The draft regulation under the Environment Quality Act (chapter Q-2) proposes amendments to the existing rules for mandatory reporting of certain emissions of contaminants into the atmosphere. The purpose of these changes is to improve the accuracy and reliability of greenhouse gas (GHG) reporting in Québec, particularly regarding biomethane, a renewable gas used as a substitute for natural gas. The amendments focus on requiring verification of CO2 emissions associated with the acquisition and use of biomethane, adjusting reporting procedures, and updating default greenhouse gas emission factors for Canadian provinces and certain North American markets.

The key feature of the draft regulation is the verification requirement for CO2 emissions attributable to the combustion or use of biomethane. Previously, emissions reporting focused primarily on conventional fossil fuels, but the increasing use of biomethane as a renewable energy source necessitates a more rigorous approach to ensure that reported emissions data reflect actual environmental impacts. Under the proposed amendment, any biomethane acquired as a substitute for natural gas or distributed for consumption in Québec must have its associated CO2 emissions verified. This verification is intended to provide an independent assessment of the accuracy and reliability of the information reported by emitters and to ensure that greenhouse gas inventories and compliance measures accurately reflect the use of renewable gas sources.

Section 6.6 of the Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere is amended to explicitly require that CO2 emissions linked to biomethane combustion or use be verified. In addition, section 6.9 is revised to expand reporting details and verification procedures. Specifically, emitters must report the quantity of CO2 emissions attributable to biomethane acquired as a natural gas substitute from distributors or other suppliers in metric tons. A separate reporting line is added for CO2 emissions from biomethane distributed for consumption within Québec. Verification reports must include an opinion on the accuracy and reliability of the reported emissions, based on established protocols. If the verification report is negative, the emissions in question are treated as if they were generated from natural gas rather than biomethane, and the report must indicate the quantities of biomethane reconsidered as natural gas.

The draft regulation also updates Table 17-1 in protocol QC.17, which provides default greenhouse gas emission factors for electricity generation across Canadian provinces and selected North American markets. These emission factors, expressed in metric tons of CO2 equivalent per megawatt-hour, are used to estimate emissions when precise data is unavailable. The revised table reflects updated values for Québec and other regions, ensuring consistency in emission reporting and inventory calculations. For example, the default emission factor for Québec is set at 0.002 metric tons CO2 equivalent per megawatt-hour, while factors for neighboring provinces and markets such as Ontario, New Brunswick, and the New England Independent System Operator are adjusted to reflect current energy generation profiles and emission intensities.

Quebec (Draft) August 27, 2025
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