In 2018, the Petroleum Technology Alliance Canada (PTAC) put out a request for proposals entitled Reclamation Practices on Upland and Peatland Well Sites. The project was established in response to challenges experienced by practitioners, regulators and industry related to reclamation certification of legacy sites. The specific sites in question are those that were constructed using imported mineral soil pads in peatlands, and upland sites that that have had natural vegetation encroachment. These sites generally present one or more reclamation deficiencies according to the applicable wellsite criteria and
cannot receive a reclamation certificate without additional scrutiny and justification under current regulatory criteria and policies. The goal of the overall project is to provide recommendations for an acceptable policy framework/decision support tool(s) to assist industry and regulators in making decisions around appropriate management and certification of these sites that ensures that functioning ecosystems are developed and that there is a process that outlines eligibility for reclamation certification. To date the project has been conducted in two stages. This report describes the work in Stage 2 related to sites that were constructed using imported mineral soil pads in peatlands (a separate Stage 2 report has been prepared dealing with upland sites).
When dealing with peatland sites, the question arises of whether to remove mineral soil pads in peatlands. There has been inconsistency in how decisions about these sites are being made (i.e., different levels of reclamation effort have been applied) and in how reclamation criteria are interpreted and applied in terms of defining what are acceptable conditions for certification. Historically, industry and regulators have agreed that in certain site-specific circumstances, sites with mineral pads in peatlands can be certified without the removal of the pad or with partial removal of the pad. There has been a recognition that sites can be deemed to be on a trajectory towards developing a sustainable plant community from an ecological perspective, and to not be causing off-site impacts, without further disturbance/reclamation. A consistent and standard method to define and address these circumstances has been difficult to discern within the current regulatory and policy framework.
Stage 1 of the project identified that there is limited guidance on how decisions are being made to accept or reject requests for a change in land use and that there are misperceptions associated with why requests are being made (from the government/regulator perspective) and how the requests are being evaluated (from the industry/practitioners perspective) (Tokay et al. 2019). It was determined that these perceptions must be addressed before meaningful change can occur. Stage 1 also identified the key factors to consider when assessing the ecological implications of a change in land use request (hydrology, cumulative effects and regional considerations, upland function, status of the borrow pit, site location, and land use considerations) and a number of knowledge gaps which should be addressed to confirm the effectiveness of a decision support tool and policy framework. However, consultation with Alberta Environment and Parks (AEP) and Alberta Energy Regulator (AER) regarding the findings from Stage 1 was recommended before developing a policy framework and research project to address the knowledge gaps to ensure resources are allocated appropriately.
The Certification of Mineral Soil Pads in the Boreal Region – A Path Forward working session was held in December 2019 for the purpose of facilitating a productive discussion involving industry (Oil and Gas and Environmental Consultants) and government (AEP and AER) related to change in land use requests. The objective was to inform a path forward for a policy framework that provided clarity on the process to request a change in land use and the criteria for evaluating the requests.
A total of 30 people representing AEP, AER, oil and gas industry, environmental consulting companies and the project team participated in an open, productive discussion. An overview of the key findings from Stage 1 of the project was presented to the group (Appendix B) to provide context for the discussion.