Regulatory Intelligence
Can two gas proration batteries be combined simply because they share a common sales point?
Category:
Measurement and Reporting
Research Basis
Archive Period
2018-2020
Records Reviewed
4
Primary Topics
Directive 017, proration batteries, production measurement, proration factors, measurement by difference
Current Reference
AER Directive 017; AER Manual 011; Petrinex reporting requirements
Common Question
Can two gas proration batteries be combined simply because they share a common sales point?
Archive Findings
No. An analysis of historical regulatory correspondence shows that combining gas proration systems depended on facility configuration, not simply the fact that production ultimately reached a common sales point. The archive specifically distinguishes between a common sales point and a common group point. The reviewed records indicate that, for two proration systems to be treated as one, the wells needed to be configured consistently with the applicable proration battery subtype and flow to a common group point with common separation, measurement, and storage. The historical correspondence also shows that the relevant definition was not necessarily found only in Directive 017; facility subtype definitions in Manual 011 were also important.
Engineering Insight
Facility configuration matters. A shared sales point may be too far downstream to demonstrate that two proration systems function as a single proration battery. Engineers and regulatory staff should evaluate where commingling occurs, where separation and measurement occur, and whether the facility configuration matches the applicable reporting subtype. The archive supports a practical lesson: when dealing with proration battery questions, do not rely only on sales disposition. Review the actual measurement schematic and the reporting definitions that apply to the facility subtype.
Current Guidance
Current measurement requirements should be reviewed under AER Directive 017. Facility subtype and reporting definitions should also be checked against current Manual 011 and Petrinex reporting requirements.