By: Drew Yewchuk
PDF Version: The December 2021 Mine Financial Security Program Standard
Regulatory Document Commented On: The December 23, 2021 Mine Financial Security Program Standard
In a post back in May 2021, I mentioned a quietly made change to Alberta’s Mine Financial Security Program (MFSP), which sets out the security requirements for coal and oil sands mines in Alberta: Continue reading
By: Drew Yewchuk
PDF Version: Bill 77, Unpaid Municipal Taxes, and the Connection to the Inactive and Orphan Wells Problem
Bill Commented On: Alberta’s Bill 77: Municipal Government (Restoring Tax Accountability) Amendment Act, 2021, 2nd Session, 30th Legislature
Alberta’s Bill 77: Municipal Government (Restoring Tax Accountability) Amendment Act, 2021 (2nd Session, 30th Legislature) is moving towards becoming law. This post describes what Bill 77 would do, explains the connection between oil and gas companies’ unpaid municipal taxes and Alberta’s orphan well problem, and describes some reasons why Bill 77 will be ineffective. Continue reading
By: Drew Yewchuk
PDF Version: The AER’s Mandatory Closure Targets are Deficient
Legislation Commented On: AER Bulletin 2021-23 ‘Mandatory Closure Spend Targets’
This is a follow up post to my June 24, 2021 post on the changes the Alberta Energy Regulator (AER) is making to the Liability Management Framework and specifically Draft Directive XXX: Licensee Life-Cycle Management (Draft Directive) meant to replace the current Directive 006 once finalized. Readers are encouraged to check that post for background context. Continue reading
By: Drew Yewchuk
PDF Version: The AER Announces Some Details of the Mandatory Closure Spend Targets
Legislation Commented On: AER Bulletin 2021-22 ‘Invitation for Feedback on Proposed New Licensee Life-Cycle Management Directive’; AER Bulletin 2021-23 ‘Mandatory Closure Spend Targets’
This is another post on the changes the Alberta Energy Regulator (AER) is making to the Liability Management Framework for conventional oil and gas assets. The earlier post I co-authored with Shaun Fluker on the problems with the liability management framework and the changes being made to it (and specifically the changes to the Eligibility Requirements for Acquiring and Holding Energy Licences and Approvals) is here. The AER is now seeking comments on Draft Directive XXX: Licensee Life-Cycle Management (the Draft Directive) until July 25, 2021. The Draft Directive will replace the current Directive 006 once finalized. This post discusses the Draft Directive and the details of the inventory reduction program first announced a year ago. Continue reading
By: Christine Laing & Drew Yewchuk
PDF Version: The Canada Energy Regulator Protects Trans Mountain from Canadians
Decision Commented On: Decision on Trans Mountain’s Request for Confidential Treatment dated 29 April 2021
The Canada Energy Regulator (CER or Commission) has the statutory duty to assess financial resources plans filed by operating pipeline companies each year and determine whether those resources remain sufficient to cover the company’s expected liabilities if a pipeline spills. The written review process is open to the public through postings on the CER’s website. Trans Mountain requested an exception to the typical public filing process, asking the CER to keep their insurers confidential going forward. On April 29, 2021, the CER granted the request by making an order under section 60 of the Canadian Energy Regulator Act, SC 2019, c 28, s 10 (CER Act) to keep the identity of Trans Mountain’s insurers confidential. The decision pertains to the insurance in place to cover liability for the operating Trans Mountain pipeline, not liability associated with its decommissioning or liability associated with the construction or operation of the Trans Mountain Expansion Project. Continue reading
