July 2025

AER Issuing Noncompliance Notices for Unapproved Commingling

The Alberta Energy Regulator (AER) has recently issued notices of noncompliance to several operators for commingling without approval.

Operators are being directed to submit action plans and compliance timelines to the AER and reminded that simply shutting in a well is not considered compliant.

If your company has wells that may not have formal commingling approval in place, we strongly recommend reviewing your well files and proactively addressing any potential noncompliance.

 

If you’ve received a notice or suspect there may be commingling issues in your inventory, reach out to our team—we’re here to help you stay compliant and avoid operational disruptions.


At Benoit Regulatory, we assist clients with:

  • Developing action plans to bring wells into compliance
  • Preparing and submitting commingling applications to the AER
  • Supporting self-disclosure submissions, when appropriate


Contact us at kpyszynski@benoitregulatory.com for support.

AB: Oil and Gas Reserves Update as of 2024

The AER has published the updated crude oil and natural gas reserves on their website. The reserves tables can be found HERE.

AB: New Edition of Manual 023

On July 9, 2025, the AER we released a new edition of Manual 023: Licensee Life-Cycle Management

AB: New Edition of Directive 010

On July 7, 2025, the AER we released a new edition of Directive 010: Minimum Casing Design Requirements

AB: New Edition of Specified Enactment Direction 002

On July 22, 2025, the AER released a new edition of Specified Enactment Direction 002: Application Submission Requirements and Guidance for Reclamation Certificates for Well Sites and Associated Facilities (SED 002)SED 002 sets out the information requirements under the Environmental Protection and Enhancement Act (EPEA) for reclamation certificate applications for energy resource development and brine-hosted-mineral resource development, including associated facilities and pipelines. 



Additional information can be found in Bulletin 2025-23

AB: New Specified Enactment Direction Regarding Pipeline Conservation and Reclamation

On July 24, 2025, the AER released Specified Enactment Direction 004: Pipeline Conservation and Reclamation Approvals Under the Environmental Protection and Enhancement Act, which contains application requirements for AER-regulated pipelines requiring approval under the Environmental Protection and Enhancement Act  (EPEA) and postconstruction reclamation assessment reporting requirements for EPEA-approved pipelines. 

Under Schedule 1, Division 3(c), of the Activities Designation Regulation, pipelines in the White Area with an index number of 2690 or greater require an EPEA approval prior to construction.

The regulation also lists the exemptions where an EPEA approval is not requiredand includes examples of common pipeline scenarios and guidance regarding when an EPEA approval is required. 



SED 004 replaces the Information Requirements for Regulated Pipelines and Guide for Pipelines Pursuant to the Environmental Protection and Enhancement Act and Regulations  for AER-regulated pipelines.

Effective July 24, 2025, all new applications for the approval of construction and reclamation of a pipeline under EPEA must meet the requirements set out in SED 004. Any applications submitted prior to July 24, 2025, will be reviewed using the previous requirements and do not need to be resubmitted.

Additional information can be found in Bulletin 2025-24

AB: Mandatory Submission of Electronic Data for PNG Tenure and Geothermal Applications

The PNG Tenure Operations will no longer accept paper-based data or USB flash drives for the applications submitted through the Electronic Transfer System (ETS).

As of August 11, 2025, submission of electronic data via ETS will be mandatory for the following: • Continuation and Validation Applications

• Geothermal Applications

• Crown Mineral Activity Applications

• Offset Notice Responses

For the following applications and other submissions currently managed outside of ETS, submission of electronic data through the corresponding business email below will be mandatory as of August 11, 2025:

• Continuation, Validation, and Geothermal Authorized Confidential Data: EM.DatasubmissionPNGContinuation@gov.ab.ca

• Trespass Notice Responses and Data: Energy.Trespass@gov.ab.ca

Unitization and Production Allocation Unit Agreement Proposals, Amendments, Enlargements and Data: EnergyUnitsHelpdesk@gov.ab.ca

Offsets Appeals Data: Energy.Offsets@gov.ab.ca.

Crown Mineral Activity – Additional Application Data and Audit Notice Responses Data: Energy.Crownauthorizations@gov.ab.ca

Additional information can be found: Mineral Rights Information Bulletin 2025-04

SK: 2025-26 Oil and Gas Cost Recovery Levy Issuance

On July 2, 2025, the ER posted details regarding the issuance of invoices for the 2025-26 Oil and Gas Cost Recovery Levy.



Additional information can be found in BT 2025-006

SK: Gas Oil Ratio (GOR) Enforcement

All single well batteries that use the GOR method must have documented proof of an annual GOR test, as outlined in Directive PNG017: Measurement Requirements for Oil and Gas Operations. If this documentation is not available upon request, the operator may be ordered to undertake a GOR within a specified timeframe. Failure to conduct the GOR may result in a suspension order for the well(s) in question until a GOR has been conducted and verified.



Additional information can be found in BT 2025-007

BC: Notice Regarding Pipeline Dent Screening 

On June 19, 2025, the BCER posted a notice to pipeline permit holders of a potential issue related to a dent assessment methodology previously included in the American Petroleum Institute’s (API) Recommended Practice (RP) 1183.



Pipeline permit holders are reminded that the evaluation of imperfections on operational pipelines must be done in accordance with the requirements of Clause 10 of CSA Z662:23. The BCER expects individuals performing engineering assessments to remain informed of updates to assessment methodologies and, where necessary, to revise or update previous assessments if new information emerges that could invalidate previous assessment results.


Permit holders should refer to CER Safety Advisory 2025-01 and API’s Addendum to API RP 1183 for Improved Dent Screening for more information.


 Additional information can be found: SA 2025-03

BC: Application Management System (AMS) New Application Type Added

On July 16, 2025, the BCER announced an update to the Application Management System (AMS) introducing a new application type and two new activities to support submissions for Renewable Energy (Wind and Solar) and Prescribed Transmission Lines.



Additional information can be found: TU 2025-12

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