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August 2024

AB Reminder: Directive 040 pressure requirements 

Directive 040 requires that annual pressure and testing surveys be completed by December 31, 2024 and submitted by March 31, 2025. 

Failure to obtain and submit the required pressures and, in some instances, fluid analysis, will result in a $1000 administrative penalty (fine) plus you will still have to obtain and submit the test data to fulfil the 2024 requirement. Contact us if you require assistance requesting a waiver.


The list of wells and projects requiring annual testing can be found HERE

AB: Invitation for Feedback on Revisions to Directive 020

On August 8, 2024, the AER has requested feedback on its update to Directive 020: Well Abandonment.


Section 5 of Directive 020 has been updated along with web copy for Directive 020 that provides information on qualified pools for commingled abandonment in central Alberta and a map of the new routine commingled abandonment region.


Additionally, retrievable mechanical plugs are allowed to remain in the well after abandonment. The AER is looking at allowing a layered cementing methodology in a select number of wells to evaluate the regulatory effectiveness of this methodology while ensuring the risk to public safety and environmental protection are mitigated. the AER developed  the “Layered Cement Plug Variance Submissionform to request nonroutine remedial cementing of wells, which regulated parties must provide the AER with data before and after executing the operation. The AER will review the data gathered from these select wells and determine if any other regulatory changes are necessary.


To provide feedback on the proposed revisions to Directive 020, complete the public comment form. Feedback will be accepted through September 20, 2024.  Additional information can be found: Bulletin 2024-21

Are you planning to drill a new well? We Can Help!

Benoit Regulatory Compliance offers submission guidance for Directive 056 and Manual 012, when applying for licensing new or amending facilities, pipelines and wells.

 

In addition, we can prepare your H2S release rate reports, calculate surface casing setting depth, and submit post-drilling and well completion data, as well as tours, directional surveys and logs.

For more information contact mronald@benoitregulatory.com

 BC: Changes to Reporting and Management of Incidents 

Effective September 12, 2024, updates to the Compliance Management Information System (CM-IS) will change how permit holders report and manage minor and level 1, 2 and 3 incidents.


An initial update will replace the minor incident reporting function of KERMIT, and will enable users to upload documents, enter contact information and view the status of both minor and level 1, 2 and 3 incidents. A short overview and demonstration video have been posted on the BCER website.


These changes will only apply to incidents reported after September 12, 2024. Incidents reported prior to this date will be managed using KERMIT and/or email until they are closed.


KERMIT users can use their usernames and passwords to log in to CM-IS. User roles will continue to be managed by their company administrator via their Online Systems account.


A second update, planned for early 2025, will add communication capabilities similar to those in the inspections and non-compliance component, as well as replace uploaded forms with direct data entry into the system.


Additional information can be found: TU 2024-14

BC: Changes to Energy Development in Treaty 8 Territory

The BC Province and BCER have completed changes to balance responsible energy resource development with protecting and restoring Treaty 8 rights in the following initiatives. 

1.    A landscape planning pilot (LPP) between the BC Province and Halfway River First Nation (HRFN). The HRFN LPP is brought into effect by an update to the Treaty 8 Planning and Mitigation Regulation. The BCER released the following announcement.

Additional information can be found: TU 2024-10

 

2.    The BC Province and Blueberry River First Nations (BRFN) have completed the HV1-C Gundy Complex Plan. The BCER released the following announcement.

Additional information can be found: TU 2024-11

 

3.    To support offset activity requirements described in TU 2024-11, changes to the Application Management System (AMS) to add a new associated activity type for offsets were required.

Applicants who are required to apply for offsets under regulation must include offsets as an associated activity type within their application. The spatial data must include and reference the associated activity type (AS_TYPE) for Offset (OSET). As described in Technical Update 2024-06, applicants must ensure they are using the most recent version of the RCNR and RHE Line Lists, which can be found in the supporting documents section of Chapter 6 of the Oil and Gas Activity Application Manual on the BCER website.

Additional information can be found: TU 2024-12

 

4.    A Cumulative Impacts Order comes into effect on September 1, 2024, requiring statutory decision-makers to prepare a written record for industrial and commercial activities in northeast BC. This record describes the impacts of the activity on Treaty 8 rights and the measures the applicant has taken to avoid or mitigate those impacts.

To support the preparation of the written record, applicants are required to fill out an updated Project Description Form, which is an application requirement as of September 1, 2024.

Additional information can be found: TU 2024-13

 

The BCER announced this change was implemented to support offset activity requirements as described in Technical Update 2024-11: Guidance for Energy Industry Following the Gundy Complex HV1-C Plan.


Additional information can be found: TU 2024-14

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