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Following the provincial government’s announcement of the Alberta Site Rehabilitation Program (ASRP) on April 24th, 2020, North Shore has been inundated with calls and meetings with existing clients, potential clients, and environmental service providers curious on how they can take part in and receive some of the program benefits. With many details of the program not yet officially released, there are two common questions being asked:
- What will determine a licensee’s “ability to pay” and subsequent funding eligibility (25-100%)?
- If an application is made and desirable funding eligibility (e.g. 25% vs 100%) is not received, can the application be withdrawn?
These are all very good and important questions that we’re sure will be answered shortly and will ultimately have an impact on a licensees willingness to participate with various service providers in the program.
Some other concerns we are hearing is that the program is restrictive in terms of the potential funding being offered compared to the work required to complete a task (especially when there can be many unknowns to account for). This is especially true for a lot of the higher expense services like downhole abandonment and remediation activities. This initial phase of the ASRP may seem somewhat restrictive in the fact that funding is capped and applications are currently required to be made on a site by site basis. It is however important to consider that this initial phase will be a trial of the program with further revisions and details to follow in the implementation of future phases.
North Shore feels that it is equally important to maintain context of this program and what it is attempting to achieve. The main intention of the ASRP is to support eligible oil and gas service companies by creating jobs and putting Albertans to work, with the added benefit of addressing outstanding environmental liabilities in Alberta and perhaps also lessening future financial burdens on the province, the Orphan Well Program, and many of the currently active licensed producers. When reviewing the program goals, it is also quite obvious that the program itself is not necessarily focused on achieving site “closure” or completing all aspects of each closure activity under its funding model. It simply states that it is designed to accelerate abandonment and reclamation efforts and quickly complete a high volume of environmentally significant work. These goals align closely with the overarching intention of the program, to immediately get Alberta’s specialized oil and gas labour force back to work. Further to this, the list of eligible activities under the program is also quite broad. We feel that this is by design in order to allow flexibility to licensees and ensure service providers are able to make applications to conduct as many different closure tasks (or portions thereof) as possible.
As we await further application details regarding the initial phase of the program, we would also like to encourage licensees and service providers to consider opportunities for other “activities” that may be eligible for funding applications. Some of these opportunities could include partial or interim activities where, if completed, would:
- Help accelerate the site closure progress;
- Reduce, identify, or characterize potential surface or subsurface liability; and
- Continue the trajectory towards future site closure.
If possible, any remaining portions of the work required could then be deferred and completed at a later date and/or possibly under funding applications as part of future phases of the ASRP.
North Shore will continue to share information and work with service providers and potentially eligible oil and gas licensees to ensure we are positioned to effectively and efficiently maximize program benefits and opportunities when the application process is initiated on May 1st, 2020.
For additional information on how to work with North Shore as either an eligible producer/licensee, or as an applicable service provider, please contact us either by phone or the email below.
Contact – ABSiteRehabProgram@northshoreenv.com
Government Link – Alberta Site Rehabilitation Program
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