Commingling production occurs when two or more pools are produced without segregation in the wellbore. Commingled production is regulated under sections 3.050 and 3.060 of the Oil and Gas Conservation Rules (OGCR).
Segregation of production in the wellbore is regulated to
- avoid wellbore and reservoir conditions that may adversely affect resource recovery,
- maintain the ability to gather data on an individual-pool basis for resource evaluation and reservoir management,
- ensure operational safety, and
- ensure the protection of non-saline groundwater.
While these reasons for segregated production remain valid, commingling of production from multiple pools in the wellbore after approval by the AER is a longstanding practice in Alberta that has occurred over a wide range of formations and depths. The AER recognizes that commingling maximizes conservation in many cases and is necessary for economic and orderly development of lower-productivity resources.
Sections 3.1.5 and 3.1.6 of Directive 065: Resources Applications for Oil and Gas Reservoirs allow commingling to occur without an application being filed or an AER approval being issued if the associated risk is low and specific requirements are met. For higher-risk situations, if the commingling of production from two or more pools in the wellbore is desired, an application for approval to commingle must be submitted to the AER in accordance with section 3.1.8 of Directive 065.
The applicant will submit its commingling application through electronic applications submission (EAS). Applications are registered using the Integrated Application Registry (IAR), and all material related to an application is stored in this system.
Please note the following clarifications and explanations for commingling applications:
Commingled Streams that Contain H2S
Where the H2S concentration for the proposed commingled production stream is 100 parts per million or greater, the following information must be submitted with the application:
- The H2S release rate and the calculated emergency planning zone size for the operation
- The distance from the proposed commingling operations to the nearest surface developments (i.e., occupied permanent or part-time dwellings, and publicly used facilities including campgrounds, places of business, and any other surface development where the public may gather on a regular basis)
- The distance from the proposed commingling operations to the nearest urban centre
- Which emergency response plan will be used for the proposed commingling operation and the date the plan was last updated
Review Process for Commingling Applications
After the application is received, it will be reviewed for completeness in accordance with the requirements set out in table 3.2 of Directive 065. If the application is determined to be incomplete and deficient, the application will be closed with an explanation. If the application is determined to be complete, a review will be conducted as follows:
- Notice of all applications will be published on the Public Notice of Application page on the AER website to encourage public participation throughout the application process. This is in addition to any notification requirements an applicant must fulfill before submitting an application.
- A person who believes they may be directly and adversely affected by an application may file a statement of concern (SOC) with the AER.
- If an SOC about an application is received, the application is considered “Non-Routine” and must follow the AER’s SOC procedures and will not be subject to the application timeline.
- Staff will check that the requested commingling does not qualify for DE or SD commingling, and that the approval does not already exist in the MU orders.
- Staff will ensure that the application contains all of the requirements set out in table 3.2 of Directive 065, depending on the table’s “Reason for filing a commingling application,” and that these requirements are complete. The requirements in the application MUST be listed in numerical order.
- Staff review will focus on the impact of the proposed commingling on resource recovery, conservation risks, pool depletion, resource evaluation and reservoir management, operational safety, and protection of non-saline groundwater.
- If clarification or additional information is required, you might receive an e-mail request for more information.
- If an application does not meet Directive 065 requirements, it will be closed.
- Changes to an MU order will be made for complete applications that meet all applicable requirements.
- You will receive an e-mail notification when your application has been dispositioned. You can find the disposition by following the link provided in the notification e-mail for 30 days after the date of disposition.
- After the 30-day period, the disposition document and a copy of the application documents can be ordered through the AER’s Information Distribution Services Group at InformationRequest@aer.ca or (403) 297-8311.
Some decisions on the application can be appealed by eligible persons based on the Responsible Energy Development Act. The filing requirements for a request for regulatory appeal, including form, content, and time limits, are set out in section 30 of the Alberta Energy Regulator Rules of Practice. The regulatory appeals procedures are set out in sections 30 through 33 of the Alberta Energy Regulator Rules of Practice.
The processing time for this application is 120 calendar days.