ERCB Bulletin 2010-22 answers some questions regarding regulatory applications for CCS projects in alberta:
The Energy Resources and Conservation Board (“ERCB”) is responsible for the safe, responsible, and efficient development of energy resources in Alberta, including oil, natural gas, oil sands and coal. As part of this jurisdiction, the ERCB regulates approvals for the development and operation of carbon capture and storage (“CCS”) projects. The ERCB has answered some of the questions about how it will treat CCS project applications in Bulletin 2010-22, ERCB Processes Related to Carbon Capture and Storage (CCS) Projects.
Bulletin 2010-22 clarifies that the ERCB will use existing instruments to process applications for approval to develop and operate a CCS project, including the following (among others):
- key application requirements with respect to transportation of carbon dioxide (“CO2”) via pipeline and underground injection by well are set out in Directive 056: Energy Development Applications and Schedules and Directive 065: Resources Applications for Conventional Oil and Gas Reservoirs;
- the mineral rights owner must grant the applicant have the right to dispose of C02 into an underground geological formation;
- well classifications, completion, logging, and testing requirements for wells injecting CO2 are set out in Directive 051: Injection and Disposal Wells;
- monitoring, reporting and safety will be dealt with primarily through site-specific conditions on approval to be determined by the ERCB, as well as the Pipeline Regulation A.R. 84/2009, Directive 007: Volumetric and Infrastructure Requirements, Directive 017: Measurement Requirements for Upstream Oil and Gas, Directive 065 and Directive 071: Emergency Preparedness and Response Requirements;
- suspension, abandonment and reclamation will primarily be dealt with through the Pipeline Act, R.S.A. 2000, c. P-15, the Pipeline Regulation A.R. 84/2009 and Directive 020: Well Abandonment; and
- liability requirements and procedures are set out in Directive 001: Requirements for Site-Specific Liability Assessments in Support of the EUB’s Liability Management Programs and Directive 006: Licensee Liability Rating (LLR) Program and Licence Transfer Process.
The ERCB’s reliance on its existing instruments likely means that its past decisions with respect to acid gas disposal schemes will serve as a useful source for guidance on how the CCS project applications will be treated. For a recent example of such a decision, see Decision 2009‑073 + Errata, AltaGas Ltd. Applications for Two Pipeline Licences, an Amendment to a Facility Licence, and Approval for an Acid Gas Disposal Scheme, Pouce Coupe Field.
