Exemptions from Reclamation for Well or Facility Sites with Overlapping Activities

Licensees of well or facility sites where timely reclamation is prevented due to overlapping activities on the land area, may qualify to have the reclamation requirement under The Oil and Gas Conservation Regulations, 2012 exempted in full or in part.

Guidance

A licensee may apply to the Saskatchewan Ministry of Energy and Resources for an exemption from reclamation for an abandoned well or decommissioned facility where the site overlaps with another well or facility site that remains in operation. The overlapping licensed well or facility site may belong to the same or different licensees.

The ministry recommends the licensee seek and receive partial exemption approval before any reclamation work is carried out at the site, to ensure the boundary is established, prior to conducting the work to achieve an AOR application in the future. Further details and examples are provided in the Directive PNG016: Acknowledgement of Reclamation Requirements.

Eligibility

Before submitting an Exemption from Reclamation for overlapping activities, you must:

• Have an Integrated Resource Information System (IRIS) account and the appropriate permissions assigned by your IRIS Security Administrator.
• Be the registered licensee of the well or facility site in IRIS.
• Ensure any known contamination existing in the overlap is disclosed to the Ministry on the application form and to the licensee accepting responsibility to reclaim the overlap area (where the application involves two licensees).
• Verify in IRIS that the following is true for the licence proposed to have the overlap area exempt from reclamation:
  • Facility Infrastructure Status Type is 'Decommission’ or Well Status is “Abandoned” or “Cancelled” (where the site had been built, but the well was not drilled and the site reclaimed).
  • Abandonment Liability associated with the licence under the LLR Program is $0.00
  • NOTE: Unlicensed well or facility sites do not appear in IRIS or the LLR Inventory Reports. However, the AOR Program requirements still apply if there was any surface disturbance at the site.
• Verify in IRIS that the following is true for the licence proposed to carry the reclamation responsibility of the overlap area:
  • Well or facility licence appears in IRIS to ensure reclamation liability can be assigned, and reclamation responsibility can be tracked, under the LLR Program.
  • Well or facility licence appears in the LLR Well List or the LLR Facility List, and has not received a Grandfathered Reclamation Release, AOR or Full Exemption Approval.

How To Apply

To apply for an Exemption from Reclamation authorization:

1. Ensure you meet all eligibility requirements.
2. Obtain the most recent survey for both of the licences involved in the overlap activity. Each survey must clearly define the:
   • Boundary of the well or facility site
   • Boundary of the associated access road, where applicable
   • Surface co-ordinates of the given well, where applicable
   • Surveyed area assigned to the given well or facility site
   • Surveyed area assigned to associated access road, where applicable
3. Complete the Exemption from Reclamation (overlap activity) Form in accordance with the Directive PNG016 requirements:
   • All required information must be completed (i.e. if there is no non-exempt area remaining you must enter '0' instead of leaving it blank).
   • Refer to IRIS to ensure the correct owner names are provided for the licence numbers identified.
   • Both sections must be completed and signed and dated by their applicable representatives to validate the document regardless of whether the exemption involves a single or different licensees.
     • The first section provides details of the licensee of the licensed well or facility site requesting the exemption from reclamation due to overlapping land activity. Note: The Ministry's Orphan Fund Procurement Manager is the representative signature required for deemed orphan well or facility sites.
     • The second section provides details of the licensee of the licensed well or facility site accepting responsibility to reclaim the exempted/overlapping area of land.
     • Note: If the overlap activity involves different licensees the application must be completed jointly by the applicable licensees.
4. Prepare each of the surveys involved in the overlap activity as follows:
   • Use an arrow to clearly indicate the applicable wells or facility boundary and label it with the corresponding licence number.
   • Highlight the applicable areas (so you can still see the information beneath it):
     • Green: Overlap area being requested for exemption.
     • Yellow: Any remaining site or access area associated with the licence proposed for exemption.
     • Blue: Any remaining site or access area associated with the licence proposed to reclaim the exempted area.
   • Provide the calculations used to derive the area assigned to the site, access, overlap or non-overlap reported on the exemption form, where it is not obvious.
5. Prepare the application package as a single PDF document (no security applied):
   • Name it either "Licence# Exemption from Reclamation.pdf" or "Licence# Partial Exemption from Reclamation.pdf" depending on the application type.
   • Ensure the pages are oriented so they can be read on a computer screen.
• The applicable components must be presented in the following order:
  • Completed Exemption from Reclamation (overlap activity) Form
  • Survey associated with the licence requesting full or partial exemption from reclamation
  • Survey associated with the licence proposed to reclaim the exempted area
6. Log in to IRIS and complete the application process. For step-by-step details on how to complete the Partial Exemption From Reclamation application process in IRIS see Acknowledgement of Reclamation (AOR) at the User Learning Centre.

The status of the application is communicated to the applicant as a notification through IRIS.

When a full exemption application is authorized, the reclamation liability associated with the exempted licence under the LLR Program is zeroed.

When a partial exemption application is authorized, the reclamation liability associated with the exempted licence remains unchanged. Once the remaining portion of the site is reclaimed, the licensee would submit an AOR application (which excluded the exempted area) to have the associated reclamation liability removed.

Apply

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Further Information

Reclamation Responsibility for Exempted Area

If an Exemption from Reclamation (overlap activity) is approved, the responsibility to reclaim the exempted area is transferred to the licence, identified in the application, that the licensee signed to accept responsibility of the lands with the overlapping activity.

Please be advised that the ministry may increase the reclamation liability associated with a licence taking on the responsibility of the overlap area to ensure there is sufficient coverage of the exempted area.