Polluter Pay Federation and ALDP File a Group Statement of Concern with the Regulator – Objecting to Transfer of Well, Facility and Pipeline Licenses from Shell to Pieridae Without Related Security


Unfunded upstream oil and gas (end of life) liabilities are serious problems that continue more or less unchecked in Alberta. Total liabilities for upstream oil and gas wells alone are between $30-$70 Billion (Alberta Liability Disclosure Project published estimates using Regulator data).

Alberta Energy Regulator (AER) Directive 006 requires the AER as the Regulator to require well and facility licensees (including new transferees) to post security or make a deposit in precise circumstances to cover certain end of life obligations (well plugging or facility decommissioning or “abandonment” and land remediation and reclamation cost obligations all licensees have at law).

The Proposed Transfer of Concern

Shell Canada Limited (“Shell“) is proposing the transfer of three bundles of licenses associated with certain assets (collectively the “Foothills Assets“) to Pieridae Alberta Production Ltd. (“Pieridae”). The concern shared by the Polluter Pay Federation, the Alberta Liabilities Disclosure Project (“ALDP“) and members of these not-for-profit groups are no details related to any deposits or security to be posted by Pieridae to cover Abandonment and Reclamation Obligations (“ARO“) that all licensees have at law. Taxpayers, landowners and the orphan fund are thereby put at risk, which is contrary to the purpose of AER Directive 006.

Statement of Concern No. 31884

On February 18, 2021 a Group comprised of Polluter Pay Federation and ALDP Directors and others filed Statement of Concern No 31884 with the AER in respect of the proposed transfer of licenses for the Foothills Assets of Shell to Peiridae. The Group is represented by Mark Dorin of Dorin Management.

A copy of SOC 31884 is provided at the link below for the information of the membership and the public. It is noteworthy that members of the public have many questions about how to file a Statement of Concern with the Regulator and how the AER should properly dispose of such submissions.


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