. The Commission’s

CLMP is designed to ensure that oil and gas restoration costs continue to be paid for by industry, not the

public. All permit holders in BC are evaluated for risk, and modernized methods are being employed to

evaluate corporate risk to the OSRF.

The CLMP includes mechanisms to modernize liability management and further evaluate the corporate

health of permit holders. This framework, coupled with the additional financial mitigation provided by

the orphan fund, ensures that industry, not the public, pays for oil and gas site restoration.


These actions respond to the Panel report recommendations in SRHF pp. 191-192. The CLMP has three

primary purposes: modernizing liability management; improving the rate of inactive site restoration; and

addressing orphan site treatment and closure.

1. The CLMP modernizes liability management to supplement its liability management programs

with additional tools that can more closely track and respond to oil and gas liabilities, evaluate

financial risk, and scale appropriate financial assurance instruments to mitigate liability risk.

2. CLMP improves the rate of inactive site restoration with the 2019 Dormancy and Shutdown

Regulation. The Regulation imposes timelines on the cleanup of dormant well sites, which are

wells and their associated operating areas that for five or more years have not met a certain

threshold of activity. This will reduce liability risk to the OSRF.

3. CLMP addresses orphan site treatment and closure through a new industry levy effective spring

2019. The Commission implements an orphan restoration program with expenditures of

approximately $15 million per year. This is designed to ensure that orphan sites are restored in

a timely manner, with immediate priority given to the protection of public safety and the

environment.

Cumulative Effects and First Nations In the Panel report, consideration of the impacts of oil and gas activities from a cumulative effects

perspective was deemed the most notable concern expressed by Treaty 8 First Nations. Further to this

the panel noted that Indigenous people had expressed a desire to be more involved in regional

environmental monitoring and compliance activities. Specifically, on the subject of cumulative effects,

the panel recognized the work of the Province and local First Nations in collaborating to address these

issues. The Province is actively working on the recommendations in the report that stress the

importance of continuing this work and leveraging it to directly inform oil and gas development in the

area (SRHF pp. 194, 195, 197).

Regional Strategic Environmental Assessment

The Province is currently working in collaboration with First Nations on cumulative effects through the

Regional Strategic Environmental Assessment (RSEA), an Environmental Stewardship Initiative which

includes Treaty 8 First Nations: Saulteau, Blueberry River, Doig River, Prophet River, Halfway River, West

Moberly, and McLeod Lake Indian Band.

The common goal of the RSEA agreement is to bring Treaty 8 First Nations together with the Province in

a shared understanding of the current and future state of the land base which may set the stage for

more collaborative and effective management in the future. The RSEA Project Team is expected to

deliver management response recommendations that optimize the meaningful exercise of Treaty 8

rights. The RSEA process for Northeast BC includes consideration of water quality and quantity, peaceful

enjoyment of the land, environmental livelihoods, wildlife values and old forest / forest diversity. This is

a long-term initiative that will run until 2022. The outputs of the RSEA will inform updates to the

Commission’s Area Based Analysis (ABA) tool (SRHF p. 195).

Land and Resource Management Plan (LRMP)

First Nations are playing an active role in planning land-based activities in Northeast BC. Government is

working in partnership with Blueberry River First Nations and other interested Treaty 8 First Nations to

update and amend the Fort St. John LRMP. Amending the Fort St. John LRMP will provide long-term


land management direction for all land users. For the Fort St. John LRMP, the intention is that work

from RSEA will feed directly into land planning.

Other Initiatives

The Commission has been engaging First Nations in orphan site reclamation planning and prioritizing.

Blueberry River First Nations and the Commission jointly developed a list of ten priority orphan sites for

restoration. Restoration work has advanced in regard to addressing orphan wells within Blueberry River

First Nations territory. Orphan restoration pilot projects are ongoing with Fort Nelson First Nation, Doig

River First Nation and Saulteau First Nations (SRHF p. 194).

Additionally, in the last two years the Commission has partnered with the University of Northern BC and

Vancouver Island University to offer three hands-on training programs in environmental monitoring field

techniques for Indigenous students in Northeast BC (SRHF p. 197).

