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From the Archive:

Can operators request a variance from standard abandonment requirements?

Does non-routine abandonment work require approval before field work begins?

If a well has pressure after abandonment work, is it considered abandoned?

When can zonal abandonment be treated as routine instead of non-routine?

Regulatory Intelligence 

Is closure planning only about abandoning individual wells?

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

Is closure planning only about abandoning individual wells?

Archive Findings

No. The archive indicates that closure planning extended well beyond deciding which individual wells to abandon. Historical correspondence describes closure as a broader compliance and planning framework involving Area Based Closure participation, mandatory and voluntary spend pathways, OneStop reporting, DDS reporting where appropriate, surface equipment removal timing, and differences between well risk categories. The records also show why these program-level decisions mattered. Enrolling in Area Based Closure could provide flexibility in where closure dollars were spent, allowing operators to focus on completing closure in an area rather than spreading work across several areas. The correspondence also discusses situations where certain medium-risk wells may have reduced downhole work or pressure-testing implications depending on the applicable closure pathway and risk type. The archive therefore supports a broader interpretation of closure work: it is not only a field abandonment program, but also a regulatory planning, reporting, spending, and prioritization exercise.

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Engineering Insight

The engineering and regulatory lesson is that closure planning should be integrated early. Operators may focus on the physical abandonment work, but the archive shows that program selection, spend commitments, reporting obligations, and well risk categories can influence both compliance strategy and field execution. For engineers and regulatory staff, this means closure decisions should not be made well-by-well in isolation. The better approach is to consider abandonment requirements, closure spend obligations, area strategy, reporting systems, and surface abandonment requirements together.

Current Guidance

Current abandonment requirements should be reviewed against AER Directive 020. Current closure spend, Area Based Closure, OneStop reporting, and liability management requirements should be confirmed against the current AER closure and liability management framework applicable at the time of planning.

Related Regulatory Insights

Historical newsletter insights that reference the same directive, manual, rule or regulatory requirement.

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This issue covers AER administration fees, orphan fund levy updates, phishing-awareness information, mineral-development sessions, cryptocurrency mining information requests, Directive 020, and Saskatchewan orphan levy and PNG017 updates.

Jul 31, 2024

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This newsletter combines Directive 040 reminders, Directive 020 feedback, well-licensing service information, and BCER incident and Treaty 8 items.

Feb 28, 2021

Directive 020 Commingled Abandonment and Gas Injection Applications

This issue discusses Directive 020 commingled well abandonment and short-term gas-injection application processes.

Jul 31, 2023

Industry-Wide Closure Spend Requirements and Directive 020 Feedback

This newsletter summarizes industry-wide closure spend requirements for 2024, Directive 020 feedback, ACCI, Directive 071, Saskatchewan liability items, and the BCER mandate.

May 31, 2023

Benoit+ Compliance Tools and Directive 020 Feedback

This newsletter highlights Benoit+ and compliance-tool development while also referencing CSA standard access, Directive 020 feedback, mineral-resource information, and Saskatchewan and BC updates.

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