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.
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. Further details and examples are provided in the Directive PNG016: Acknowledgement of Reclamation Requirements.
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 the status of the well or facility in IRIS is one of the following:
- Cut and cap 'abandoned' or 'cancelled' for a licensed well
- 'Abandoned not reclaimed' for a licensed facility
- Ensure the abandonment liability associated with the site is zero on the licensee's Licensee Liability Rating (LLR) inventory and liability report (SIGN IN).
- 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's any surface disturbance at the site.
- Ensure the well or facility license you are proposing to transfer the reclamation responsibility of the overlap to:
- Ensure any existing contamination is disclosed to the Ministry and second licensee (if applicable) accepting responsibility to reclaim the area.
How To Apply
To apply for an Exemption from Reclamation authorization:
- Ensure you meet all eligibility requirements.
- Obtain the most recent survey for both of the licenses 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
- 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 license 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.
- 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 license 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 license proposed for exemption.
- Blue: Any remaining site or access area associated with the license 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.
- Prepare the application package as a single PDF document (no security applied):
- Name it either "License# Exemption from Reclamation.pdf" or "License# Partial Exemption from Reclamation.pdf" depending on the application type.
- Ensure the pages are oriented so they can be read on a computer screen.
Log in to IRIS. Depending on the type of overlap, complete either the Partial Exemption from Reclamation or Full Exemption from Reclamation application process.
- The applicable components must be presented in the following order:
- Completed Exemption from Reclamation (overlap activity) Form
- Survey associated with the license requesting full or partial exemption from reclamation
- Survey associated with the license proposed to reclaim the exempted area
The status of the application is communicated to the licensee as a notification through IRIS. Please be advised that a signed approval will no longer accompany the authorization approval on IRIS.
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 licensee identified in the application who accepted responsibility of the lands with the overlapping activity.
Liability Status for a Fully-Exempted Site
If an Exemption from Reclamation (overlap activity) is approved for the entire well or facility site, the reclamation liability associated with the exempted well or facility license under the LLR Program is zeroed. The Ministry may, however, increase the reclamation liability for the license receiving the liability to ensure there is sufficient coverage for the exempted area.
Licensees that use the LLR SIGN IN to review their inventory and liability reports will see the change reflected the next day. The approval is indicated by an 'F' in the 'Exemption from Reclamation' column in the applicable LLR Well List or LLR Facility List after the 1st of the month.
Liability Status for a Partially-Exempted Site
If an Exemption from Reclamation (overlap activity) is authorized for only a portion of the well or facility site, the reclamation liability associated with the partially exempt well or facility licenses under the LLR Program will remain unchanged.
The partial exemption approval is indicated by a 'P' in the 'Exemption from Reclamation' column in the applicable LLR Well List or LLR Facility List after the 1st of the month.
Once the remaining portion of the site that received partial exemption is reclaimed, the licensee submits an AOR application (which excluded the exempted area) to have the associated reclamation liability removed.