ERCB Play plan
Sharon McLeay
Times Contributor
In December 2012, the Energy and Resources Conservation Board (ERCB) released a new framework discussion paper, as to how they will deal with unconventional oil and gas development.
Due to the increased exploration activity in Alberta, and technological advancements that allow companies to drill vertically, the Board developed the discussion paper, www.ercb.ca, to get feedback on the suggest process.
“Alberta’s regulatory framework needs to evolve to meet new challenges, to provide all Albertans with assurances that the system effectively manages the risks associated with oil and gas development, to ensure efficiency in the regulatory system for industry and to deliver the policy outcomes established by the Government of Alberta,” said Darin Barter, ERCB Communications spokesman.
Wells won’t be approved on a well-to-well basis, but multi-companies will combine forces to develop a resource development plan (called a PLAY) over a geological and geographic area, considering the properties of the resource and the technology required to develop that resource.
The levels of risk to public safety, the environment and the resource itself would determine ERCB approval. Approval will not hinge on operators defining how they will meet regulations; they must only show achievement of play-specific outcomes. ‘Guiding Principles for Hydraulic Fracturing’ by The Association of Petroleum Producers (CAPP), is a cited as an example of industry recommended practises that would lead to achievement of outcomes.
The outcome challenges must address:
• Maintenance of the quality and sustainability of non-saline surface and ground water
• Conservation of resources, minimize waste, prevent pollution, protect the environment
• No measurable adverse air quality affects to public or environment
• Maximize economic recovery of reservoir fluids and conservation of gas
• Ensure all resource owners to have equal opportunities for equitable production shares
• Minimize regional issues and cumulative effects of oil and gas development.
• Ensure public safety.
• Understand and disseminate information of the play regarding resources, production capacity, reserves volumes, and other geological and reservoir characteristics.
Individual operators in the multi-company collaboration will provide a project plan for their own leases. Both the Play plan and Project plans must address water management, surface infrastructure development, subsurface reservoir management, stakeholder engagement and life-cycle wellbore integrity.
Since vertical drilling uses multi-well pads, the new process will combine approval for drilling individual wells and completing multiple wells with installing related production equipment on a pad, into one approval. Pad approvals could be used anywhere in the province.
Monitoring of performance and outcome achievements will be made public, to ensure accountability. The Board could supersede or modify existing regulations, to allow developers to adapt to requirements of the play. The framework paper suggests a regulatory response will be at a level proportional to the severity of the risk.
“Ultimately when the ERCB declares a Play, Wheatland County residents could expect to be much more engaged in the planning and consultation process as they will understand the entire development and activity. This will address the broader concerns Albertans have about air, water, land use etc.,” said Barter. “All companies who are a formal part of the Play would be responsible to ensure that their specific wells are operated safely and any residual issues are addressed. On a broader scale all companies would be responsible, under a Board Order to address concerns or incidents,” said Barter.
The ERCB sees company collaboration optimizing infrastructure, exchanging information, and allowing a one-window approach for communication with stakeholders.
On finalization of the new framework, two test trials of the Play format will occur, and any modifications to the framework incorporated, prior implementation.
“I respectfully submit that the Discussion Paper is highly responsive to landowner concerns, historically and those that have been expressed going forward. I encourage your readers to read the Discussion Paper carefully and provide their honest and full input and feedback. This is a unique opportunity for all Albertans to help the ERCB shape regulation going into the future,” said Barter.
All Albertans have until March 31, 2012 to submit their feedback regarding the new framework. Call toll free number 1-855-297-8311.
Provide your feedback by: urf_feedback@ercb.ca or by mail: Address to: Regulating Unconventional Oil and Gas in Alberta Energy Resources Conservation Board Suite 1000, 250 – 5 Street SW Calgary, Alberta T2P 0R4.