Another program the Commission is continuing to support is the Natural Resource Aboriginal Liaison

Program (ALP). Aboriginal Liaisons work with agencies to monitor resource development and resulting

stewardship outcomes. Liaisons are assigned monitoring and inspection tasks including reporting their

observations and findings to their community and partner agencies. The ALP, initiated by the

Commission, has grown to include nine ALP agreements, 15 northern First Nations, and all the natural

resource agencies in three northern BC regions (SRHF p. 197).

In addition to recent actions noted above, government commits to the actions outlined below in

response to the Panel report’s recommendations.

Action Plan


5.1. Advance RSEA to inform decision making relating to oil and gas development (SRHF pp. 195-

196) (EMPR).

5.2. Engage with Treaty 8 First Nations in the LRMP process (FLNR).

5.3. Continue and expand Commission initiatives to enable Indigenous peoples to participate in

prioritizing and monitoring environmental values impacted by resource development (SRHF

p. 197) (Commission).

SECTION 2: COLLABORATING FOR CONTINUOUS IMPROVEMENT

Baseline Data and Monitoring Background Discussion A significant number of the recommendations and advice contained in the Panel report pertained to

enhancing the amount and utility of monitoring data and its public reporting (SRHF pp. 37-38, 60, 81-

82). Knowledge regarding baseline water quality and quantity characteristics and their variability in

Action Area #5

Continue to advance initiatives with Indigenous peoples that address cumulative impacts.


space and over time is important to support policy development and regulatory decisions related to

water allocation, site reclamation, site investigations and, compliance and enforcement. Effective

monitoring and reporting require coordination across all natural resource activities, and commitment

from multiple partners to ensure long-term delivery.

In 2015 the Northeast Water Strategy (NEWS) was launched to create a proactive, long-term approach

for the sustainable use and management of water resources in Northeast BC. One outcome of the

NEWS was that it created a partnership forum for information sharing and co-ordination of existing but

separate water stewardship efforts. The Panel report noted that the role of NEWS, to coordinate

projects and identify knowledge gaps related to baseline information and data, had become inactive.

The Province will explore which elements of NEWS may be valuable in continuing to support information

sharing and effective co-ordination of water stewardship initiatives.

The Province is exploring options to increase monitoring data and analysis and enhance the way

associated public reporting is done. While the Province has proven systems for baseline monitoring in

support of operations which are employed across British Columbia, enhancing baseline monitoring

would need to consider the unique data collection challenges and costs of the Northeast BC region and

leverage existing infrastructure, programs and projects already in place. Monitoring provides assurance

regarding the effectiveness of the regulatory framework at protecting water resources and provides

data to inform regulatory or policy enhancements as needed.

Enhanced baseline monitoring would address recommendations about water quantity (SRHF pp. 37-38),

calibration of hydrologic models and model comparison (SRHF p.60), and the cumulative effects on

water resources (SRHF p. 60). It would also provide an information base for understanding water

balance and total water resource flux in a watershed (SRHF p. 36) and include coordination with

traditional Indigenous knowledge (SRHF p.37). Actions for improving baseline monitoring would also

encourage increased coordination and collaboration with local Indigenous peoples to engage in

monitoring at mutually agreed upon locations.

As part of the implementation of the Water Sustainability Act, the Province has applied significant effort

to revise data management systems to ensure they are more user-friendly and seamlessly integrated.

This effort includes: third-party data agreements, improved interaction between systems such as wells

data and aquifer data, improved user interaction with wells data and better metadata, and

improvements to large data server systems like Aquarius and the Environmental Monitoring System

(EMS). There are also some supports in place to help First Nations transition and share their privately

acquired monitoring data on Provincial Data Servers. In addition, a new ability to ingest third-party data

provides an excellent platform to begin coordinating with industry to house and share some of their

relevant monitoring data.

The above improvements support the Panel report recommendations to ensure data management

systems are more robust and integrated and to have data available to support the expressed need of

Indigenous peoples to ensure environmentally sustainable ecosystems.

Building on current baseline water monitoring initiatives, government commits to the actions outlined

below in response to the Panel report’s recommendations.


Action Plan


6.1. Examine potential partnership structures, in consideration of previous successes and practical

limitations of the NEWS (SRHF pp. 37-38, 198, 200) (ENV, EMPR, FLNR, Commission).

6.2. Identify cost effective opportunities to enhance provincial monitoring programs that leverage

existing infrastructure, programs and projects (SRHF p. 37) (EMPR, ENV, FLNR, Commission).

