Lahee and Confidentiality Status Change

 

Lahee and Confidentiality Status Change

The following outlines the review process, how to submit an appeal for Lahee or confidential status, or both, and how to amend a well’s Lahee or confidential status. It includes links to relevant procedures and guidance documents. The licensee is responsible for selecting the correct Lahee and confidential assignment for a well when submitting a well licence application.

Lahee classifications are used to categorize a well before drilling based on the risk of drilling and production success that the well’s licensee will assume. It is important to ensure that a well’s Lahee classification is correct because Alberta Energy uses it for its royalty-based programs, and it is used in determining your drill-cutting requirements.

Well confidentiality is assigned to keep well-related information confidential from the public and to protect the well licensee‘s investment. For each well carrying a confidential status, the AER will initially assign an expected confidentiality release date of one year from the well’s finished-drilling date. To keep the playing field level for industry, the AER may review a well’s confidentiality at any time. If the well meets the conditions for release under section 12.150 of the Oil and Gas Conservation Rules (OGCR) or section 15 of the Oil Sands Conservation Rules, AER staff will revise the confidential status and will not notify the licensee. Therefore, it is strongly recommended that the licensee regularly review its confidential status during the first year to ensure the accuracy of its well’s classifications.

The Lahee and confidentiality assignments that have been selected for each well are reviewed for technical accuracy by AER staff soon after the licence has been issued. Lahee and confidential status for each well licence is reviewed at the same time, although each classification takes into account different criteria. Below are the considerations for Lahee and confidentiality classifications.

Request Submissions

Amendments to Lahee or confidentiality status as well as any issues concerning Lahee and confidentiality are to be sent by e-mail to Geoconfteam@aer.ca.

Review Process for Lahee And Confidentiality

The Lahee and confidentiality assignments that have been selected for each well are reviewed for technical accuracy by AER staff soon after the licence has been issued. Lahee and confidential status for each well licence is reviewed at the same time, although each classification takes into account different criteria. Below are the considerations for Lahee and confidentiality classifications.

Lahee Considerations

A Lahee classification is a “pre-spud” assignment to each well based on the geological complexities and the known existence of hydrocarbon accumulations (pools) in the area where the well is to be drilled. The classification takes into account the general degree of geological failure.

  • Lahee reviews take into account all zones to be penetrated by the well.
  • All pre-existing pools will be considered regardless of whether they have been exploited or officially designated.
  • Step-out distances vary depending on the size and trend of pools previously encountered in the region.

Because Lahee is a risk assessment based on pre-spud information, a Lahee revision after the well has been drilled and results obtained will not be accepted (except in cases where Lahee is being revised to a less exploratory classification).

Confidentiality Considerations

Wells may have an initial status of confidential, confidential below, or non-confidential. This status can change at any time during a well’s first year, providing it meets the specified criteria. There is no minimum confidentiality period, although confidential status may be granted for a maximum of one year from a well’s finished-drilling date.

  • For confidential status reviews, all zones in which a designated non-confidential AER order is present are taken into account.
  • If a well does not fall inside a designated non-confidential AER order, the well is deemed confidential.
  • If a well falls inside a designated non-confidential AER order but the well’s total depth is deeper, the well is deemed “confidential below.”
  • If a well falls inside a designated non-confidential AER order at total depth, the well is deemed non-confidential.
  • If a well meets the requirements to be confidential but the licensee chose the well to be non-confidential, whether intentional or in error, the AER will not propose to the licensee a greater confidential level. However, there are some exceptions if the well is licensed under section 2.030 of the Oil and Gas Conservation Rules.

The AER maintains the right to revisit and reassess a well’s confidentiality at any time during its first year, and if at any time the well meets the conditions for release under section 12.150 of the Oil and Gas Conservation Rules, the AER will revise the well’s confidential status and will not notify the licensee. Updated amendments to Lahee and confidential status can be viewed in Petrinex. Petrinex-related inquiries are to be directed to petrinexsupport@petrinex.ca.

Review Process

  • If the initial Lahee and confidential selections meet the appropriate classification requirements, no further action is taken.
  • If the initial Lahee and confidential selections do not meet the requirements, the AER will propose a revised classification and a letter will be sent to the licensee (contact identified on schedule 1). The letter will include the original selection and the AER’s proposed revision.
  • The licensee has 30 days from the date on the letter to respond to the proposed revision. If no response is received after 30 days, the AER’s proposed changes will be applied.
  • If the licensee disagrees with the AER’s revision, the licensee must notify and send an appeal package via e-mail to Geoconfteam@aer.ca within the 30-day period.

The Lahee and Confidentiality Appeal Process

An appeal package must be sent in within 30 days of the date of the AER’s proposed letter date. The appeal package must include

  • a cover letter stating the views of the licensee and any pre-spud information (e.g., maps, seismic, cross-sections, etc.) in support of keeping the original classification selection,
  • the full bottom-hole unique well identifier,
  • the licence number, and
  • the current Lahee and confidential status.

Once the submission package has been received, AER will review it for technical completeness. Any technical information that is submitted post-spud will be omitted. In some cases, additional supporting pre-spud information may be requested.

For appeals that do not align with section 12.150 of the Oil and Gas Conservation Rules, an alternative Lahee or confidential status could be agreed on. Once the appeal is reviewed and a decision has been made, a disposition letter will be sent to the licensee.

Operator Lahee and Confidentiality Amendment Process

The licensee may submit requests for Lahee or confidential status amendments at any time. Each request is reviewed using the Lahee and confidentiality considerations. Once the review is complete and a decision has been made, a disposition letter will be sent to the licensee.

Processing Timelines

The processing time for appeals addressing confidential status only and for requests for amending Lahee or confidentiality changes is 10 days. The AER aims to meet this target 90 per cent of the time.

The processing time for appeals addressing Lahee is 60 days. The AER aims to meet this target 90 per cent of the time.