Information Letter: Updated surface contract holder site closure planning and response timelines

March 2025

This Information Letter provides an overview and update on surface contract holder site closure planning and response timelines for lands that are no longer being used for their original purpose. Site closure planning includes well abandonment, remediation, and reclamation including end land use.

This updated Information Letter replaces the previous Implementation of section 78 abandonment, remediation, and reclamation requirements Information Letter from October 2022.

The main changes include:

On this page

Site closure planning and required response timelines

Surface contract holder requirement(s) Required response timeline
1. Contact the First Nation and discuss site closure process and timing issues such as:
  • well abandonment
  • remediation
  • reclamation
  • direction from Chief and Council on any facilities to be left in place or changes to end land useFootnote 2 that would need a First Nation Band Council Resolution
  • consideration of economic benefits including employment, business, and contracting opportunities for resident First Nation members and businesses during remediation and reclamation phasesFootnote 3
 60 calendar days from receipt of noticeFootnote 1
2. Submit a Site Closure Declaration to IOGC and the First Nation that includes:
  • Whether the First Nation:
    • met with the surface contract holder/well licensee and the meeting date
    • did not respond or declined the request to meet with the surface contract holder/well licensee
  • If the meeting occurred,
    • names and titles of the First Nation representatives
    • names and titles of the surface contract holder representatives or third-party consultants
    • a summary of the site closure process and proposed timing including confirmation that consideration of economic benefits including employment, business, and contracting opportunities for resident First Nation members and businesses during remediation and reclamation phases were discussedFootnote 3
    • next steps that were mutually agreed upon
  • If the meeting did not occur,
    • include details of outreach efforts made
    • proposed next steps and timelines including site closure communication approach with the First Nation and IOGC
  • A declaration by the surface contract holder including the signatory's name, title, and date of signature.
3. Submit a Site Closure Plan to the First Nation and to IOGC for review and approval 150 calendar days from receipt of noticeFootnote 2
4. Submit an Annual Site Closure Progress Report to the First Nation and IOGC 1 year and March 31 each year thereafterFootnote 2
5. Submit a complete Reclamation Application to the First Nation and IOGC 5 years from receipt of noticeFootnote 2

IOGC will continue sending site closure notices to surface contracts holders for high priority sites identified by First Nations and IOGC.

IOGC site closure review service standard

Failure to comply

Surface contract holders that fail to meet site closure planning and response requirements will have their surface contract placed into non-compliance and referred to IOGC's Compliance and Enforcement Business Unit.

Important note

Surface contract holders may also be subject to legal proceedings and administrative monetary penalties up to $10,000 for each violation.

Site closure plan requirements

Surface contract holders are required to submit a Site Closure Plan that includes:

  1. Location
    • name of First Nation lands
    • IOGC surface contract number, such as OS-#### or RW-####
    • legal land location (legal subdivision or LSD)
    • site survey plan
  2. Contact information
    • company representative
    • First Nation representative
    • third-party consultants (if applicable)
  3. First Nation engagement
    Describe:
    • how the First Nation will be engaged throughout the site closure program
    • how Traditional Ecological Knowledge (TEK) will be integrated into site closure work
    • whether economic benefits including employment, business, and contracting opportunities for resident First Nation members and businesses during remediation and reclamation phases were discussedFootnote 3
    • next steps that were mutually agreed upon
  4. End land use
    • pre-disturbance conditions
    • desired end land use of the site, such as agricultural, forested, native prairie, peatlands

Important note

A Band Council Resolution (BCR) is required when pre-disturbance conditions differ from targeted end land use. See our Environmental requirements and updates for more information.

  1. Site closure work details and timing
    • key project milestones or steps, including timelines with proposed start and completion dates
    • type of site closure work to be carried out, such as surface well abandonment, remediation, reclamation
    • specify if the entire surface contract is being reclaimed or if the First Nation has requested some portions be left in place, such as an access road or power lines

Important note

In addition to the requirements listed above, a Remediation Action Plan (RAP) may be required if contamination is likely or is discovered during the site closure plan process. RAPs must be submitted to the First Nation and IOGC and approved by the IOGC Environment Unit before the remediation work can commence.

Annual site closure progress report requirements

Surface contract holders are required to submit an Annual Site Closure Progress Report that includes:

  1. Location
    • name of First Nation lands
    • IOGC surface contract number, such as OS-#### or RW-####
    • legal land location (LSD or legal subdivision)
    • site survey plan
  2. Contact information
    • company representative
    • First Nation representative
    • third-party consultants (if applicable)
  3. Milestones and any updates to original site closure plans or previous annual site progress report
    • brief description of key site closure achievements completed in the past year including First Nation engagement
    • update closure program next steps and timelines including rationale for any changes to the original Site Closure Plan submitted or the previous year's Annual Site Closure Progress Report
  4. Photos
    • dated photos of the work completed to date including direction and site location

How to submit your site closure declaration, plan, and annual progress reports

You are required to submit your Site Closure Declaration, Plan, and Annual Progress Reports to the First Nation's Chief and Council and IOGC as follows:

First Nation

IOGC

Important note

We are unable to accept email submissions for your Site Closure Declaration, Plans, or Annual Progress Reports.

Background and regulatory context

For more information

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