“Adding the Emissions Cap and Methane 75 would add confusion and redundancy that is not needed.” – Woodland

Pipeline Online will be publishing most of the submissions made to the Saskatchewan Economic Impact Assessment Tribunal regarding the proposed oil and gas emissions cap and Methane 75, being brought forward by the federal Liberal government. The tribunal presented its report to the Saskatchewan government on Sept. 24, and the government has made all submissions public. (Contact information is being edited out) This is the submission of Woodland Development Corp., which is an active producer in southeast Saskatchewan:

July 18, 2024

Attention: Executive Director Ken Dueck

The Canadian Government’s Oil and Gas Sector Greenhouse Gas Emissions Cap (the Emissions Cap) and the draft regulations
amending the regulations Respecting Reduction in the Release of Methane and Certain Volatile Organize Compounds (Methane
75) are two proposed regulations that will have wide reaching implications on the small cap energy producers of Saskatchewan.
Woodland Development Corp. (WDC or the Company) is a small, approximately 6,000 BOE/D, producer in the Southeast
Saskatchewan region. WDC employs roughly 50 people in the field and utilizes the services of countless others. The majority of
shareholders are Saskatchewan based. The Company spends 100% of it’s capital in Saskatchewan and is a large part of the local
community.

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Currently, the Saskatchewan Government has an Output-Based Performance Standards (OBPS) program to regulate flaring in
upstream oil and gas operations and the generation of greenhouse gases from stationary fuel combustion. This program has set
aggressive reduction targets for operators that are aligned with the Provincial and Federal Government’s mandates to reduce
greenhouse gas emissions. Additionally, there is the Oil and Gas Emissions Management Regulations (OGEMR) program to
regulate and reduce natural gas venting in upstream operations. The goal of both these programs is to reduce greenhouse gas
emissions and to effectively reward companies for conserving their gas through carbon credits and taxing those that fall short of
their baselines. Additionally, there is the Enhanced Production Audit Program (EPAP) to effectively monitor and audit
production, measurement, and reporting practices.

We feel that the Saskatchewan Government has built a comprehensive emissions reduction strategy that has resulted in
meaningful emissions reductions in upstream operations, on both an intensity and absolute basis. WDC also feels that adding
more regulation will be a detriment to the Company and the industry. Currently, these programs and the reporting associated
with them takes a great deal of time, effort, and investment. Adding more rigorous monitoring systems will effectively reduce
the amount of time and capital available to develop our assets and focus on growth, ultimately having a negative impact on staff
levels, production volumes and government revenues.

In summary, the Saskatchewan Government has effective greenhouse gas emission programs currently in place. These programs
took time to implement and refine. Adding the Emissions Cap and Methane 75 would add confusion and redundancy that is not
needed. Woodland Development Corp believes the programs that are in place are sufficient to reduce greenhouse gases in a
meaningful way and this is verified by the energy sector reducing greenhouse gas emissions last year by 67% below levels
reported in 2015.

Should there be any questions or comments in this regard, please contact myself at (email and phone number).

Kind Regards,

Woodland Development Corp.
Rob Willson
President & CEO

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