Regulatory Intelligence
Does non-routine abandonment work require approval before field work begins?
Category:
Well Abandonment
Research Basis
Archive Period
2017-2022
Records Reviewed
6
Primary Topics
Directive 020; Well Abandonment; Non-Routine Abandonment; Variance Requests; Zonal Abandonment; Closure Programs
Current Reference
AER Directive 020
Common Question
Does non-routine abandonment work require approval before field work begins?
Archive Findings
Yes. The archive is clear on this point. The DDS non-routine abandonment guidance states that non-routine abandonment operations require ERCB approval before the work is started, and the related correspondence reinforces that approval was required before abandonment work could begin. The folder also shows why timing and sequencing mattered. Before a non-routine abandonment request could be made, related well information such as completion or perforation data may have needed to be submitted through DDS. The correspondence also indicates that other notifications or regulatory processes could be triggered by the field activity itself, especially where a well had been re-entered or where non-routine plugging was being considered. The deeper lesson is that non-routine abandonment was not just a submit-a-form exercise. It was part of a sequence: understand the well status, confirm the data in the reporting system, determine whether the proposed work is routine or non-routine, make any required submissions, and obtain approval before starting the work.
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Engineering Insight
Engineers should treat non-routine abandonment planning as a regulatory sequencing problem as much as a field execution problem. The archive shows that uncertainty about approval timing can become operationally important, particularly where a rig is available or work is already being planned. A practical takeaway is to identify the non-routine element early. If the planned program may depart from standard Directive 020 abandonment requirements, the approval pathway should be confirmed before equipment is mobilized or abandonment work begins.
Current Guidance
Current requirements for non-routine abandonment approval should be reviewed against the current version of AER Directive 020 and the current AER submission process. Historical DDS references provide useful context but should not be treated as current procedural instructions unless confirmed against current AER systems.
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