Proposed changes to section 4.2 of Directive 088 will impact closure nomination and reporting.
The Alberta Energy Regulator (AER) is seeking feedback on proposed changes to Directive 088: Licensee Life-Cycle Management intended to support the ongoing implementation and operationalization of closure nomination. Changes include clarifications to closure timelines, reporting requirements, and licensee expectations; specifically, section 4.2 of the Directive 088 draft includes the following changes:
- Revised table 1 of the closure plan activities:
- Sites without an “abandoned” licence status will have up to three years to complete abandonment, equipment removal, and Phase 1 environmental site assessment (ESA) closure activities.
- Sites with an “abandoned” licence status must complete equipment removal and the Phase 1 ESA within one year.
- Clarified the requirement for licensees to accurately identify any completed or outstanding closure activities for the site.
- Changed the reporting requirements, shifting from reporting by March 31 of each year to quarterly with specific completion dates.
- Added table 2 on closure activity reporting for closure nomination, so that licensees are clear on demonstrating compliance and progress for each required closure activity.
- Clarified that the transferee or amalgamation survivor is responsible for being aware of and verifying whether any licences it has received in a transfer application are part of an accepted closure nomination.
In the interim, licensees will still be required to complete closure activities and retain records of their activities as outlined in the current version of Directive 088. Reporting for closure activities under closure nomination is delayed for this year, and the AER will provide a notification when the new reporting requirements come into effect.
The AER is accepting feedback on the draft version of Directive 088 until November 12, 2025. RMA will review the draft directive and provide feedback. Members are encouraged to provide feedback on the draft version of Directive 088 and the proposed revisions by completing the public comment form on the AER website, emailing feedback to Closure.Nomination@aer.ca, or mailing comments to the AER at Suite 1000, 250 – 5 Street SW, Calgary, Alberta T2P 0R4.
Joseph Kay
Policy Advisor
587.689.5484
joseph@rmalberta.com
Warren Noga
Manager of Policy and Research
825.319.2285
warren@rmalberta.com