Class III Fluid Disposal Legal Header

Project Application


Our estimated processing time for this application is 130 business days. See our timeline spreadsheet for updates.

Purpose of the Application

We classify disposal wells based on their injection fluid type. Our classification system is described in Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements.

Companies must apply to use a Class III fluid disposal well. Class III fluids include

  • sour gas, and 
  • acid gas.

With our approval, companies can dispose of Class III fluids in underground formations or depleted hydrocarbon pools for reasons other than enhanced recovery or gas storage. There must be no impact to public safety and no adverse effects on the environment or hydrocarbon recovery in the surrounding area.

Process Checklist

Before Applying
To be approved, applications must meet our technical and safety requirements in the following documents:

Wells used for disposal do not have to be drilled before submitting a Class III fluid disposal application. If the disposal well has not yet been drilled, this disposal application must be supplemented with an application for a well licence under Directive 056. If approved, these two applications together will give provisional and conditional approval for disposal while committing the applicant to drilling the well within a specified timeframe.

Submit an Application
Companies must submit Class III fluid disposal applications through our Digital Data Submission (DDS) system. Our detailed checklist document can be referenced to ensure that applications are complete. We will register each application and assign it 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 that 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), we will close the application. Otherwise, we will proceed with a full technical review. We look at
    • whether the applicant holds mineral rights to the proposed disposal zone, or the requisite disposal consent has been secured from the current mineral rights holder;
    • whether the proposed disposal fluids contain acid gases or H2S (to comply with Directive 071);
    • whether offset wellbores have been reviewed for potential high-risk hydraulic isolation deficiencies;
    • whether the wellbore integrity of the proposed disposal well is suitable to the proposed operation (to comply with Directive 051);
    • whether the proposed maximum wellhead injection pressure is appropriate for the operation. The safety factor on the estimate of the formation fracture propagation pressure must be applied at the sand face (bottomhole) for all disposal wells;
    • whether the Crown has been sent a letter of indemnification as it pertains to the proposed disposal activities, if on Freehold lands;
    • whether depleted hydrocarbon pools or their associated aquifers are the disposal zone. If so, it could cause over-pressurization. Disposal will be limited by a maximum operating pressure equal to the initial reservoir pressure. If the maximum operation pressure is reached, disposal will be stopped; and
    • whether the application has fulfilled notification requirements in Directive 065, specifically that licensees of all wells (including abandoned wells) within a 1.6 km radius have been notified. This is a minimum requirement and could expand depending on the estimated fluid and pressure plume areas of influence.
  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 for 30 days through the Integrated Application Registry. We will also share our decision on our Publication of Decision page.