Protecting the Public Interest-The Evolution of Sulphur Recovery and Solution Gas Conservation in Alberta
Authors: Brown M. , Spangelo J. 
Published: March 2010

Abstract
Alberta has used two different approaches in developing new requirements for sulphur recovery and for managing solution gas flaring in Alberta. Both processes have used multi-stakeholder input and have demonstrated measurable success. The new sulphur recovery guidelines include clear requirements with both an incentive and enforcement component. The policy developed for solution gas management combines a voluntary approach with a regulatory backstop. The involvement of diverse stakeholders contributed to the success of using novel approaches to find solutions.

Introduction
As the petroleum industry and concerns with development evolve, a regulator cannot expect to regulate in the same manner as it always has. Even the approach taken for developing regulatory requirements must grow and adapt. In this paper, two examples are explored where a regulator employed different approaches for developing requirements which are in place today and working successively. These novel approaches have resulted in measurable successes, including a 70% reduction in solution gas flaring and a 30% reduction in sulphur emissions from larger, older sour gas plants. Details are provided on the resulting requirements and the paths taken to get there. Key elements that contributed to the successes are highlighted.
The Alberta Energy and Utilities Board (EUB) is a government agency charged with regulating the oil and gas industry in Alberta. In doing so, it must protect the public interest as it relates to the discovery, development, and delivery of oil and gas resources. Regulation is needed so that non-renewable resources are produced in a responsible, efficient, and fiscally sound manner.

History of Sulphur Recovery

Requirements in Alberta
Currently, Alberta has approximately 50 sulphur recovery gas plants producing about 15,000 tonnes of sulphur per day. The average sulphur recovery efficiency for these plants in 2004 was 99.0%
Sulphur recovery guidelines in Alberta were set for all plants in 1971. At that time, requirements were in place for recoveries that the technology of that time could not yet achieve. Industry rose to the challenge, drove research, and developed the technology required to meet the new requirements, which became more stringent during a number of upgrades through the 1970s and 1980s.
Revisions to the requirements dating from 1988 grandfathered existing facilities unless significant new gas was added. In 2001, the sulphur recovery guidelines were revised to provide clarity regarding when upgrading of grandfathered plants (plants not meeting the requirements of new plants) was required as a means to improve regulatory certainty, consistency, and fairness in interpretation.
Consultation that preceded Alberta's current sulphur recovery requirements included a discussion paper issued to solicit broad input, plus recommendations from a multi-stakeholder advisory group consisting of the public, environmental organizations, industry, and academic stakeholders. This group advised the EUB in several areas, one of the most difficult being when the requirements for new plants should be applied to grandfathered plants. The advice of this group formed the basis for the current requirements.

Current Requirements
The requirements set out in August 2001 in EUB Interim Directive 2001–03 have three components that contribute to their success: