Author: Drew Yewchuk Page 1 of 20

B.A. (UAlberta) J.D. (UCalgary) LLM (U.B.C.) Drew was a full-time staff lawyer with the University of Calgary's Public Interest Law Clinic from 2018-2022. He is now an PhD student at the Peter A. Allard School of Law. His research focuses on administrative secrecy, access to information law, species at risk, resource law, and environmental liabilities.

The Orphan Well Association Annual Report 2025/2026: The Problem with the AER’s Long Run Plan for Orphan Oil and Gas Sites

By Drew Yewchuk

On July 30, 2026

In Energy, Oil & Gas

By: Drew Yewchuk

Matter Commented On: Orphan Well Association Annual Report 2025/2026

PDF Version: The Orphan Well Association Annual Report 2025/2026: The Problem with the AER’s Long Run Plan for Orphan Oil and Gas Sites

On July 15, 2026, the Orphan Well Association (OWA) released their annual report for 2025/2026. OWA annual reports provide insight into Alberta’s orphan oil and gas site problem and the pace at which the problem is being addressed (see the ABLawg posts on past OWA annual reports: 2022/2023; 2023/2024; 2024/2025). The OWA annual report is separate from the Alberta Energy Regulator (AER)’s annual liability management performance reports, which are concerned with the closure liability of oil and gas sites generally in Alberta, most of which still have operating licensees.

$120,000 Penalty for the 2023 Kearl Tailings Overflow

By Drew Yewchuk

On July 2, 2026

In Administrative Law, Environmental, Oil & Gas

By: Drew Yewchuk

Regulatory Decision Commented On: AER News Release 2026-06-11, Imperial pleads guilty to EPEA violation in Crown’s summary disposition on Kearl

PDF Version: $120,000 Penalty for the 2023 Kearl Tailings Overflow

On 29 May 2026, Imperial Oil Resources Limited (Imperial) entered a guilty plea to a charge of contravening a term or condition of its Environmental Protection and Enhancement Act, RSA 2000, c E-12 (EPEA) approval by releasing a substance from the Kearl oilsands mine in early 2023, and on 11 June 2026 the Alberta Energy Regulator (AER) posted a news release publicizing that Imperial would pay a $120,000 penalty, $118,000 of which will go to a creative sentencing project.

Unpaid Oil and Gas Municipal Property Taxes: Another Problem for the AER’s Closure and Liability Management System

By Drew Yewchuk

On April 9, 2026

In Administrative Law, Municipal Law, Oil & Gas, Tax

By: Drew Yewchuk

Document Commented On: Property Tax Accountability Strategy (PTAS) Final Report and Recommendations, March 2026

PDF Version: Unpaid Oil and Gas Municipal Property Taxes: Another Problem for the AER’s Closure and Liability Management System

On March 16, 2026, the government of Alberta announced a new report on the ongoing problem of unpaid municipal property taxes by a segment of the Alberta oil and gas industry. The announcement says the report is “the result of the Property Tax Accountability Strategy (PTAS) working group, which comprised Alberta’s government, the Rural Municipalities of Alberta (RMA), and rural municipal administrators, with support from representatives of the Alberta Energy Regulator (AER) and the oil and gas industry as observers.” The PTAS Report includes a description of the problem, along with 17 recommendations to address the problem. This post reviews some highlights of the PTAS Report’s description of the problem and comments on the likely effectiveness of the PTAS Report’s recommendations.

AlphaBow Again Challenges AER Enforcement Related to Oil and Gas Closure Liabilities During Insolvency

By Drew Yewchuk

On February 23, 2026

In Energy, Environmental, Insolvency, Oil & Gas

By: Drew Yewchuk

Decisions Commented On: Re AlphaBow Energy Ltd., 2025 ABKB 622 (CanLII) (AlphaBow ABKB); Re AlphaBow Energy Ltd., 2026 ABCA 35 (CanLII) (AlphaBow ABCA)

PDF Version: AlphaBow Again Challenges AER Enforcement Related to Oil and Gas Closure Liabilities During Insolvency

This post comments on two decisions relating to the ongoing insolvency process of AlphaBow Energy Ltd. (AlphaBow). AlphaBow brought challenges to the power of the Alberta Energy Regulator (AER) to require security deposits as a condition for transferring oil and gas licences from AlphaBow’s inventory. AlphaBow was unsuccessful at King’s Bench and then failed to get leave to appeal from the Court of Appeal.

This post provides some background to AlphaBow’s insolvency, summarizes the two decisions, and concludes with commentary on what AlphaBow’s ongoing insolvency process shows about oil and gas closure liability management and insolvency in Alberta.

Grading the 2024 AER Liability Management Performance Report

By Drew Yewchuk

On February 5, 2026

In Energy, Environmental, Natural Resources

By: Drew Yewchuk and Shaun Fluker

Report Commented On: 2024 AER Liability Management Performance Report

PDF Version: Grading the 2024 AER Liability Management Performance Report

In November 2025, the Alberta Energy Regulator (AER) published the 2024 Liability Management Performance Report (2024 Report). This is the third AER Liability Management Performance Report to the public on progress to reduce Alberta’s massive unfunded closure liability in the conventional (non-oil sands mine) oil and gas sector. We discussed the 2022 report here and the 2023 report here. In a positive change from earlier years, the AER has kept the 2022 and 2023 reports up on their website. While this allows the public to compare information in the current report with past years, it is noteworthy that the AER itself does not use the previous years to evaluate performance and the 2024 Report provides almost no discussion or analysis of the data set out in the report. This is one of the reasons why the 2024 Report receives an F grade.