Reminder That The Pre-2019 Substance Release Extension Request Deadline Is April 30th, 2021 Under EPEA Remediation Regulation

The Remediation Regulation was ratified on January 1st, 2019. This regulation requires licensees to report known impacts from releases on Legacy Sites that have not been remediated within two years of discovery.

If licensees are not able to meet reporting requirements within a two-year time frame, the AER will consider one company-wide extension request from authorized representatives of licensees.

To request extensions, licensees must e-mail request letters to CSUsubmissions@aer.ca before April 30th, 2021 with “Pre-2019 RAP Extension Request” in the subject line. The extension request letter should provide rationale for the extension, how risk is being managed in the interim, and a reasonable timeline.

Starting on April 22, 2021, licensees will have the ability to report and submit pre-2019 remedial action plans (RAP) on the AER’s OneStop platform.

The reporting of Legacy Sites (those that have known impacts identified prior to January 1st, 2019) may impact licensees in the following ways:

  • ARO and Shareholder Transparency: the disclosure of many long-term remedial liabilities could impact shareholder and investor perception.
  • Licensee Capability Assessment (LCA): a company’s ability to manage spills and site closure is listed as one of the “Key Performance Indicators” under the AER’s new Liability Management Policy.

Resources

The following Regulations and Resources referenced above are available for review:

About 360 Energy Liability Management

360 is a liability consulting firm focused on helping clients with their full closure cycle. For every well, pipeline, facility, or site at the end of its productive lifespan, 360 is there to help understand costs, manage obligations, and define risks – and as a result, make closure simple.

Our Services:

  • Liability Assessment & Strategy
  • Site Abandonment & Decommissioning
  • Environmental Reclamation & Remediation

Dear user, please be aware that we use cookies to help users navigate our website content and to help us understand how we can improve the user experience. If you have ideas for how we can improve our services, we’d love to hear from you. Click here to email us. By continuing to browse you agree to our use of cookies. Please see our Privacy & Cookie Usage Policy to learn more.