6.3. Enhance opportunities for participation and input from Indigenous peoples in shared water

stewardship activities (SRHF pp.37, 56, 198). (EMPR, Commission, FLNR, ENV).

6.4. Improve data management systems by documenting and refining existing datasets (SRHF p.82)

(Commission, ENV).

6.5. Examine options for data amalgamation and communication (SRHF p. 82) and expand data

availability through industry and First Nations data sharing agreements (EMPR, ENV, FLNR,

Commission).

6.6. Examine and leverage potential funding opportunities through government initiatives such as

the Groundwater Science Fund, industry partners and non profits like GBC, water funders and

others (SRHF pp.198-200) (EMPR, ENV, FLNR, Commission).

Strategic Research Partnerships Background Discussion The Panel report cites a need for targeted research to address important knowledge gaps and concerns

regarding environmental impacts (SRHF pp. 36-37, 59-60, 71, 82, 89, 96-97, 102, 106-107, 122, 129, 134-

135, 144, 156, 165-166, 173, 183, 189, 198-200). These knowledge gaps focus on technical issues

around induced seismicity, water quantity, water quality and fugitive emissions.

In light of these findings, the panel brought forward the following recommendation:

A “[by] British Columbia for British Columbia” strategic research partnership would be well

placed to foster relationships between regulator, industry, First Nations, and the public.

Ultimately, best-practice regulations founded on a body of peer-reviewed science can be used

to inform the regulatory framework that protects the environment without unnecessarily

encumbering development, while providing confidence to the public that the province’s

resources are being developed responsibly.

Regulatory review for continuous improvement is the ongoing practice of government and the regulator

and to this effect, government Ministries and the Commission use peer-reviewed science to inform the

Province’s regulatory framework and to ensure best-practice regulations. As the panel indicated, a key

challenge is the need to first address the knowledge gaps, and this requires focussed research.

Action Area #6

Enhance baseline monitoring in Northeast BC for surface water and groundwater data collection

and research.


In the past few years, many research collaborations have been struck to fill knowledges gaps around

hydraulic fracturing and its associated impacts. Table 1, for example, shows some of the collaborations

and associated partnering agencies that exist in the Western Canadian Sedimentary Basin for induced

seismicity and seismic research.

TABLE 1

INDUCED SEISMICITY AND SEISMICITY RESEARCH COLLABORATIONS

PARTNERING AGENCIES

BC SEISMIC RESEARCH CONSORTIUM

BC Oil and Gas Commission, Natural Resources Canada, Yukon Government, Alberta Geological Survey, Canadian Association of Petroleum Producers, Geoscience BC

CANADIAN INDUCED SEISMICITY COLLABORATION

Alberta Geological Survey, Pacific Geoscience Centre, GeoScience BC, TransAlta, Nanometrics, McGill University, University of Alberta, Western University, University of Calgary, University of Pittsburgh

MICROSEISMIC INDUSTRY CONSORTIUM

Approximately 30 oil and gas companies; government agencies; University of Alberta, University of Calgary

CONSORTIUM FOR RESEARCH IN ELASTIC WAVE EXPLORATION SEISMOLOGY

University of Calgary, Industry

Other existing research collaborations have previously been noted in this Action Plan (i.e., BC OGRIS,

MERC, EERI). Still others, not previously mentioned, such as the Cumulative Impacts Research

Consortium out of the University of Northern British Columbia, exist to address cumulative impacts

research in the broader context of all activity on the land base not just oil and gas activity. The cross-

government working group considered the panel’s recommendation regarding a “single” research entity

in the context of these specialized research initiatives already underway.

Research to support hydraulic fracturing is, by its nature, highly technical and widely varied. It is

complicated to develop a research partnership program and mandate that ensures collaborative

participation and is complementary to existing (and successful) initiatives and consortiums. The

benefits of such an overarching strategic research partnership includes broader multi-party monitoring

of research progress and outcomes and greater transparency. Such a partnership could also provide a

vehicle for input on research direction through collective insights and support research that provides

practical deliverables to enhance the regulation of hydraulic fracturing in British Columbia.

