Clarification on Project Eligibility for Pneumatic Instruments and Pumps in Alberta
In July of this year (2021), Alberta Environment published a Memorandum, outlining draft guidance for how pneumatic instruments and pump offset projects would be impacted by impending vent gas limits in the AER's Directive 060. I published a blog post shortly afterwards, which outlined these proposals (you can read the original version here).
A final version of the Memorandum was published November 29 (2021) and is available from AEP here. As before, the Memorandum makes for complex reading, owning to the way in which D060 differentially treats instruments (that is, controllers, positioners, transducers and switches) and pumps, and differentially treats installations (i.e. putting in a device where there previously was none, or replacing a non-functional device) compared to conversions (i.e. replacing an existing, functional device or changing its power source).
To make this somewhat easier to digest, the key eligibility pathways from the Memorandum are shown graphically below (vent gas capture projects have been excluded from this graphic owing to some continued uncertainty with how these will be treated).
Compared to the previously issued Memorandum, the major changes are:
For Instruments - Clarification that instruments included in electrification or Instrument Gas to Instrument Air (IGIA) conversion projects (i.e. where the instrument was already installed on or prior to Dec 31, 2021) are eligible to create offsets until the end of their normal 8-year crediting period and will not be curtailed at the end of 2022 (instruments included in high-to-low projects will remain subject to this crediting period restriction). However, from 2023 onwards, the baseline for these projects will be low-bleed instruments, regardless of whether the instruments in place are high- or low-bleed models.
For Pumps - Clarification that, starting on Jan 1, 2022, new installations of pumps are only eligible to create offset credits if they are pumps that 750 hours or less in a year. (Installations of pumps running more than 750 hours in a year are required by D060 to be non-venting from this date). Eligible pumps remain able to create offsets until the end of their normal 8-year crediting period.
Overall, this is good news for the industry and continues to ensure there is an offset 'carrot' to complement the regulatory 'stick' for reducing venting from pneumatic devices in the field.