Rescission of CBM Pressure and Flow Control Wells

 

Rescission of CBM Pressure and Flow Control Wells

The control well rescission process provides the AER with the means to remove coalbed methane (CBM) control wells that operators ask to be removed for various reasons.

Pressure and flow control wells gather coal-only information for the Alberta Energy Regulator (AER) to assess CBM resources and reserves. Flowmeter values and changes in reservoir pressure are examined for each CBM zone. This analysis is expected to improve the estimates of CBM recovery factors.

Before pressure and flow control wells were established, testing was required for every CBM-producing well. A single pressure and flow control well is validated and tested to meet the requirements for all CBM production within a specified area.

CBM developers are encouraged to work together in selecting control wells in a CBM development area in order to make the control well designation process as effective and efficient as possible for all parties.

As more and more pressure and flow control wells were added, it became apparent that there needed to be a mechanism for dealing with situations in which an operator would ask to remove a well as a pressure and flow control well. These rescission applications are made for several reasons, including the following:

  1. Overlapping control wells in certain areas meant that some control wells could be removed with no loss of coverage to any well.
  2. Mechanical problems. Failed compressors or other mechanical issues could make a control well unable to produce.
  3. Low or no productivity. As pressure and flow control wells continued to produce, some wells reached the end of life and were no longer productive.
  4. A proposed replacement well has better vertical coverage.

The following outlines the process to follow to get approval for the rescission of a CBM pressure and flow control well. It includes links to application submission procedures and guidance documents.

Applying to Rescind CBM Pressure and Flow Control Wells

Applicants can submit their CBM pressure and flow control well rescission applications through the Digital Data Submission (DDS) system. Applications are registered using the Integrated Application Registry (IAR), and all material related to an application is stored within this system.

Review Process for Rescission of CBM Pressure and Flow Control Wells

After the application is submitted through DDS and received by the AER, the application process will proceed as follows:

  • All applications will be published on the Public Notice of Application (PNoA) page on the AER website to encourage public participation in the approval process.
  • Statements of concern (SOCs) can be filed by parties that may be directly and adversely affected by the rescission of a CBM pressure and flow control well for which approval is sought. These are evaluated for relevance to the application. If relevant, a 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.
  • The application will be assigned to a processor and reviewed for administrative completeness—the processor will either recommend that an information-deficient application be closed, or proceed with a full technical review of the administratively complete application.
  • The processor will check internally to determine whether the land referred to in the application is within the Lower Athabasca Regional Plan or South Saskatchewan Regional Plan areas—if the application is within one of these areas, the application will go for leadership approval. Staff will review the geologic aspects of the proposed pressure and flow control well rescission application—the review will focus on the reason for the rescission request and on the effect it will have on surrounding wells.
  • The applicant may receive a request, called a supplemental information request, for additional information, if needed.
  • A draft disposition letter will be prepared for technically complete applications (once the review is deemed complete and uncontested)—the processor will recommend that the application be approved, denied, or closed, and the Geology signing authority will then review the technical recommendation and make a decision on the application. Upon disposition, the applicant will receive a link to the disposition letter. The letter can be accessed for 30 days through the IAR query tool—for access, go to www.aer.ca, under Systems & Tools.
  • Some appealable decisions on the application can be appealed by eligible persons based on the Responsible Energy Development Act—the procedures for regulatory appeals are set out in sections 30 through 33 of the Alberta Energy Regulator Rules of Practice.

The list of valid control wells is published to the AER website—to access, go to www.aer.ca under Rules & Directives, Control Well Requirements.