Benoit Regulatory Compliance Inc.

AB: Updated Requirements for Unpaid Municipal Property Taxes Effective September 15, 2024, and in accordance with Ministerial Order 096/2024, the AER will continue to require evidence that licensees have resolved unpaid property taxes exceeding a threshold amount before approving a new well licence application under Directive 056: Energy Development Applications and Schedules, Directive 089: Geothermal Resource Development, and Directive 090: Brine-Hosted Mineral Development or a well licence transfer application under Directive 088: Licensee Life-Cycle Management. The threshold for municipal tax arrears remains at $20,000. Listed licensees must continue to provide satisfactory evidence to the AER that arrears exceeding the threshold have been paid or that a payment arrangement has been made with the municipality or municipalities to which the arrears are owed. It is the licensee’s responsibility to gather and submit evidence when requested by the AER as part of the application process. For well licence transfer applications where the transferor is listed, the applicant must provide evidence that payment of municipal taxes exceeding the threshold is a condition of the purchase and sale agreement with the transferee. Additional information can be found: Bulletin 2024-22 https://lnkd.in/gk_P7gVP

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 has been posted to 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 https://lnkd.in/g57TqZjE

AB: Invitation for Feedback on Proposed Changes to Directive 071 The AER is seeking feedback on proposed changes to Directive 071: Emergency Preparedness and Response, Manual 026: Emergency Preparedness and Response Guide, and three new associated forms. The Directive will now applies to operations of different sizes, types, and hazards regardless of the duty holder’s energy and resource development activities or the phase of the development’s life cycle. The directive’s scope has been expanded and all duty holders within the scope are to have an emergency management program (EMP). The AER will accept the feedback on the proposed changes until November 25, 2024. Additional information can be found: Bulletin 2024-20 https://lnkd.in/gK3q_hPh

AB: Invitation for Feedback on Proposed Directive 065 The AER has requested feedback on its update to Directive 065: Resources Applications for Oil and Gas Reservoirs. The proposed changes are for “Unit 4 Disposal / Storage” for all types of disposal activities (Class I-IV disposal, gas storage and sequestration schemes). The AER will accept feedback on the proposed changes until September 16, 2024. Additional information can be found: Bulletin 2024-18 https://lnkd.in/gZRUibGn

AB: Facility Life-Cycle Status Changes On July 2, 2024, the AER announced changes to facility life-cycles that affected the determination of its inactive liability. Updated facility life-cycle statuses and their determination methods are available to licensees in the OneStop liability assessment report. One of the business rules used to determine a facility’s life-cycle status (whether it is active or inactive) comes from activity reporting at Petrinex reporting facility IDs. The AER has changed the business rules so that if any reporting facility ID other than a gathering system is active, the facility licence is considered active. Additional information can be found: Bulletin 2024-17

AB: Facility Life-Cycle Status Changes On July 2, 2024, the AER announced changes to facility life-cycles that affected the determination of its inactive liability. Updated facility life-cycle statuses and their determination methods are available to licensees in the OneStop liability assessment report. One of the business rules used to determine a facility’s life-cycle status (whether it is active or inactive) comes from activity reporting at Petrinex reporting facility IDs. The AER have changed the business rules so that if any reporting facility ID other than a gathering system is active, the facility licence is considered active. Additional information can be found: Bulletin 2024-17

AB: Updates to Directive 011 Estimated Liabilities On June 26, 2024, the AER released a new edition of Directive 011: Licensee Liability Rating (LLR) Program; Updated Industry Parameters and Liability Costs. The revision focuses on liability cost updates for well abandonments only, to be used in the new liability management framework. As part of the updates a new appendix has been added that includes the previous regional well abandonment cost tables, which will continue to be used for the LMR. The LMR can still be found in the Liability Rating Report in the Digital Data Submission (DDS) system but will be removed as part of the changes that will occur in the fall of 2024. Effective July 6, 2024, Licensees can access their specific liabilities using the new values in the OneStop Liability Assessment report. Additional information can be found: Bulletin 2024-16 https://lnkd.in/g_BEqfbJ

BC: Permits Required for Hydrogen, Ammonia and Methanol Operators All operators of existing or planned hydrogen, ammonia, or methanol manufacturing facilities in BC must apply for permits from the BCER. Individuals or companies currently producing hydrogen, ammonia, or methanol who have not previously contacted the BCER, as well as potential future operators of such production facilities, are required to contact the BCER directly. This is necessary to discuss the regulatory framework and the process for submitting permit applications under the Energy Resource Activities Act. The approach to regulating hydrogen production is explained here: https://lnkd.in/gjCdAeaS Additional information can be found here:IU 2024-08 https://lnkd.in/grUFx-gy

AB: Upcoming Changes to Emergency Planning Zones (EPZ) We want to inform you about an upcoming change affecting all wells in the province: the recalculation of the Directive 056 Emergency Planning Zone (EPZ). There will be no grandfathering; all wells will be subject to this new requirement. Previously, D056 EPZ calculations were based on the average values, pursuant to CAPP guideline 2012-0008, H2S Release Rate Assessment and Audit Forms. Moving forward, the EPZ will be calculated based on the maximum values. The release rate remains unchanged, but the EPZ will have to be recalculated and submitted to the AER. The AER plans to announce this change within the next few months. Stay tuned for future updates.

AB: Deadline to apply for the Emerging Resources Program The Emerging Resources Program (ERP) was introduced in January 2017 as one of two new royalty programs under the Modernized Royalty Framework. The intent of the ERP was to encourage the development of oil and gas resources in higher-risk and higher-cost areas that have large resource potential. Applications to this program can only be made on or before December 31, 2024. The program regulations and guidelines can be accessed on the Government of Alberta website: https://lnkd.in/gHcNndrZ Additional information can be found: Information Bulletin 2024-02 https://lnkd.in/gCSsYsZf