Preparing Variance Justifications for Reclamation Certification of Wellsites and Associated Facilities on Forested Land: 2023 Update

Heather Tokay
Kevin Renkema
Dean MacKenzie
Chris Powter
Bonnie Drozdowski
Natalie Shelby-James
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In 2018, the Petroleum Technology Alliance of Canada (PTAC) initiated a multi-stage project on the reclamation certification process for sites that were constructed using imported mineral soil pads in peatlands, and upland sites with vegetation on a trajectory to approximate natural forest vegetation but with one or more reclamation deficiencies according to the forested land criteria. These sites cannot receive a reclamation certificate without additional scrutiny and professional justification under current regulatory criteria and policies. The goal of the overall project is to ensure that decisions made during the reclamation certification process result in the best possible ecological outcome (i.e., net environmental benefit) for these sites and surrounding region. This document is focused on upland sites; a separate document has been prepared for sites that were constructed using imported mineral soil pads in peatlands.
Stage 1 of the project identified that there has been inconsistent approach applied to these sites during the reclamation certification process that may not result in the best possible ecological outcome and the inconsistency has created ambiguity in terms of defining acceptable conditions for certification. There are misperceptions of the decision-making process, lack of clarity for variance requirements and often a lack of scientific-based information to support professional justification used in variance requests. This document was developed during Stage 2 of the project to encourage preparation of complete and comprehensive variance requests to allow for consistent decisions that result in the best possible ecological outcome. A third stage of the project is planned as a field research program to address knowledge gaps identified in previous stages.
The first version of this document was published in late 2020 after undergoing an initial review by a small group of stakeholders including industry, practitioners, and decision-makers (Alberta Energy Regulator and Alberta Environment and Parks). In 2021, PTAC sought verification of the document from a larger audience and stakeholders were asked to apply the document to current sites in their work portfolio. Feedback was obtained during a knowledge transfer session, field verification and working sessions.