Commingling

Timeline

Our estimated processing time for this application is 45 business days. See our timeline spreadsheet for updates.

Purpose of the Application

In commingled production, resources like oil and gas are produced from multiple pools beneath the ground and are brought to the surface together through a common wellbore. Commingled production is regulated under sections 3.050 and 3.060 of the Oil and Gas Conservation Rules.

Commingled production is a longstanding practice in Alberta. It has occurred over a wide range of formations and depths. In many cases, commingling helps conserve resources and supports economical and orderly development of lower-productivity resources.

However, commingling must be regulated to

  • avoid wellbore and reservoir conditions that may adversely affect resource recovery,
  • maintain the ability to gather data on an individual-pool basis for resource evaluation and reservoir management,
  • ensure operational safety, and
  • ensure that nonsaline groundwater is protected.

For these reasons, companies must submit commingling applications to us to review before producing this way.

Process Checklist

Before Applying

Under sections 3.1.5 and 3.1.6 of Directive 065: Resources Applications for Oil and Gas Reservoirs, we allow commingling without AER approval if the associated risk is low and specific requirements are met. For higher-risk situations, an application for approval to commingle must be submitted according to section 3.1.8.

The following information must be submitted when the H2S concentration for the proposed commingled production stream is 100 parts per million or greater:

  • the H2S release rate and the calculated emergency planning zone size for the operation
  • the distance from the proposed commingling operations to the nearest surface developments (i.e., occupied permanent or part-time dwellings, and publicly used facilities including campgrounds, places of business, and any other surface development where the public may gather on a regular basis)
  • the distance from the proposed commingling operations to the nearest urban centre
  • the emergency response plan that will be used for the proposed commingling operation and the date the plan was last updated

Submit an Application

Companies must submit commingling applications through our Digital Data Submission (DDS) system. We will register each application and assign a reference number.
By submitting an application, the company accepts that its information is no longer confidential.

Review Process

  1. We share all applications on our Public Notice of Application page to encourage public participation in the approval process.
  2. Anyone who believes they may be directly and adversely affected by an application can file a statement of concern (SOC). If we receive an SOC, it may take us longer to process the application.
  3. We will assign the application to a subject matter expert for initial review. If information is missing (i.e., the application is not complete and Directive 065, table 3.2, requirements are missing), we will close the application. Otherwise, we will proceed with a full technical review. In our review, we
    • check that the requested commingling does not qualify for development entity (DE) or self-declared (SD) commingling, and that the approval does not already exist in commingling (MU) orders;
    • assess the following: the impact of the proposed commingling on resource recovery, conservation risks, pool depletion, resource evaluation and reservoir management, operational safety, and protection of nonsaline groundwater; and
    • verify that the application contains all of the requirements set out in table 3.2 of Directive 065, depending on the “Reason for filing a commingling application,” per table 3.2, and that these requirements are complete. The requirements in the application must be listed in numerical order.
  4. We may request additional information (through a supplemental information request) to complete our technical review.
  5. We will decide to approve, close, or deny the application. If we close it, the applicant may reapply without prejudice. If we deny it, the applicant can file an appeal through our appeal process.
  6. We will provide the applicant with a link to the letter with our decision, which is accessible through the Integrated Application Registry. We will also share our decision on our Publication of Decision page.