Regulatory Intelligence
Should an operator submit a disposal application before final perforations or stimulation work are complete?
Category:
Applications and Approvals
Research Basis
Archive Period
2019
Records Reviewed
6
Primary Topics
application timing; perforation interval; acidizing; notification; hydraulic isolation logs; amendments
Current Reference
AER Directive 051; AER Directive 065; AER Directive 056; AER Manual 012
Common Question
Should an operator submit a disposal application before final perforations or stimulation work are complete?
Archive Findings
The 2019 correspondence captures a common timing problem. The well initially did not take enough fluid, and the operator was considering additional perforations and acidizing while wanting to keep the application moving. The regulatory advice in the archive was practical: apply for the largest interval that could be defended and notified, because narrowing later is easier than expanding after approval. The correspondence also cautioned that applying for one interval while testing or planning a different or larger interval could look misleading and would weaken the evidence package.
Engineering Insight
.png)
Need help with an application?
Our team can help you navigate regulatory requirements, prepare strong applications and avoid costly delays
587.880.2249
Before filing, reconcile four things: proposed perforated interval, notification interval, hydraulic-isolation logging interval, and the interval shown on the wellbore schematic. If the operator may add perforations, decide whether the application should cover the larger credible interval from the start. If post-approval changes are likely, identify what amendment may be needed and what evidence will be rerun. Do not rely on a log or notification program that covers less than the requested disposal interval.
Current Guidance
Current Directive 051 requires logs and the Well Summary/completion schematic to support the injection or disposal approval before operations begin. Current Directive 065 requires representative geological cross-sections, maps, fluid-interface interpretation, and confirmation of wells in the area of influence. Manual 012 and Directive 056 govern application procedures and participant involvement where applicable.