March 2021
Happy St. Patrick's Day!
Everyone's Irish on St. Patrick's Day!  
We know the beginning of 2021 has not been easy for many, but hopefully you can relax and enjoy today. Support your local restaurant if you get a chance and celebrate! 
The AER released a new edition of Directive 020: Well Abandonment on February 4, 2021. Section 5 has been updated to allow for select routine abandonment of commingled wells that involve qualified subsurface geological strata in corresponding geographic locations.

Information on qualified pools is available on the Directive 020 webpage. The AER will update this information as they evaluate more pools. They will continue to accept all nonroutine requests related to commingled abandonments. 

Additional amendments to Directive 020 have also been made as part of the AER contributions towards the Government of Alberta’s Red Tape Reduction Act. Please refer to Bulletin 2020-07 and the directive’s “What's New” section for further information.

If you have any questions, please contact WellOperations@aer.ca.
Additional information can be found here.
AER Gas Injection – Short Term Application
As part of the AER’s ongoing application effectiveness review, the AER has identified the need for an application process for short-term gas injection in the Electronic Application Submission (EAS) System. The Gas Injection – Short Term application type is applicable to operators proposing to inject produced gas back into the same defined producing pool during surface facilities turnaround maintenance and other routine outages.

The AER will assign the application to a subject matter expert for initial review. They will review and assess the following information. If the items listed below are not included in the application, the application will be returned to the applicant.

a. The applicant has identified the target formation for the short-term gas injection. This must be an AER defined pool. There are no subsurface requirements for notification to other parties because the volume of gas to be injected will be for small volumes and for a limited duration on an annual basis.

b. Whether the applicant has the right to inject gas into the target formation.

c. If the injected fluid contains H2S (sour gas). An up-to-date, AER-approved emergency response plan as per Directive 071 must be in place.

d. Proof of Directive 051 approval is required prior to commencement of injection.
e. The applied for maximum wellhead injection pressure (MWHIP) and justification if the MWHIP is above Directive 065, Appendix O, Table 1

f. The applied for maximum daily gas injection rate

g. The cumulative days required on an annual basis, for the temporary injection and indicate the total number of years required.

h. Specify the cumulative gas volume on an annual basis.

The application can be found in EAS under Directive 065, Gas Injection – ST.
AER Update to Survey and Mapping Requirements
On February 4, 2021 the AER released Bulletin 2021-04 indicating that changes had been made to the Pipeline Rules and the Oil and Gas Conservation Rules (OGCR) that affect survey and mapping requirements.

Section 4(1) of the Pipeline Rules was amended to remove the requirement to survey "before the commencement of construction." Pipelines must still be surveyed within the timeframe given in the pipeline approval.

Section 2.020(3)(c)(i) of the OGCR has been repealed, meaning applicants are no longer required to submit the elevation of the corners of the well surface lease. However, this section still requires operators to provide the elevation of significant water bodies, the topographic and drainage patterns, and the general spatial and topographic information. A corresponding change has been made to rescind requirement 16(g)(i) in section 7 of Directive 056. The AER also rescinded requirement 18 in section 7. Survey plans based solely on remotely sensed, three-dimensional survey data (like LiDAR) are not acceptable. Though these data can still be used to support a survey plan.

Additional information can be found here.
AER Changes to the Exploration Regulation and Associated Directives
On January 22, 2021, the Government of Alberta amended the Exploration Regulation under which the geophysical industry is regulated in Alberta. These amendments include the following:

  • The contents of the former 26 exploration directives have been consolidated into a single Exploration Directive.
  • A number of technical, operational, and procedural requirements have been transferred from the regulation into the consolidated directive.
  • Some administrative changes have been made to the regulation, including clarifying the ministry responsible, clarifying requirements around existing financial deposits, and providing timeline and process flexibility for complex applications.

The amended Exploration Regulation can be found at the Queen's Printer. The consolidated Exploration Directive can be found at https://open.alberta.ca/publications/exploration-directive.

Additional information can be found here.
Manitoba – Enhanced Oil Recovery (EOR) Report Waiver
The Regulatory Services Branch may waive the EOR Report requirement on a case-by case basis. The company must demonstrate that the remaining recoverable reserves are five percent (5%) or less of the total estimated recoverable reserves for each unit. Once the requirement is waived it will be exempt for all future years.

Additional information can be found here.
Saskatchewan – Stratigraphic Isolation of Fresh Water Formations During Well Abandonment 
The Ministry of Energy and Resources has published a new guideline, Guideline PNG044: Stratigraphic Isolation of Fresh Water Formations During Well Abandonment to provide industry with further direction and clarity regarding fresh water stratigraphic isolation requirements mandated within Directive PNG015: Well Abandonment Requirements (Directive PNG015).

Please note that guideline documents are intended to provide additional clarity in regards to existing requirements found in Directives and Regulations.

Additional information can be found here.
BC Oil and Gas Commission – Changes have been made to the Environmental Management Act (EMA)
The Government of British Columbia has approved stage 13 amendments to the Environmental Management Act (EMA) and Contaminated Sites Regulation (CSR) regarding changes to the current process for identifying contaminated sites.

The Site Profile document is amended with the Site Disclosure Statement and the timing of the required submission of the forms has changed.

Changes to the Certificate of Restoration (CoR) process have also been made. Details of the changes to the legislation and CoR process can be found here.
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. 
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