Advancing a strategic research partnership model could provide a framework for technical research

aligned with the Panel report recommendations. Such a framework could use a coordinated team of

provincial scientists and engineers to: refine key research questions around the recommendations that

would lead to improved policy and regulation; champion research-oriented collaborative partnerships

through engagement; prioritize research, reports and presentations to raise the needed research

questions in the agenda to action; communicate broadly the process, key findings and results of the

research, and coordinate with policy teams to improve related policy and regulations.

The Provincial government currently provides funding for scientific research, including research specific

for oil and gas development in BC, through grants to BC-funding agencies. Research-related decisions

are then supported by independent subject-based consortiums, research groups, and advisory groups.

A strategic partnership framework would build on existing structures to: identify knowledge gaps and

https://www.inducedseismicity.ca/

https://www.inducedseismicity.ca/


action research at the consortium-level; review and leverage parallel research in other jurisdictions; and

ensure cross government communication.

Building on current partnerships, government commits to the actions outlined below in response to the

Panel report’s recommendations.

Action Plan


7.1. Engage with partner agencies, institutions, industry, stakeholders, and Indigenous peoples, to

enhance and build effective strategic research partnerships (Commission, EMPR, ENV, FLNR).

7.2. Engage with funding agencies and existing research consortiums in the subject areas to reduce

potential for overlap of efforts and ensure alignment with recommended research directions

(EMPR).

7.3. Coordinate consolidation of existing research under each subject area as a foundation to

support the strategic research partnerships and mandate (EMPR).

SECTION 3: COMMUNICATION AND INFORMATION SHARING

Background Discussion The Panel report stressed the important roles communication and information sharing play in building

trust in regulatory processes and government as the Province works to ensure oil and gas development

continues in a safe and environmentally responsible manner. It emphasised that the public needed

more communication on how the Province is regulating oil and gas activities, ensuring compliance and

taking into consideration the interest of citizens, Indigenous peoples and the environment

The recommendations and advice contained in the Panel report relating to communication (SRHF pp.

59-60, 68, 82, 97, 156, 165, 178, 189 and 191), data management, and access to data are being

addressed in policy, regulations and initiatives outlined in this Action Plan. As government moves

forward with the Action Plan, it will continue to focus on transparency in how it shares information

about the response to the Panel report. This will include explaining what has been accomplished and

what work is still underway in the oil and gas sector for hydraulic fracturing related subjects.

There are different audiences for different aspects of the Action Plan, therefore, progress on the actions

in response to the Panel report will be expressed through various communication methods.

Additionally, government will continue to work with various existing engagement groups in Northeast

BC to pursue dialogue on topics that resonate with local community members and Indigenous

community concerns (SRHF pp. 178 and 189). For example, ENV actively engages with neighbouring

jurisdictions and First Nations in Northeast BC to implement the commitments outlined in the Bilateral

Water Management Agreements under the Mackenzie River Basin Master Agreement. This ongoing

Action Area #7

Advance strategic research partnerships building on existing structures to provide a framework

for technical research tied to the Panel report recommendations.

https://www2.gov.bc.ca/gov/content/environment/air-land-water/water/water-planning-strategies/water-management-agreements

https://www2.gov.bc.ca/gov/content/environment/air-land-water/water/water-planning-strategies/water-management-agreements


work includes information sharing, open communication, watershed classifications, and other

mechanisms to protect aquatic ecosystem health.

To further improve communication, transparency and information sharing, government commits to the

actions outlined below in response to the Panel report’s recommendations.

Action Plan

Supporting actions include:

8.1. Improve communications, data management and access to data as part of ongoing policy and

regulatory work (Commission, EMPR, ENV, FLNR).

8.2. Enhance government’s web presence for subjects as they relate to hydraulic fracturing in

British Columbia and provide:

a. updates on the progress of this action plan and in addressing the recommendations of the

Panel report;

b. links to data and scientific information; regulatory and policy changes; and plain-language

explanations of hydraulic fracturing and related subject areas (EMPR).

8.3. Identify opportunities for information sharing in Northeast BC (Commission, EMPR, ENV, FLNR).

8.4. Participate in information sharing and gather feedback to bring forward identified

communication and knowledge gaps to research consortiums or appropriate regulatory

agencies (Commission, EMPR, ENV, FLNR).

SECTION 4: SUMMARY OF ACTIONS The following table summarizes all actions that have been taken by government, whether completed,

underway or identified as an action in this Action Plan, that respond to the SRHF Panel report

recommendations. The indicated status is current to the date of publication of this Action Plan. Some

of the actions in the table were started before the Panel’s recommendations were released, others were

started in the months since or will commence in 2020.

