November 2022
Happy Holidays from Benoit
Wishing you a festive season of sheer joy! May your days be filled with peace, hope and joy this holiday season. Merry Christmas and Happy New Year 2023!

As always, thank you for your business, loyalty and support. 
AB Reminder: Directive 040 pressure requirements 
Directive 040 Section 2.2.3 requires that annual pressure and testing surveys be completed by December 31, 2022 and submitted by March 31, 2023

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 2022 requirement. 
Contact us if you require assistance requesting a waiver.

The list of wells and projects requiring annual testing can be found HERE
AB: Reminder of Closure Spend Reporting Requirements
The AER announced that with the release of Directive 088: Licensee Lifecycle Management on December 1, 2021, all licensees with inactive inventory are required to meet an annual mandatory closure spend target. Under this directive, each licensee must report to the AER all its 2022 closure activities and closure spends to OneStop by March 31, 2023. 

The AER monitors reporting progress and strongly recommends that licensees begin their reporting as soon as possible to ensure they can resolve any discrepancies or other issues they encounter while still meeting the deadline.

As per section 3.6 of Manual 023: Licensee Lifecycle Management, all costs can be updated multiple times for 2022. The most recent submission overwrites any prior submissions. Closure spends reported after the March 31, 2023 deadline will not be considered. See section 3.6 and Appendix 1 of Manual 023 for more details. 

Additional information can be found here: Bulletin 2022-36
AB: Revisions to Directive 088
The AER is proposing update to Directive 088: Licensee Lifecycle Management to support the Government of Alberta's new Liability Management Framework and rule changes announced in Bulletin 2020-26Feedback was accepted until December 6, 2022.  
The following update will be applied to section 4.2, "Closure Nomination," of the draft directive The introduction of the Closure Nomination Program, provides an opportunity for eligible requesters (e.g., private landowners, First Nations, Métis settlements, municipalities, disposition holders, ministers) to request the closure of a site.

Additional information can be found here: Bulletin 2022-35
AB: Extensions in Alberta Caribou Ranges
This Information Letter (IL) replaces IL 2020-20. In consideration of ongoing sub-regional planning for Alberta’s caribou ranges, Alberta Energy will consider applications for extensions of term to Petroleum and Natural Gas, Oil Sands, and Metallic and Industrial Minerals agreements which fall in whole or in part within a caribou range. Holders of agreements in caribou ranges may still pursue development, validation or continuation of their agreements in the normal course of business.

Every extension application must be submitted to Alberta Energy prior to the expiry of a qualifying agreement. Alberta Energy will grant extensions of term to qualifying agreements until the agreement expiry falls on its term date in 2026.

Additional information can be found here: Information Letter 2022-41
AB: Rental Waivers for P&NG Agreements with Shut in Wells
This Information Letter (IL) replaces IL 2017-35. It relates to Petroleum and Natural Gas (PNG) Agreements acquired prior to December 11, 1996, that have well(s) shut-in by the Alberta Energy Regulator pursuant to the Chard-Leismer Decision (Decision Report 2003-023) and Order 05-001.

As outlined in IL 2017-35, Alberta Energy extended rental waivers for an additional five-year period until December 31, 2022. As such, designated representatives of affected agreements will have to apply to continue to receive a rental waiver after December 31, 2022. In addition to rental waivers, affected agreements with expiry dates on or after September 1, 2003, also were granted term extensions.

Applications to continue to receive a rental waiver must be submitted by email (not through ETS) to Energy.Rentals@gov.ab.ca no later than February 28, 2023.

Rental waivers and term extensions can no longer be transferred with an agreement.

Additional information can be found here: Information Letter 2022-40
AB: Cold Lake Sub-regional Plan 
On December 1, 2022, the Alberta Energy announced policy direction on new and existing subsurface dispositions. The Cold Lake Sub-Regional Plan (CLSRP) provides the overarching policy direction for various land-uses in order to maintain the sub-region as a working landscape while also more efficiently placing and managing footprint.

Additional information and the details on policy can be found here: Information Letter 2022-39
SK: Directive PNG048
The Ministry of Energy and Resources (ER) has updated the requirements in Directive PNG048: Hydraulic Fracturing Requirements, effective December 9, 2022. New fields have been added and existing fields updated to reflect the new requirements. This enhancement allows users to report required information directly into IRIS as structured data when reporting a hydraulic fracture. The submission of the identified detailed structured data for hydraulic fracture reporting is required immediately. 
 
Additional information and the details on reporting can be found HERE
BC: Compliance Management Information System (CM-IS)
On Nov. 25, 2022, the BCOGC updated the Compliance Management Information System (CM-IS) to enable permit holders to receive inspection reports and manage non-compliances associated with inspections. These functions were previously managed through the Commission's KERMIT system. Technical Update 2022-03 and Industry Bulletin 2022-12 provide additional context for these changes.

Permit holders will now receive inspection reports and non-compliance notices through CM-IS. Users of KERMIT can use their same usernames and passwords to log in to CM-IS.

Additional information can be found here: TU 2022-06
Well Testing Services at Benoit
To support Benoit's regulatory application and compliance related submissions, Benoit 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 Reza Ali directly at 403.454.0430.
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 for more information. 
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We post regulatory updates to our LinkedIn company page on a weekly basis. Follow us to ensure you have access to the most up-to-date information. To view and follow our company page, please click here. 
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phone: 587.880.2249 | email: questions@benoitregulatory.com