PPCIEM: ASEA’s opportunity for Mexico’s international leadership comeback
On March 31, the IEA-COP26 Net Zero Summit will take place, in which more than 40 ministers of energy and environment will participate in 5 discussion panels on the Net Zero goals to 2050. Among those confirmed are: United States, India, China, European Union, Brazil, Indonesia, South Africa, France, Germany, Italy, Colombia, and Australia. Despite not being part of this list, Mexico is one of the few countries that currently regulate methane emissions in the hydrocarbon sector. In this one-pager, we will show how the National Agency for Industrial Safety and Environmental Protection of the Hydrocarbons Sector (ASEA) can reaffirm Mexico’s leadership in its fight against climate change.
INDUSTRY, TECHNOLOGY, AND REGULATION
For more than a decade, the Canadian and US oil industries have used Optical Gas Imaging (OGI) technology to detect and quantify methane emissions. Several years later, this international standard was incorporated into their methane regulations: the US in 2016 and Canada in 2018. With little planning, Mexico joined its northern neighbors in combating methane emissions and published the Guidelines for the Prevention and Control of Methane Emissions in the Hydrocarbons Sector in 2018 (one month before Canada). However, this effort was not accompanied by the required technological assimilation necessary to control methane emissions in our country.
In the absence of technological capabilities, the ASEA regulation allows indirect methods through the application of emission factors or desktop calculations. However, indirect methods and factor use overestimate the measures (by design), as not all equipment leaks (especially newer or well-maintained equipment).
For example, based on data from the first study on methane emission factors for the Mexican oil sector prepared by the Mexican Petroleum Institute in 2012, we can observe that CENAGAS would have natural gas leaks equivalent to a value of between 6 and 431 million pesos annually.
These results are scandalous and unacceptable for any company and any officer in charge, as they could lead to financial and environmental liabilities. This example demonstrates that the overestimation derived from the use of factors is not recommended both for companies and the country. Consequently, it is not possible to have a credible emissions inventory creating unfavorable conditions for all stakeholders. Furthermore, indirect methods do not allow the implementation of detection, repair, and mitigation processes for these leaks. That is why the ideal would be for everyone to measure directly.
The lack of technological capabilities has resulted in a need for authorized third parties to dictate compliance with this regulation. However, the ASEA could take that power by demonstrating the economic benefit for the Nation by investing in an administrative area of the ASEA instead of continuing to postpone the fulfillment of international commitments. In that sense, the regulation’s intended socio-environmental benefit would be demonstrated since the current situation is zero action.
RISK OF NON-COMPLIANCE
Regulated companies should avoid using estimates by indirect methods and instead quantify the Base Year emissions with Optical Gas Imaging (OGI) technology since this same technology is required in the guidelines for the execution of the quarterly Leak Detection and Repair Program (LDAR).
* Requieres favorable technical opinion from an Authorized Third Party
Eminent is a brand from Grupo Talanza specialized in the management of methane emissions (quantification, prevention, control and regulatory compliance).
María Serna advises on the design of the regulatory compliance strategies where she oversees that each of our suggestions is both legally viable and enforceable as well as representing the minimum government relationships wear. She has experience in advocating before high-level public servants of the energy regulators in favour of our clients often integrating diverse stakeholders’ points of view.