Table 1: Summary Table of Actions

Action Status

Water Quantity

1. Install streamflow gauging stations (FLNR, Commission) Underway

2. Work with three Treaty 8 First Nations to establish the stations for the collection of streamflow data over a two-year period (Commission)

Underway

3. Continue work with federal government on installation and maintenance of hydrometric stations with real-time data sharing (ENV)

Underway

Action Area #8

Foster greater public trust and transparency of government regulations, policies and programs by

increasing communication and information sharing and strengthening relationships in Northeast BC.


4. Require that hydrogeological assessments be overseen by a qualified professional (Commission)

Complete

5. Work with First Nations to install new groundwater observation wells near Fort Nelson (FLNR)

Complete

6. Increase mapping of aquifers (ENV) Complete

7. Implement a new process to make sure commission-regulated oil and gas dams in B.C. are operating with appropriate permits (Commission)

Complete

8. Put in place new procedures to ensure all dams and water storage structures used in oil and gas development are properly licensed and safe for use (Commission)

Complete

9. Advance next steps to require water use reporting of water sales on private land (FLNR)

Action 1.1

10. Ensure that the outreach and education initiative to landowners with dams continues and is expanded as resources are available (FLNR)

Action 1.2

11. Improve transparency by ensuring timely publication of quarterly water use reports (Commission)

Action 1.3

12. Develop a mechanism for tracking alternative fluid use and the reuse and recycling of fluids for hydraulic fracturing (Commission)

Action 1.4

13. Assess further options, including regulations, to advance hydraulic fracturing water reuse and recycling (EMPR, Commission)

Action 1.5

14. Review industry-submitted data with respect to water use, to track water use and ensure compliance with license-specific conditions. The Commission will engage their External Audit team to undertake audits of submitted data (Commission)

Action 1.6

15. Complete a progress report on the Mattison recommendations (FLNR) Action 1.7

16. Ensure the dams and dugouts spatial layering through the Commission’s website and BC data catalogue are up-to-date and publicly available (Commission)

Action 1.8 Complete

17. Advance work initiated on requirements for decommissioning and reclamation plans to be submitted for large fresh water storage dams for oil and gas activity. Ensure that the Commission’s Comprehensive Liability Management Plan accounts for all oil and gas infrastructure, including dams, to ensure restoration costs are born by industry (Commission)

Action 1.9

Water Quality

18. Support UBC EERI Research Initiative placement of water wells in a diversity of hydrogeological settings (Commission)

Underway

19. Continue work with the federal government and First Nations on water quality sampling in lakes and streams and to advance the Canadian Aquatic Benthic Invertebrate Network (CABIN) (EMPR, ENV, FLNR, Commission)

Underway

20. Conduct Forest and Range Evaluation Program (FREP) riparian assessments for stream health assessment program (Commission)

Underway

21. Publish private well survey to EcoCat (ENV, FLNR) Complete

22. Consider the classification of hydraulic fracturing wastewater as hazardous waste and determine whether the current definitions within Federal legislation to be inclusive and robust (ENV, Commission)

Complete


23. Collect and analyze samples of flowback water and establish a joint Commission/ENV working group to address toxicity assessment and evaluate regulatory thresholds (ENV, Commission)

Action 2.1

24. Expand the Commission’s website mapping interface to include all reported spills in addition to reporting incidents related to pipeline (Commission)

Action 2.2

25. Review and assess regulatory policies for risk-based groundwater monitoring requirements for oil and gas activities, with consideration of existing regulatory requirements and processes, existing data, and insights gained from ongoing research (Commission)

Action 2.3

Induced Seismicity

26. Increase the number of open data stations in Northeast BC in partnership with Natural Resources Canada (NRCAN), Geoscience BC (GBC), McGill University and BC Oil and Gas Research and Innovation Society (BC OGRIS) (Commission)

Underway

27. Develop a guideline for standardized magnitude calculation and calculation of ground motion parameters (Commission, with the BC Seismic Research Consortium)

Underway

28. Map zones that are likely to experience greater ground motion from seismic events (Commission, EMPR with Geoscience BC and Industry)

