Operational Authorizations - Production Operations

 

Operational Authorizations - Production Operations

Operational Authorizations are secondary approvals granted to operating wells, facilities and pipelines. These requests may be due to unforeseen issues or events that could not be predicted during the submission of the licence application.

Operational Authorizations - Production Operations may include requests for approvals, waivers, extensions and/or regulatory variances for activities at operating facility sites and are focused on 3 main technical areas:

  1. Measurement – deviations from the measurement requirements found in Directive 017, Measurement Requirements for Oil and Gas Operations
  2. Equipment spacing1
  3. Other production operations requests1; for example, proposing an alternate use for a pop tank

    1Requests related to technical areas 2 and 3 should be included in the Directive 56 facility application whenever possible; the Operational Authorizations process should be used if:

    • it is being requested for a licence exempt site/activity (as defined by sections 5.5.1, 5.5.2 and 5.5.3 of Directive 56), or
    • it is being requested for an existing site where no licence amendment application is required (requirements for licence amendments can be found on pages 5-44 and 5-45 of Directive 56).

The following outlines the critical information requirements and the process to follow in order to obtain an operational authorization related to production operations. It contains links to relevant application submission procedures and guidance documents.

Application Submission

Operational Authorizations – Production Operations are submitted to the following email addresses:

For Measurement Deviations under Directive 17: Directive017Applications@aer.ca

For Equipment Spacing or Other Production Operations requests:
ProductionOperationsApplications@aer.ca

Paper submissions will not be accepted.

Applicants are required to identify the operator name, type of request it is seeking and the associated location in the subject line of the email communication; for example:

ABC Company, Chart Extension, 01-01-001-01W4M or
ABC Company, Spacing Waiver, 01-01-001-01W4M

Submissions that do not identify the type of request in this manner will be closed without further review.

Operational Authorizations - Production Operationsshould not be submitted to AER field centres unless anequipment spacing waiver is required during well servicing and completion.

Submissions are routed to the appropriate subject matter expert based on the type of request.

Review Process Summary for Operational Authorizations – Production Operations

Upon receipt at the AER, the submission is reviewed initially for administrative completeness. This portion of the review ensures the mandatory documents required to support a variance request have been attached and are relevant.

The mandatory documents are outlined in the Production Operations - Technical Check List. Applicants may include additional attachments to assist in the decision making process.

A detailed technical review is conducted to ensure the information submitted supports the variance or waiver request. Depending on the type of request, it may be necessary for staff to engage other AER experts through an internal referral process. Such referrals may extend the time required to process the request.

During the review it may be necessary to request additional information from the applicant to clarify the request.  If further information is required, a Supplemental Information Request (SIR) is sent to the applicant via email with a submission deadline of 5 business days, unless otherwise specified. An application may be closed if the SIR response is not received within the specified timeframe, if the minimum information described above is not submitted or if the mitigation proposed in support of the requested variance is not acceptable. The applicant will be notified via email of the decision. The application may be resubmitted upon receipt of the closure notice.

If the application is technically complete and an assessment of the risks associated with the request are deemed to be acceptable, an approval letter will be sent to the applicant via email notification.

Application Timelines

Measurement Deviation under Directive 17:  30 business days

Equipment Spacing or Other Production Operations request: 15 business days