December 2019
Reminder: End of Year Obligations
This is your last chance! In accordance with Directive 040, annual and /or initial pressure surveys must be taken by December 31, 2019 and submitted within 90 days (or pay a $1000 fine per pool or violation).

Methane Emission Reduction Requirements come into effect January 1, 2020. All operators must have their Fugitive Emissions Management Plan (FEMP) available to the AER on request. Administrative penalties may be applied on an individual and/or corporate level for non compliance.

The federal Greenhouse Gas Pollution Policy Act (GGPPA) comes into effect January 1, 2020 and will apply a fuel charge to fossil fuels used in the province.

The provincial government is introducing the TIER system under the Technology Innovation and Emissions Reduction Regulation. Operators can opt into TIER instead of the GGPPA. Information on the GGPPA and TIER can be found here .

Thank you!

We hope you all have a wonderful holiday season.

Thank you so much for your continued support in 2019! We're looking forward to working with you all next year and wish you the best in 2020!

AER Bulletin 2019-28: Pipeline Integrity Management Programs Must Consider Slope Movement
On November 7, 2019, the AER released information that Licensees must consider natural hazards (including slope movement) as part of their integrity management programs. In particular, clauses 3.1.2, 3.2, and 3.3 and Annex N require licensees to have a safety and loss management system, manage risks, have integrity management programs that monitor for conditions that can lead to pipeline failure (including slope movement), and act to eliminate or mitigate such conditions.

A copy of Bulletin 2019-28 can be found here.


Well Testing Services at Benoit
To support Benoit's regulatory application and compliance related submissions, Benoit now utilizes an in-house well test analysis expert, Mr. Reza Ali, C.E.T.

Mr. Ali has over 30 years of experience specializing in domestic and international Flow and Build-Up, Production Data and DFIT Analyses. 

If you would like a well test analyzed or if you would simply like more information on our well testing services, please feel free to contact Robyn (at 403.263.3690) or Jason (at 403.874.6769). You may also contact R eza Ali directly at 403.454.0430.

Integrated Compliance Management Program (ICMP) at Benoit
Did you know that Benoit provides a service which covers our regulatory application, liability management ratio and evaluation services under one umbrella?
 Under this program, Benoit acts as a “regulatory arm” for your company by receiving and responding to all compliance related matters on your company’s behalf.

As your regulatory designate, in addition to our regulatory application service, Benoit conducts a number of additional services including, but not limited to:

  • Inactive Well Compliance Program Monitoring
  • Liability Management Rating Forecasting
  • DDS Entry for Well/Completion Details
  • Flaring Notifications
  • Well Test Data Submissions
  • Gas Conservation Economic Analyses
  • Monthly VRR calculations/updates for Enhanced Recovery Schemes

If you're interested in this service or would like to discuss this further, please contact us or visit our website for more information

AER Bulletin 2019-29: Tracking and Manifesting Produced Water

On November 12, 2019, the AER announced, that all Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry are still in force and are independent of Alberta Transportation requirements issued in Permit 2018-4703 (Permit P) on November 19, 2019. Some confusion has arisen due to the overlap with the AER’s tracking and manifesting requirements found in D058.

More detailed information can be found in Bulletin 2019-29 here .


AER Bulletin 2019-30: Change to Consent Requirements When Crown Mineral and Disposal Rights Overlap

On November 20, 2019, the AER announced that effective immediately, pursuant to the Alberta Energy Information Letter 2019-37 , the AER will no longer require proof of consent from overlapping Crown mineral rights holders for new or existing disposal schemes where the disposal scheme applicant or approval holder has a valid Crown authorization to dispose issued by Alberta Energy under section 54(5) or section 32(4) of the Mines and Minerals Act.    

A copy of Bulletin 2019-30 can be found here.

 
AER Bulletin 2019-31: 2019/20 AER Administration Fees (Industry Levy)
On November 29, 2019, the AER announced that the Government of Alberta approved the AER to issue two sets of administrative fees for 2019. Invoices to operators detailing the fee calculations will be mailed on November 29, 2019, and payments are due by January 6, 2020 .  

The first set of administrative fees ($154M) was issued on July 12, 2019, to allow the AER to secure the appropriate funds to operate until a budget approval date. As the Government of Alberta has approved a total industry levy of $233.2M, the AER is now issuing the second set of administrative fees to collect the remaining $79.2M.

A copy of Bulletin 2019-31 can be foun d here.

AER Training Sessions: Area-Based Closure
The AER is offering area-based closure (ABC) training in January. These sessions will cover new functions of ABC within the OneStop tool and updated guidelines.

To register for training , visit the AER events page

SK Waterflood Development Program – Royalty Deferral Program   
On December 5, 2019 the Ministry of Energy and Resources (ER) announced that the Waterflood Development Program (WDP) applications will be accepted between Dec 1, 2019, and Dec 31, 2024. The WDP program provides a repayable royalty deferral with a low interest rate to eligible wells for a period of three years.
WDP repayable royalty deferral amounts for eligible wells:

◦Drilling a new dedicated horizontal injection well - $1,000,000.
◦Drilling a new dedicated vertical injection well - $500,000.
◦Converting a vertical or horizontal production well to an injection well - $500,000.

Important: This is a deferral program, not a royalty holiday. The royalty deferral is applied at the corporate level. Beginning in the 4 th year, the total deffered royalty amount and accrued interest has to be paid to ER in 10 monthly instalments.

Additional information can be found here .


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CONTACT US:

phone: 403.263.0896 | email: questions@benoitregulatory.com