Underway

29. Launch an induced seismicity susceptibility framework and map an Integrated Machine Learning and Mechanistic Validation Approach government funded Geoscience BC (GBC) (Commission, GBC)

Action 3.1

30. Engage with industry, partner agencies and academia to grant access to additional seismic arrays for public consumption and revisit the current policy for accelerometer data (Commission)

Action 3.2

31. Add the relevant, induced seismicity components of the Kiskatinaw Seismic Monitoring and Mitigation Area (KSMMA) special project order, including the pre-assessment requirement, to the Drilling and Production Regulation with spatial boundaries that match the northern ground motion monitoring area and the KSMMA special project order boundary (Commission)

Action 3.3

32. Review research on fault slip potential as well as pre-assessments received to date from KSMMA special project order activities and create a template outlining the minimum content required in a pre-assessment (Commission)

Action 3.4

33. Continually evaluate submitted pre-assessments after completion operations to assess the validity of the information supplied and the mitigation outcomes (Commission)

Action 3.5

34. Finalize a draft pre-assessment template and proposed regulatory enhancements (Commission)

Action 3.6

35. Complete work to develop a guideline for standardized magnitude calculation and calculation of ground motion parameters and have all event data posted to a public facing website using optimal magnitude calculation (Commission)

Action 3.7


Fugitive Emissions 36. Implement regulatory changes to the Drilling and Production Regulation to

reduce methane emissions from the upstream oil and gas sector (Commission)

Complete

37. Create a new Investigations Regulation under Oil and Gas Activities Act giving citizens the right to request investigation of methane emissions that are suspected of occurring in contravention of the regulations (EMPR)

Complete

38. Develop guidelines for industry to comply with the methane emission requirements including:

• Fugitive Emission Management Program Guidelines (Commission)

• Leak Detection and Repair Data collection forms (Commission)

• Updated Flaring and Venting Reduction Guidelines (Commission)

• Program to Reduce Benzene Emissions from Glycol Dehydrators and Annual Inventory Form (Commission)

Underway & Complete

39. Advance Clean Growth Infrastructure Royalty Program to partner with industry in methane and other greenhouse gas emission reduction projects using royalty deductions (EMPR)

Underway

40. Launch the CleanBC Industry Fund to accept methane reduction projects as part of the CleanBC Industrial Incentive Program (ENV)

Underway

41. Assess different methods of making available industry data regarding gas migration including detection, monitoring, and mitigation measures taken (Commission)

Underway

42. Create the BC Oil & Gas Methane Emissions Research Collaborative (MERC) to advance research on methane emissions from oil and gas activity (Commission, EMPR, ENV)

Complete

43. Review and update regulatory requirements so to require submission of all surface casing vent flow tests conducted by permit holders (Commission)

Complete

44. Make surface casing vent flow data available via the Commission’s website (Commission)

Complete

45. Support research to better understand gas migration through UBC’s EERI research consortium at the Hudson Hope facility (Commission)

Underway

46. Support UBC-EERI research to increase understanding of regional hydrogeology and to monitor groundwater quality (Commission)

Underway

47. Support UBC-EERI geospatial data investigations on energy well construction and the potential for gas migration (Commission)

Underway

48. Conduct aerial surveys of decommissioned gas wells, identify well sites where methane is detected and order remediation (Commission)

Underway

49. Advance research through MERC and other opportunities. The results of this research will be reviewed to consider approaches and directions for further targeted research priorities (see research partnership section) (EMPR, ENV, Commission)

Action 4.1

50. Conduct a mid-point regulatory review of the methane emission reduction regulations to ensure the Province is on track to reach a 45 percent reduction in methane emissions by 2025 (EMPR, ENV, Commission)

Action 4.2

51. Complete a review of gas migration data submitted by industry and publish data in the Commission’s existing data base (Commission)

Action 4.3


Other Topics (Health, Orphan Wells, and Cumulative Effects and First Nations) 52. Engage industry in removing or finding safer substitutions for the

chemicals used in hydraulic fracturing (Commission) Underway

53. Launch a Comprehensive Liability Management Plan (CLMP) that holds industry accountable, addresses unrestored oil and gas sites and protects the environment and public safety (Commission)

Complete

54. Engage First Nations in orphan site reclamation planning and prioritizing (Commission)

Underway

55. Pass Bill 15, amendments to the Oil and Gas Activities Act to address the growing number of inactive and orphaned well sites (EMPR)

