OFA submitted comments to the Ministry of Natural Resources and Forestry (MNRF) regarding the proposed regulatory provisions under the Oil, Gas and Salt Resources Act.
OFA endorses the Ministry’s proposed requirement for Special Projects pursuing authorization to establish full-cost, project-based financial security, prior to any site preparation. Additionally, OFA supports the proposal to eliminate any cap or combined cap to the maximum amount of security that operators must set aside going forward and eliminate any exemptions to security caps for all other well types in addition to Special Projects.
OFA recommends that the government direct efforts towards addressing the larger safety and environmental risks of onshore and offshore commercial orphan wells. OFA further suggests that the Ministry consider methods to help assist private well operators to access financial security to responsibly manage the end of life for all private wells and that landowner be given the opportunity to update easement or lease contract arrangements at the time of any conversion, change or transfer of a well licence.
Furthermore, OFA highlights the Ministry’s Abandoned Works Program, which assists landowners that discover abandoned wells on their property.
Previous related OFA submissions:
May 18, 2023 – OFA submission regarding proposed changes to the Oil, Gas and Salt Resources Act (ERO # 019-6752)