Concurrent Production (CCP)

 

Concurrent Production (CCP)

Exploitation of the hydrocarbon resources of a saturated pool is expected to be done without drawing down the gas in the gas cap area, until it is determined that ultimate recovery of oil will not be adversely affected by so doing. A concurrent production (CCP) approval can be granted for the simultaneous production of the free gas associated with an oil pool, and the oil. This is only granted in situations where it can be proven that the drawdown of the free gas will not result in a resource conservation issue, or where it can be determined that the efficient exploitation of the resources cannot proceed without some drawdown of the gas cap gas.

CCP approval can be granted for the production of gas cap gas

  • from all wells in a pool, including gas wells;
  • from all wells in the pool, with the exclusion of gas wells;
  • from oil wells subject to a maximum gas rate limitation;
  • from oil wells subject to a maximum gas-oil ratio limitation;
  • from specific well intervals only;
  • with special operating conditions; and
  • with specific wells being exempt from the gas conservation requirement.

A Directive 065: Resources Applications for Oil and Gas Reservoirs application must be submitted in accordance with section 39(1)(e) of the Oil and Gas Conservation Rules for the approval to exploit an oil resource concurrent production with its associated free gas. The hydrocarbon pool must have a long enough production performance history to be able to technically assess the reasonableness of granting CCP approval before submitting this application.

The following outlines the critical information that the AER requires and the process the applicant must follow to get CCP approval for a hydrocarbon pool. It contains links to relevant application submission procedures and guidance documents.

Application Submission

A CCP application must be submitted using the Digital Data Submission (DDS) system, which is available through “Systems & Tools” on the AER website, www.aer.ca.

Applications are registered using the Integrated Application Registry (IAR), and all material related to an application is stored within this system.

All submissions made in relation to any application are held non-confidential by the AER and are accessible, upon request, by other interested parties.

Approval Process for a CCP Application

All applications are published on the Public Notice of Application (PNoA) page on the AER website (www.aer.ca) to encourage public participation in the approval process.

Applications are initially reviewed for administrative completeness upon receipt at the AER. The application may be closed if significantly deficient of Directive 065 requirements. If the application is declared administratively complete, a technical review will be conducted and will include the following (supplemental information may be requested during the review period):

  • Statements of concern (SOCs) filed by parties that may be directly and adversely affected by CCP for which approval is sought are evaluated for relevance to the application. If relevant, an SOC may necessitate a public hearing to address the stated concerns prior to the disposition of the application. The relevance of the SOC is decided by the AER director of subsurface authorizations;
  • Notification in accordance with Directive 065 guidelines to all parties who may be affected by CCP approval for a pool;
  • Application referral to AER Authorizations Subsurface (Geology), if required to ascertain the size of the gas cap relative to the oil pool and the average thickness of the reservoir rock;
  • The applicant’s reservoir fluid volumetric estimates and the AER database estimates;
  • An assessment of the reservoir pressure depletion trend and the effect of reservoir energy depletion on the production performance trend;
  • Evaluation of enhanced oil recovery potential, such as waterflooding and gas flooding;
  • The list of active producers in the pool and their completion details;
  • Gas conservation in accordance with Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting;
  • A technical memorandum, with disposition recommendations, and draft approval letter prepared and presented for supervisory review.

The reservoir engineering manager or the manager’s delegates make the final decision on the merits of any application and sign off on the approval. The application is finalized in accordance with the decision of the panel, when a public hearing is required.

Application approvals can be appealed after disposition if the SOC is received from eligible parties. Eligibility for an SOC is based on the Responsible Energy Development Act. The filing requirements and process for a request for regulatory appeal, including form, content, and time limits, are set out in sections 30 through 33 of the Alberta Energy Regulator Rules of Practice.

Application Timelines

The processing time for this application is 70 business days, and the AER aims to meet this target 95 per cent of the time. This timeline is made up as follows:

Task Business Days
Administrative Completeness 5
Assignment 5
Referral 20
Supplemental Information 10
Technical Review 20
Decision 10
TOTAL 70