Complete

56. Support the Natural Resource Aboriginal Liaison Program (ALP) (Commission)

Underway

57. Work with Indigenous communities within Treaty 8 in developing culturally appropriate restoration practices (Commission)

Underway

58. Continue partnership with University of Northern BC and Vancouver Island University to offer three hands-on training programs in environmental monitoring field techniques for Indigenous students in Northeast BC (Commission)

Underway

59. Establish consultation agreements with Treaty 8 First Nations. Capacity funding is provided to First Nations to support them in their review of oil and gas activity applications (EMPR, Commission)

Underway

60. Advance RSEA to inform decision making relating to oil and gas development (EMPR, Commission)

Action 5.1

61. Engage with Treaty 8 First Nations in the LRMP process (FLNR) Action 5.2

62. Continue and expand Commission initiatives to enable Indigenous peoples to participate in prioritizing and monitoring environmental values impacted by resource development (Commission)

Action 5.3

Baseline Data and Monitoring 63. Revise data management systems to ensure they are more user-friendly

and seamlessly integrated. Improve: interaction between systems such as wells data and aquifer data; user interaction with wells data and better metadata; and, large data server systems like Aquarius and the Environmental Monitoring System (EMS) (ENV)

Underway & Complete

64. Support First Nations transition and share their privately acquired monitoring data on Provincial Data Servers (ENV)

Underway

65. Improve provincial ability to ingest and share publicly third-party data (ENV)

Complete

66. Continue NEWS to support information sharing and effective co-ordination of water stewardship initiatives (EMPR, ENV, FLNR, Commission)

Underway

67. Examine potential partnership structures, in consideration of previous successes and practical limitations of the NEWS (EMPR, ENV, FLNR, Commission)

Action 6.1

68. Identify cost effective opportunities to enhance provincial monitoring programs that leverage existing infrastructure, programs and projects (EMPR, ENV, FLNR, Commission)

Action 6.2


69. Enhance opportunities for participation and input from Indigenous peoples in shared water stewardship activities (EMPR, ENV, FLNR, Commission)

Action 6.3

70. Improve data management systems by documenting and refining existing datasets (ENV)

Action 6.4

71. Examine options for data amalgamation and communication and expand data availability through industry and First Nations data sharing agreements (EMPR, Commission)

Action 6.5

72. Examine and leverage potential funding opportunities through government initiatives such as the Groundwater Science Fund, industry partners and non profits like GBC, water funders and others (EMPR, Commission)

Action 6.6

Strategic Research Partnerships

73. Continue practice of seeking opportunities to use peer reviewed science to inform Province’s regulatory frameworks’ continuous improvement and ensure best practice regulations are in place (EMPR, ENV, FLNR, Commission)

Underway

74. Engage with partner agencies, institutions, industry, stakeholders, and Indigenous peoples, to enhance and build effective strategic research partnerships (EMPR, ENV, FLNR, Commission)

Action 7.1

75. Engage with funding agencies and existing research consortiums in the subject areas to reduce potential for overlap of efforts and ensure alignment with recommended research directions (EMPR)

Action 7.2

76. Coordinate consolidation of existing research under each subject area as a foundation to support the strategic research partnerships and mandate (EMPR)

Action 7.3

77. Engage with partner agencies, institutions, industry, stakeholders, and Indigenous peoples, to enhance and build effective strategic research partnerships (EMPR, ENV, FLNR, Commission)

Action 7.4

Communication and Information Sharing

78. Continue work with various existing engagement groups in Northeast BC to pursue dialogue on topics that resonate with local community members and Indigenous community concerns (EMPR, ENV, FLNR, Commission)

Underway

79. Improve communications, data management and access to data as part of ongoing policy and regulatory work (EMPR, ENV, FLNR, Commission)

Action 8.1

80. Enhance government’s web presence for subjects as they relate to hydraulic fracturing in British Columbia (EMPR)

Action 8.2

81. Identify opportunities for information sharing in Northeast BC (EMPR, ENV, FLNR, Commission)

Action 8.3

82. Participate in information sharing and gather feedback to bring forward identified communication and knowledge gaps to research consortiums or appropriate regulatory agencies (EMPR, ENV, FLNR, Commission)

Action 8.4

Documents

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