Thank you, Mr. Chairman, and members of the committee.
As a Canadian association we're able to provide broad industry views on policy and regulation, as well as information on the state of the industry. We're not able to talk, obviously, about the circumstances of the Gulf of Mexico--as I say, we're a Canadian organization--and neither are we able to speak specifically to company plans.
CAPP appreciates the opportunity to convey our initial thoughts both on the emergency response assets and on the current policy and regulatory regime for offshore oil and gas drilling and production, as noted in this committee's invitation to appear. We're also prepared to contribute further information as may be required or useful as this study proceeds.
CAPP and its members certainly believe that the incident in the Gulf of Mexico is a tragic and unfortunate event. It is in the interest of all stakeholders that we collectively take the time to consider the findings and recommendations arising from this investigation of the incident. This measured approach will allow us to fully understand the circumstances under which this incident occurred and assess whether there is an opportunity to improve our regulatory system or industry operating practices. Canadians, governments, and industry all have a vested interest in achieving the right outcomes from this study.
We have a number of key themes for this study today. To provide some context, the International Energy Agency projects that world energy demand will grow by about 40% over the next 20 years, with crude oil and natural gas expected to meet 40% of that growth in demand.
Global offshore crude oil production represents about 38% of the world's energy supply, and the Canadian offshore crude oil production represents about 12% of Canada's crude energy supply.
The offshore regulatory regime and industry operating practices have evolved over a number of decades, resulting in a robust regulatory system in place today.
All forms of energy development do pose environmental and safety risks. The challenge for government policy, and regulators and indeed industry collectively, is to take reasonable measures to mitigate the risks such that incidents are unlikely to occur, and then to be prepared to respond in the event an incident does occur. Again, as I said, we need to make sure we take the time to learn from the gulf incident prior to determining what the next steps might be.
With respect to the emergency response assets, we believe we should be targeting both an understanding of prevention and an understanding of the measures of preparedness. Both government's and industry's focus is on prevention first. That means understanding the risks and the measures that can be taken to control those risks.
Industry approaches all activity with a goal to complete that activity without incident or injury. Risk is assessed and mitigative measures are applied to achieve a risk level that is as low as is reasonably practicable without eliminating the possibility of conducting an activity. Companies having gone through that assessment will determine whether or not they think there is reason to proceed, and if they do, they will propose those risk strategies as part of their application, which is then subject to the judgment of acceptability by the regulator.
In addition to meeting corporate and regulatory expectations with respect to prevention, companies must also demonstrate capability to respond to any incident with a view first to containment, and ultimately recovery and cleanup. Response capability means ensuring access to necessary equipment. It also means ensuring an effective management system, typically referred to as an incident command system, which integrates companies and regulatory agencies to provide and define leadership responsibilities and execution throughout the duration of an incident. Training is a key component of competent response capability, and companies are required to conduct response exercises on a frequent basis.
With respect to Atlantic Canada response capability, operators typically employ a three-tiered response capability system with respect to equipment. Tier one would involve company-owned equipment on site. Tier two would involve equipment contracted and locally situated onshore, and companies may have their own stock of equipment onshore. Tier three would be internationally situated equipment. This provides for immediate response capability and scalable access to more equipment as needed. All this needs to be lined out before approvals are obtained.
The Eastern Canada Response Corporation is an entity that provides a third party supply of that equipment in Atlantic Canada and it is an entity certified by Transport Canada under the Canada Shipping Act.
With respect to northern Canada, there is currently no industry spill response equipment in the Arctic offshore, as there is no activity at the moment. Industry would put in place, and would expect to be required to put in place, a spill response plan, with equipment, and presumably with a similar strategy as employed on the east coast with tiered response capabilities. These plans would certainly be fit for a purpose to meet the expectations of Arctic operations, and operators would be required to have their spill response capability in place to receive approval to drill or produce.
With respect to the regulatory requirements, every offshore operator must have authorization from a requisite board to pursue offshore activity, and authorization submissions from operators must include a safety plan, an environmental plan, and a contingency plan. All three plans must provide extensive details on how a company will meet expectations with respect to equipment, personnel, and processes in the areas of safety, environmental protection, and contingency.
All plans must meet the regulations of the federal and provincial governments and the guidelines of the offshore petroleum boards, and plans are approved prior to activity occurring. The application for authorization also must include, in the case of a drilling installation, a description of the drilling and well control equipment, and in the case of production installation, a description of the processing facilities and control equipment.
Drilling a relief well is also an option and can be pursued in the event of a blowout. Companies would have those plans identified as they make their applications. I think it’s important to understand that companies don’t view that as the immediate response. It needs to be ready and available as quickly as possible, but they also need to be looking at what they can be doing throughout the incident.
The offshore boards from Newfoundland and Nova Scotia and, presumably, the NEB, when there’s activity in the north, would do regular inspections of the operators to ensure equipment is in place, it meets regulations, and it is functional, and functional in real-time circumstances.
The northern operators are additionally required to follow the same-season relief well capability policy. It’s a policy that was established in 1976 and requires companies to demonstrate their ability to drill a same-season relief well. We've already heard that the board is intending to review that policy, and in fact is expanding that review in a broader sense. CAPP supported the premise of the review and we support the premise of the broader review. I’m sure our members in the association would be interested in engaging in that.
With respect to the regulatory adequacy, the industry has been operating in Canada's offshore since the late 1960s. During this time, hundreds of wells have been drilled, and there have been incidents; there have been four blowouts, two in the north and two in Atlantic Canada. I think the most recent ones in Atlantic Canada were in the 1980s. Anytime we have incidents, we and the regulators take the opportunity to learn from those.
I think one can take from this that there is an effective regulatory regime and sound operating practices by industry in place to manage the risks. Having said that, it doesn’t mean we should be complacent. As such, we support this study and the intent of it. We support the NEB's plans to do a review as well. We would also point out, and I think you understood it from the NEB, that there are periodic reviews of any of the regulations that are in place.
In recent years, the regulatory regimes around the world have been moving from a more prescriptive model to a goal-oriented model. Canada has also been moving in that direction. Goal-oriented regulation is not intended to decrease the standards or weaken the regulation. It is intended to put a higher onus on industry to be accountable for its decisions and to be compliant, and it also requires the operators to design their operations to be the most effective and fit for purpose, allowing both for innovation and incorporation of new practices. Industry remains accountable for what they do and the regulator remains accountable to ensure that we meet the goals of the regulations.
To conclude, risk management is a fundamental premise of public policy. It's evident everywhere, from rail and air travel to our road system, so it's not unique to the oil and gas industry.
The current regulatory system is designed to minimize and manage risk in a way that is deemed to be sufficiently protected and recoverable such that Canada's offshore resource can be developed.
Industry accepts that the study and other regulatory reviews that occur from time to time may identify opportunities for improvement of regulatory requirements. In fact, we continually contribute to those reviews to provide our advice around that.
So we would encourage a balanced approach, drawing on the learnings from the gulf, to any changes contemplated that provide for an appropriate level of protection while still enabling the possibility of development of this important offshore resource.
Thank you.