CAPP Response to AER Request to Assess the Significance of Fluid Disposal Challenges

Official submission

Published: December 17, 2018

CAPP believes that there is the potential for significant additional cost and project certainty/investment decision impacts for operators if these issues are not addressed. Disposal is currently regulated by Directive 051 (D051), Directive 065 (D065), and the Mines and Minerals Act (MMA). The need for change can be highlighted in the following three broad areas: Crown consent and mineral tenure issues, timelines for disposal authorizations and disposal fluid classifications.