The shale gas industry in Quebec is regulated under the Mining Act and the Environmental Quality Act.
In addition to obtaining various government authorizations, we must comply with a number of laws and regulations:
- The Ministère des Ressources naturelles et de la faune (MRNF) administers regulations that require proper drilling and cementing techniques to protect groundwater.
- The MRNF issues completion licences, and the Ministère du Développement durable, de l’Environnement et des Parcs (MDDEP) requires a Section 22 Certificate of Approval to fracture a well as part of a completion.
- The MRNF and MDDEP both require flaring permits.
- The MDDEP requires a Section 22 authorization for water withdrawals.
- The MDDEP regulates disposal facilities that receive waste water, which in turn requires testing.
Given the exploration activities that are currently underway, the existing regulatory regime which has effectively protected the environment is sufficient.
As our industry expands into the development phase, we support the current efforts to enhance the existing regulatory regime. It is our belief that centralization of regulation, where the regulator issues authorization and is responsible for enforcing it, is the best option for Quebec. Centralization provides a way to develop expertise and familiarity with industry operations. The regulator should have rule-making powers, and look at industry best practices, American Petroleum Institute and Canadian Standard Association Standards, and other jurisdictions’ practices in developing Quebec’s rules.