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

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.

The Proposed Co-operation Agreement on Environmental and Impact Assessment between Canada and Alberta

By: Nigel Bankes

Document Commented On: Draft Co-operation Agreement on Environmental and Impact Assessment between Canada and Alberta, March 6, 2026

PDF Version: The Proposed Co-operation Agreement on Environmental and Impact Assessment between Canada and Alberta

On March 6, 2026 the Governments of Canada and Alberta released a draft co-operation agreement on “Environmental and Impact Assessment”, thereby leading the way to fulfilling one of the undertakings contained in the Memorandum of Understanding on Energy (MOU) signed by the two governments on November 27, 2025. The MOU committed the parties to “Negotiate a cooperation agreement on impact assessments on or before April 1, 2026, that reduces duplication through a single assessment process that respects federal and provincial jurisdictions.” The Draft Agreement is open for comment until March 26, 2026.

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

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. 

The Mess We’re In: Insights from the 1st International Colloquium on Closure Liabilities in the Energy Sector

By: Kaitlin Schaaf, Kathy Cao, Jessica Farrell, Andrew Simmons, Emilia Yassiri, and Martin Olszynski

Matter Commented On: 1st International Colloquium on Closure Liabilities in the Energy Sector

PDF Version: The Mess We’re In: Insights from the 1st International Colloquium on Closure Liabilities in the Energy Sector

The 1st International Colloquium on Closure Liabilities in the Energy Sector was a recent three-day event organized by Professor Martin Olszynski, the current Chair in Energy, Resources and Sustainability, and hosted by the University of Calgary Faculty of Law with the support of the Public Interest Law Clinic (PILC) and the Canadian Institute for Resources Law (CIRL). From October 3 – October 5, 2025, the event brought together scholars and practitioners from Canada, the United States, Australia, and the United Kingdom to address the challenges associated with environmental liabilities in the energy sector.

A Review of Closure Nomination for Inactive Oil and Gas Sites and AER Updates to Directive 088 

By: Drew Yewchuk & Shaun Fluker 

Regulatory Bulletin Commented On: Alberta Energy Regulator, Bulletin 2025-32, Invitation for Feedback on Proposed Revisions to Closure Nomination Requirements in Directive 088 

PDF Version: A Review of Closure Nomination for Inactive Oil and Gas Sites and AER Updates to Directive 088 

The Alberta Energy Regulator (AER) is taking comments on some proposed changes to the process for nominating oil and gas sites (facilities and wells) for closure work. The comment period is open until November 12, 2025. The AER’s closure nomination system has been in place since April 2023, and one of us commented on its commencement in Updates to the Oil and Gas Liability Management Framework: The New Closure Nomination and The Renamed Closure Quotas. The proposed changes adjust the timelines for the closure nomination. In particular, they shorten the timeline for nominated sites that had already been decommissioned to complete a phase 1 environmental site assessment from three years to one year, and they extend all closure nomination timelines to the end of the quarter-year. This post reviews the public information on the closure nomination process so far, discusses the AER’s proposed changes, and assesses the effectiveness of the closure nomination process so far.  

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