Background
A new program from Alberta Energy Regulator (AER) offers operators a practical and quicker process to reduce reported liability. An application can be submitted through the AER’s Conditional Adjustment of Reclamation Liability (CARL) Program for sites where closure and reclamation activities have been completed, but do not yet have fully established vegetation to become eligible for a Reclamation Certificate.
General Information
Laura F., a Professional Agrologist with 12 years of experience, leads North Shore’s CARL program applications. When asked about the program, Laura noted that, “The program represents a simple submission using AER’s One-Stop platform to demonstrate all program requirements have been met so an operator’s reclamation liability can be reduced prior to final liability closure for a site. This applies to wellsites that have already been abandoned, remediated, and reclaimed to the applicable land use criteria, and the only remaining requirement is vegetation re-establishing at the site. On cultivated land, the associated reclamation liability is reduced to $5000 per site, while all other land uses are reduced to $9000 per site. This reduction is applicable for a period of 5 years or until a reclamation certificate is received, whichever comes first. The operator can apply for a one-time 2-year extension accompanied by a Detailed Site Assessment (DSA). If the operator does not submit a Reclamation Certificate Application (RCA) within the required timeframe, the AER will reinstate the full reclamation liability estimate.”
For one client, Laura clarified that their liability was reduced by $3 million through a desktop review and CARL applications.
Program Specifics
Laura followed up with, “Operators will need to provide specific information to the AER in their CARL request, primarily to ensure all previous assessments are complete and entered in One-Stop. These include a submitted Phase 1 ESA, Phase 2 ESA/Remediation (if applicable) and Record of Site Condition.” Regarding client feedback for the program, Laura stressed that, “Our clients see the value in the practical and quick process to reduce their reported liability. The application process overall is quite easy and straightforward, especially when all previous assessment work has already been entered into the system”. After completing large-scale CARL applications for multiple clients, she expects more questions about this valuable liability reduction tool.
For more information on how North Shore can support you on CARL Applications please email bd@northshoreenv.com.
