Revised Alberta Exploration Directives Will Change the Layout of Future Seismic Programs
Published: The CSEG Recorder - June Edition (online)
CAGC represents the business interests of the seismic industry within Canada – cagc.ca.
This column represents the authors’ perspectives on the seismic business.
There have been important updates to the Alberta Exploration
Regulation and the associated Exploration Directive that will allow better
subsurface imaging on most new seismic acquisition programs and repeat 4D
projects. The major change is described ‘briefly’ in the fourth last paragraph
of this article.
This Exploration Directive update is significant because it is the first time since 2009 that any of the 26 Directives have been reviewed, stakeholders engaged, and the Section rewritten and ultimately approved. The industry had been working since 2010 on numerous Directive improvements and finally, in April 2022, changes to 13 of the 26 Directives finally came into effect.
So why did it take
twelve years to update any Directive? Frankly, best intentions and planning do
not always translate into reality. We also had to contend with the Alberta 2019
election (closes window late 2018 until late 2019) and of course delays caused
by COVID-19. The progress looked like a saw blade tipped slightly upwards. Some
ups, some downs.
Since the 1959
Exploration Regulation (25/59), the major geophysical regulation updates were
in 1978, 1990, 1998, 2006, and now 2022. In 2006, specific components of the
1998 Exploration Regulation (214/98) were extracted and placed into 26
individual Directives to accompany the 2006 Regulation. Regulations are
reviewed every ten years and require An Order in Council to change or extend
them. Thus, Regulations are difficult to change.
Directives, on the
other hand, can be revised and approved by a Deputy Minister or a designate.
The intent in 2006 was to review the Directives frequently and make changes to
address emerging technologies, best practices, and stakeholder concerns.
It is important to
consider how many technical equipment advances have been made since the
Directives were created in 2006. At the time, it was generally deemed to be too
expensive, difficult, and environmentally impactful to record a 3D in the Oil
Sands with a cable-equipped
There are many
regulations with which the geophysical industry has to comply. The non-seismic
specific regulations, to name a few (federal and provincial), would include:
Migratory Bird
Convention Act, Department of Fisheries and Oceans, Federal and Provincial
Transportation and Explosives, Occupational Heath and Safety, The Water Act,
The Public Lands Act, …
The more direct
Alberta regulation framework includes: The Mines and Minerals Act, The
Exploration Regulation, the Directive, and the Master Schedule of Standards and
Conditions (includes some mandatory and optional conditions), and ultimately
the project geophysical approval.
The
most recent update to the Alberta Exploration Regulation (284/2006),
recommended by the Minister of Environment and Parks and was signed off by the
Alberta Lieutenant Governor, was in December of 2020. This update was necessary
to drive the way to the Directive changes.
The link below
details the changes to the Exploration Regulation. https://www.qp.alberta.ca/documents/Orders/Orders_in_Council/2020/2020_422.pdf
One of the main
changes was repealing the existing separate Directives and incorporating them
into the Exploration Directive with 24 sections. The Exploration Directive was
approved in April 2022 and can be located here:
https://open.alberta.ca/dataset/cc5d9ee6-faab-4ada-b399-1d5beeddad9c/resource/ddbd8c08- d379-434b-a103-b14c40b950dc/download/aep-exploration-directive-2022-04.pdf
The former
Directive ED2006-15, Distance Requirements, is now Section 15 of the
Exploration Directive. The Directive numbering is consistent to Section 15,
then the numbering changes because two of the Directives were dropped (16 and
23).
Of course, any
Directive change has to comply with the current Act and the Regulation. In most
cases, the overarching Mines and Minerals Act has to be modified first, then
the Exploration Regulation, and finally the Directive. That is part of the
reason why just 13 of the Directives were changed, as several proposed Section
updates are not yet aligned with the Mines and Minerals Act.
So, why did it take twelve years to
update any Directive?
