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Good afternoon Sharon

I have provided input to your questions below.

Re: Repsol's water extraction/applications from the Clearwater River:
What is the total quantity of water that Repsol has already received permission to divert from the
Clearwater River?
On January 24, 2019, Respol’s term licence application to divert water from the Clearwater River
(application 411930) was approved and a term licence to withdraw up to 1,800,000 m 3 per year was
On January 25, 2019, TDLs previously issued to Repsol were cancelled by the AER as they were replaced
by the term licence.
Information on TDLs and other licences and authorizations issued under the Water Act and the
Environmental Protection and Enhancement Act (EPEA) is available through AEP’s public authorization
What is the total quantity that is pending approval? (again referring to Repsol and the Clearwater River)
There are no pending applications for term licences or TDLs from Repsol from the Clearwater River.
By what criteria are these applications evaluated?

Protecting the environment, including water, is part of the AER’s mandate. The AER has certified water
specialists and biologists who review all water licence and temporary diversion licence applications.
When making decisions to issue a licence, AER staff consider potential impacts to the surrounding
environment, such as the aquatic ecosystem and hydrology, and other water users.
The AER also considers other factors, which are outlined in the Water Act, Water Ministerial Regulations
and other relevant Government of Alberta policies, which include:
• Demonstrated need for water,
• existing, potential or cumulative effects on household users, other licensees and traditional
agricultural users,
• existing, potential or cumulative effects on the aquatic environment,
• hydraulic, hydrological and hydrogeological effects,
• effects on public safety,
• assessment of alternative sources of water (wastewaters, saline water, etc.,
• First Nations Consultation adequacy (for term licences only), and
• other matters applicable to the licence, including all relevant policies and guidelines.

More information about how the AER regulates water use can be found on our website.
Has the AER requested that Repsol, or any other companies, use alternative water sources, such as
recycled municipal effluent or industrial wastewater, in their hydraulic fracturing operations? (as
opposed to withdrawing fresh water from the Clearwater River or other rivers)

The AER encourages companies to use alternative water sources, like recycled water, wherever possible.
The amount of water that can be recycled varies greatly between projects.
Hydraulic fracturing projects face increased challenges to using recycled water because hydraulic
fracturing is completed only once on a single well and the sites are often in remote areas with minimal
access to recycled water. In order to recycle water, a company must store and transport the water to be
used at another site, which can be located many kilometres away. In addition, few options are available
for storing and transporting large volumes of used fracturing water and alternative water sources.
However, as outlined in Directive for Water Licensing of Hydraulic Fracturing Projects – Area of Use
Approach, for every water application a company submits to the AER, they must demonstrate the need
for water over the lifecycle of the project, which includes an assessment of alternative water sources.
Guidelines to complete an assessment of alternative water sources are outlined in the Water
Conservation and Allocation Guideline for Oilfield Injection. The guideline outlines several criteria that a
proponent must use to demonstrate their assessment of alternative sources, including environmental
net effects and economic cost comparisons. Economic costs must be balanced against environmental
impacts and the benefits of water conservation efforts.
For information about how much water is used for hydraulic fracturing operations—including a
breakdown of the type of water that’s used, please see our Alberta Energy Industry Water Use Report.
Who is required to be notified when a company applies for a water licence (or a TDL)?

All water licence and TDL applications are posted for 30 days on our Public Notice of Application tool
on Any Albertan who believes they may be directly or adversely affected by a water licence of
TDL application may file a statement of concern (SOC).
I've spoken with residents who live along the Clearwater River who say they were not notified of
Repsol's application (prepared on March 20, 2018) to divert 1.8 million cubic metres of water from the
Clearwater River. Is this in line with the AER's policy?
All applications submitted to the AER are posted on the AER’s Public Notice of Application. As with all
applications, this application was posted for 30 days. A copy of the notice can be requested by email
I have looked up the total water diversion from hydraulic fracturing operations in Clearwater County on
the website The BC Oil and Gas Commission told me that the AER supplies all information
to fracfocus. Can you confirm that this is accurate? Is the data supplied by the AER
to comprehensive?
FracFocus does not provide total water diversion information—all that is provided is water use specific
to each well site and fracture fluid composition.
According to, 199 wells were fracked in Clearwater County in 2018. Can you confirm this is
Yes, we can confirm that 199 wells reported hydraulic fracturing operations in 2018.
Is it the AER's position that the associated volume of water used is sustainable in the Clearwater River?
The AER follows allocation limits and guidelines set by the Government of Alberta. Repsol’s requested
allocations are within surface water allocation limits.

Re: water used in hydraulic fracturing:
I have seen reports that a significant majority of fresh water used in hydraulic fracturing
remains trapped in the rock matrix and complex fracture network. Does the AER anticipate that water
used by Repsol for hydraulic fracturing will be returned to the hydrologic cycle? What portion of water
approved to be withdrawn does the AER anticipate will be removed from the hydrologic cycle?
Water used for hydraulic fracturing operations in Alberta cannot be returned to the hydrologic cycle.
Once water is used for this purpose, it is considered oilfield waste and must be handled accordingly, as
per Directive 055: Storage Requirements for the Upstream Petroleum Industry and Directive 058: Oilfield
Waste Management Requirements for the Upstream Petroleum Industry. This type of oilfield waste may
be recycled and reused in other hydraulic fracturing operations, or be disposed of through an AER-
approved deep disposal well.
You told me that, to date, over 180,000 wells in Alberta have been completed using hydraulic fracturing.
Does the AER believe the water use associated with these wells, and new wells completed in the future,
is sustainable?

Nonsaline water is allocated for use according to the Water Act. The AER carefully evaluates each Water
Act licence application to ensure it meets all requirements and will not adversely affect the environment
or other existing users.
In addition, only 10 per cent of all nonsaline water in Alberta is allocated to energy development. The
remaining 90 per cent is allocated for other uses, such as agriculture, forestry, commercial (e.g., golf
courses, gravel pit operations), and municipalities. Of the total amount of water allocated to the energy
industry, approximately a quarter of that amount is used. More information about water allocated to
and used by the energy industrycan be found in the Alberta Water Use Report.
By what percentage have the number of wells completed using hydraulic fracturing increased over the
last five years?

Between 2013 and 2018, the number of wells completed using hydraulic fracturing has increased by 9
per cent.
And over the past ten years?

Reliable data on the number of horizontally fractured wells is only available from 2010 onwards.
Compared to 2010, the number of wells completed using hydraulic fracturing in 2018 decreased by 1 per

Best regards,
James Mottershead, BA
Advisor, External Communications, Communications and International Relations
Alberta Energy Regulator