Working Interest Participant Obligations Under The AER' Reasonable Care And Measures Orders

Nearly a year ago, the Government of Alberta announced its new Liability Management Plan. Through this plan, the Alberta Government provided the Alberta Energy Regulator (AER) with additional tools to ensure that sites are properly managed through their full life cycle. One such tool is the ability of the AER to issue orders requiring that reasonable care and measures be undertaken to prevent impairment or damage to the environment, human health and safety, or property. The potential reach and scope of these orders is quite broad, in that they may be directed at licensees, non-operating working interest partners, or both.  Arising through the Alberta Government's changes to the Pipelines Act and the Oil and Gas Conservation Act, the implications and the inherently broad scope of these new types of regulatory orders are still being evaluated by oil and gas industry participants.