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On June 29, 2011, the Energy Resources Conservation Board (ERCB) issued Bulletin 2011-20: Invitation for Feedback on Proposed Amendments to Development Entity and Self-Declared Commingling Processes. During the feedback period from June 29 to August 19, 2011, the ERCB received submissions from four companies. A summary of the stakeholder submissions is available on the ERCB website www.ercb.ca under Industry Zone : Rules, Regulations, Requirements : Commingling.
As no concerns were raised regarding the proposed amendments to the development entity (DE) and self-declared (SD) commingling processes, the ERCB decided to proceed with all of the proposed changes.
This bulletin announces the release of a revised edition of Directive 065, effective March 14, 2012, that incorporates all of the proposed changes to the DE and SE processes (Section 3.1), as well as other amendments announced in Bulletin 2012-05 and Bulletin 2012-06.
There are currently three processes for managing commingled production in the wellbore:
Details of the three commingling processes are provided in Directive 065. A well licensee uses decision trees to determine which process to use. If the proposed commingling does not meet the requirements for commingling through the DE or SD processes, the licensee must obtain approval for commingling through the application process.
1) Effective immediately, there are no notification requirements for DE and SD commingling processes. The original notification requirements were intended to provide information about what DE and SD commingling was occurring in any given area. Parties that are interested in determining whether DE or SD commingling is occurring may now refer to a list of DE and SD wells that is posted on the ERCB website under Industry Zone : Rules, Regulations, Requirements : Commingling. The list is updated daily and provides a reliable means of obtaining information about DE and SD commingling in an area of interest. Parties that have concerns about any DE or SD commingling that has occurred should follow the process set out in Directive 065, Section 3.1.7, Explanatory Note 7.
The existing notification requirements applicable to applications for approval to commingle production under Directive 065 remain unchanged.
2) The DE and SD decision trees have been amended to remove the following decision tree question:
Are there any water wells within a 600 m radius with a total depth less than 25 m from the top of the perforations of the well proposed for commingling?
This criterion is no longer necessary because other regulatory documents are in place to address well operations near water wells, including Directive 027: Shallow Fracturing Operations—Restricted Operations, Directive 035: Baseline Water Well Testing Requirement for Coalbed Methane Wells Completed Above the Base of Groundwater Protection, and Directive 044: Requirements for the Surveillance, Sampling, and Analysis of Water Production in Oil and Gas Wells Completed Above the Base of Groundwater Protection.
Changes have been made in the March 2012 edition of Directive 065 to clarify the DE and SD criteria. These changes do not represent any change in practice, policy, or requirements except where noted above. The requirements for commingling applications have also been amended to ensure that the commingling application process is harmonized with the DE and SD commingling processes.
The newly revised edition of Directive 065 is available on the ERCB website www.ercb.ca under Industry Zone : Rules, Regulations, and Requirements : Directives. Printed copies of the directive may be purchased from ERCB Information Services, 10 Floor, 250 – 5 Street SW, Calgary, Alberta; telephone: 403-297-8311 or 1-855-297-8311 (toll free); fax: 403-297-7040; e-mail: email@example.com.
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Acting Executive Manager