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 2026 Mine Financial Security Program Update: More Volatility in Liability Estimates and an Asset-to-Liability Problem with the Fort Hills Mine

By Drew Yewchuk

On October 23, 2026

In Energy, Environmental, Natural Resources, Oil & Gas

By: Drew Yewchuk

Documents Commented On: Annual Mine Financial Security Program Submissions 2026 Submissions for 2025 Reporting Year; Mine Financial Security Program – Security and Liability, September 29, 2026.

PDF Version: The 2026 Mine Financial Security Program Update: More Volatility in Liability Estimates and an Asset-to-Liability Problem with the Fort Hills Mine

This is the annual update following the posting of the submissions for the Mine Financial Security Program (MFSP) to the Alberta Energy Regulator (AER) website. See last year’s post here. The MFSP is Alberta’s troubled system for managing the financial security for the closure (decommissioning, remediation and reclamation) of oilsands and coal mines when they stop operating. For a detailed assessment of the weaknesses in the MFSP, see this 2023 paper coauthored with Martin Olszynski and Andrew Leach, “Not Fit for Purpose: Oil Sands Mines and Alberta’s Mine Financial Security Program”. In February 2025, the Alberta government made minor changes that did not address the fundamental problems with the MFSP – see our post here.

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.