Business Challenge

A large Canadian LNG project required the development of a Fugitive Emissions Management System (FEMS) under a new and relatively untested provincial regulatory framework. As one of the first LNG facilities subject to these requirements, expectations were unclear and evolving, resulting in uncertainty for compliance strategy, technical requirements, and documentation structures. The client needed external support to coordinate SME input, interpret regulatory obligations, benchmark similar systems across industry, and create a defensible, technically sound foundation for a full FEMS.

Objectives & Success Criteria

The client sought to:

• Develop initial components of a fit-for-purpose Fugitive Emissions Management System.
• Compile and align input from internal and external subject matter experts.
• Conduct a gap analysis against current provincial regulations and industry expectations.
• Benchmark FEMS requirements across comparable jurisdictions and sectors.
• Provide high-level technical guidance outlining next steps toward full FEMS implementation.

Success was measured by delivery of a clear, technically justified FEMS foundation, a structured gap analysis, and actionable guidance that supported the client’s regulatory readiness and internal planning.

PMO Solution (What We Did)

PMO deployed a multidisciplinary team of regulatory, process safety engineering, and environmental specialists to collaboratively design the early-stage FEMS framework. PMO coordinated the work and input from multiple client SMEs, ensuring alignment between engineering studies, legal and regulatory interpretations, environmental considerations, and operational requirements. The team compiled relevant regulations, interpreted emerging expectations for LNG facilities, benchmarked similar systems across jurisdictions, and conducted a detailed gap analysis to identify missing elements. Finally, PMO developed a high-level technical guidance document outlining recommended system components, required actions, and a clear roadmap for full FEMS development. The scope ultimately expanded beyond initial expectations due to the complexity of “first-mover” regulatory interpretation and the client’s need for additional support.

Key Components / Activities

• Review and interpretation of provincial fugitive emissions regulatory framework
• Coordination of input from client SMEs across multiple technical disciplines
• Benchmarking of FEMS requirements across jurisdictions and industry
• Development of preliminary FEMS structure and required components
• Gap analysis comparing current state to regulatory expectations
• Creation of high-level technical guidance document with recommended next steps

Outcomes & Impact

PMO delivered a structured, technically defensible foundation for the client’s future fugitive emissions management program. The gap analysis clarified regulatory expectations, identified required system components, and reduced uncertainty for the client’s engineering and regulatory teams. The technical guidance established a clear roadmap for full FEMS development and positioned the client for more effective engagement with regulators. PMO’s cross-functional support provided clarity, alignment, and momentum for an otherwise ambiguous regulatory requirement.

Lessons Learned / Challenges Overcome

A core challenge involved interpreting requirements for a regulatory regime with limited precedent, especially for LNG operations. PMO overcame this by applying structured benchmarking, technical reasoning, and proactive SME coordination. Another lesson learned was that FEMS development requires strong interdisciplinary alignment—engineering, regulatory, and environmental teams need unified decision-making frameworks to avoid conflicting interpretations.

Value Proposition Summary

PMO delivered high-value technical and regulatory expertise that clarified and advanced a complex emissions compliance requirement for a first-mover LNG facility. By integrating engineering, regulatory interpretation, and benchmarking, PMO established the foundation for a complete Fugitive Emissions Management System and provided the client with a clear, actionable compliance pathway. This engagement demonstrates PMO’s capability in guiding clients through emergent regulatory environments and solving complex, multidisciplinary technical challenges.

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