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Bulletin 2025-09

Validating Facility Operational Life-Cycle Statuses – Phase II

Release Date

We previously released Bulletin 2023-34 requesting that licensees provide information to validate the operational life-cycle status of certain facilities. After January 2024, any facilities where the operational life-cycle status could not be verified were then considered inactive and included in the licensee’s assessed inactive liability.

We have since identified additional multiwell batteries that may not have the necessary well-to-battery linkages in Petrinex to provide accurate life-cycle statuses. Because of this, some active multiwell batteries may be incorrectly deemed to be inactive. This could impact a licensee’s annual mandatory closure spend and licence transfer applications.

It is the licensee’s responsibility to validate the operational life-cycle status of these facilities. If a company has active multiwell batteries where the AER has identified the life-cycle status of inactive, they can complete the facility linking template (found on the Directive 011 webpage) and submit it to FacilityLifeCycle@aer.ca. After review and validation, the AER will confirm the updated life-cycle status and correct the information in our system.

Licensees are expected to maintain accurate records for their facilities and all other energy-related assets. The AER uses inactive liability to determine a licensee’s mandatory closure spend. The mandatory closure spend will not be adjusted once set, so licensees are encouraged to review and update their information as necessary. This may involve a licensee reviewing their licensed facility data in OneStop and requesting that the AER cancel the licence of a facility that was not constructed or requesting that the AER update the link between a Petrinex reporting facility ID and an AER facility licence:

OneStop also contains flowcharts that outline the process used to determine facility operational life-cycle status. The flowcharts can now be found under the Liability Assessment Report under the Glossary tab. 

For further information regarding the facility operational life-cycle project, please contact FacilityLifeCycle@aer.ca.