CBM Control Well Exception

 

CBM Control Well Exception

The control well exception process provides the AER with the means to administer an exception for coalbed methane (CBM) producing wells that are not currently covered by control well requirements.

Exception applications are for situations in which it would be too onerous for companies to designate new control wells to provide either full areal or zonal coverage. It was also decided to grandfather in CBM wells produced before 2006.

The following outlines the process to follow to get approval for an exception to the control well requirements. It includes links to application submission procedures and guidance documents.

Application Submission for Control Well Exception

The applicant will submit its CBM control well exception application 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 Control Well Exception Applications

After the application is submitted through DDS and received by the AER, the application process will take place 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.
  • 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 must go for leadership approval. Staff will review the geologic aspects of the proposed exception application—the review will focus on the reason for the exception request. Exceptions may be granted for the following reasons:
    • Legacy wells—Control wells are required for all CBM production under amendments to the OGCR enacted on October 31, 2006. Licensees may apply for exceptions to control-well requirements on the basis of legacy development for CBM wells producing before October 31, 2006.
    • Other exceptions—In some other circumstances, the AER will consider applications for exceptions to control-well requirements on a well basis only.  The following are examples of such circumstances:
  • A well is designated by the AER as a farm gas well with CBM production
  • A well is in an area that has discontinuous coal zones where the extent of the coal cannot be reasonably predicted, mapped, or correlated.
  • A well is in an area isolated from other CBM wells, a well has unproductive CBM completions, or no further CBM development is expected in the area.
  • 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 make a decision on the application and technical recommendation.
  • 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.