In 2009, through the steering committee and a joint application by the CAGC and the CAPP Geophysical Committee, 5 significant changes were made to 3 of the Directives. The process worked exactly as planned. By 2010, there were 2 other proposed Directive updates with near final drafts, another Directive was written, and the Geophysical Field Report (GFR) document was rewritten. Then the Exploration Section Head, who had been working geophysical since the ’70s, retired. His replacement was unable to navigate the government’s process and, despite all efforts, not much transpired for the next several years. Geophysical falls under the purview of the Minister of Environment and Parks. At the time, geophysical was under Alberta Environment and Sustainable Resource Development (ESRD), which was both our regulator and policymaker. Then in 2013, the government introduced the Responsible Energy Development Act (REDA), which changed things considerably. Now we had the Alberta Energy Regulator (AER) as our regulator and Environment and Parks (AEP) as our policy group. The AEP had the authority, but not much expertise. AEP would suggest that AER needs to engage and do the subject matter expert review and then AEP would look at it. AER was not sure they could commit to that work without consent from a higher government authority. Essentially, we were stymied by Newton’s First Law of Motion, “An object at rest will remain at rest …”. It really took the effort of many to overcome the status quo. We met with the Associate Minister of Red Tape, trying that angle, but that did not work. Eventually, it was the November 2019 meeting with the Minister of Environment and Parks, Hon. Jason Nixon, that kick-started the process.
And so today, we
are reporting on this tremendous success. Finally, after twelve long years,
changes to the Exploration Directive. So, what is the most important
technological advancement within the Exploration Directive?
Before you go further, it is important to be absolutely
clear. This update will allow you, with consent, to get closer to structures
with energy sources. You will be in compliance; you will still liable for any
damages.
Section 15 of the
Exploration Directive deals with the distance requirements from sources to
specified structures. For most structures, the nearest allowable distance was
based on a minimum charge size of 2 kg, although now most of our explosive
charges are much smaller. With consent, the closest you could get to certain
structures (residence, residential water wells, observation wells, and
piezometers) with any charge less than 2 kg was 64 m, which is a surface gap of
128 m. If there is another structure within that 128 m diameter that could
additionally increase the gap. Generally, data gaps degrade the subsurface
imaging, particularly the near-surface. There is now a table based on Scaled
Distances that, with consent, will allow you as close as 16 m to a residence or
residential water well with a 0.125 kg charge or 8 m with 0.125 kg from a
company-owned observation well or piezometer. That means on existing 4D
programs you can potentially insert source points where you could not before.
With new programs, you may have less skidding and offsetting of source points
and no longer have to cut as many stub lines for infill stations. There is also
the option with lower vibrator fundamental force to approach closer than
previously allowed. This update will help image shallow targets, and marker
horizons, and potentially identify drilling geohazards. There was a great deal
of work done to advance the Alberta Distance Requirements and, in fact, this
model is probably best in class. In the absence of regulation in other parts of
the world, the
Here is a link to
the previous Exploration Directive ED2006-15 so you can compare where we were
to where we are now. You may note the link below suggests the Directive was
updated in 2013 but that was part of REDA and just administrative contact
details that changed.
https://open.alberta.ca/dataset/e8b7dda0-31a0-4350-be47-bcb52fc815b8/resource/5b4aa7ae- 6cd6-457c-9b61-adb532cb6360/download/2013-ed2006-15-distance-requirements-updated- dececember-1-2013.pdf
Just a reminder
with any 4D programs, inserting new source points will require Program Tags
(formerly called Permit Tags) at the new explosive source locations. This was
another change within the Exploration Directive, while Program Tags are required
at new explosive source points (4D’s no longer need new tags each time the hole
is drilled), programs with vibroseis source points will only require tags at
the beginning and ends of lines and at major
intersections.
A future article
will address: the engagement/consultation process, details of the other 12
updates, outstanding issues, and the next steps in the process.
About the Author
Doug Iverson is a ‘mostly retired’ Operations
Acquisition Geophysicist with hobbies that includes Peak Particle Velocity
(PPV) monitoring and adventure motorcycling. Most of his time, since 1977, has
been with field operations in Libya, Sudan, Kurdistan, Papua New Guinea, USA
including Alaska, and Canada. Doug was Team Lead for Geophysical Operations at
Talisman Energy for Domestic and International projects.
Doug is a past
Chairman of the Canadian Association of Geophysical Contractors and past
Chairman of the Canadian Association of Petroleum Producers Geophysical
Committee. Doug has been engaged with regulatory changes in Alberta,
BC, and Saskatchewan, and the Territories since 1998.
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