This insight explores the Conditional Adjustment of Reclamation Liability (CARL) program, its relevance to oil and gas producers, and the value of participating in it as part of a strategic liability management plan.
For someone relatively new to this side of the environmental industry, I’ve been struck by the complexity of the regulatory frameworks, ongoing directive changes, rehabilitation programs, government funding and—of course—the endless stream of acronyms that define the sector.
My career began with pipelines, where I gained first-hand field experience. That eventually led to selling corrosion liner systems and overseeing installations to extend pipeline lifespans. Along the way, I learned just how vast and interconnected Western Canada’s pipeline network truly is. I then transitioned into the drilling and completions world, where I gained a deep appreciation for the history, pace, and innovation of well development—along with the growing inventory of idle and orphan wells left behind.
Both experiences drew me toward the environmental side of the industry. The sheer scale of abandoned pipelines and wells across the Western Canadian Sedimentary Basin (WCSB) made me curious as to how the industry would address this challenge.
Now, in my role at 360 as a Business Development Representative for Environment, I work closely with upstream oil and gas producers to navigate this evolving landscape. Public pressure, regulatory changes, and shifting industry priorities have pushed companies to adopt strategic liability closure frameworks—leveraging programs set out by governing bodies such as the Alberta Energy Regulator (AER), making it imperative for companies to manage environmental responsibilities and liabilities.
The implementation of the CARL program began in April 2024; it was previously referred to as the Reclamation Liability Reduction Program. It allows licensees to temporarily reduce the reclamation liability estimate for a site after physical reclamation work is completed but before full vegetative recovery.
Key Features:
- Applies once all closure activities (well abandonment, equipment removal, Phase 1 & 2, soil remediation and reclamation earthworks) are finished, except for vegetation regrowth.
- Approved sites have their liability reduced to $5,000 for cultivated land or $9,000 for other land types for up to five years or until a reclamation certificate is issued.
- If a certificate isn’t obtained within five years (or without an approved extension), the original liability is reinstated, and the site becomes ineligible for CARL again.
Since it’s launch, CARL has received roughly 8,900 submissions, producing a temporary reduction of approximately $135.6 million in reported liabilities. More than 700 licences have received a reclamation certificate after entering CARL. The AER typically issues in the order of 3,500–4,000 certificates per year.
The key to this program is that it both accelerates and shortens the time in which substantive, meaningful recovery is properly recognized. In doing so, it allows producers to more accurately report liabilities that truly reflect remediation work that has been completed ––thus freeing up capital and providing greater optionality in terms of future investments and expenditures. Finally, it demonstrates to regulators, investors, landowners and the public that closure activities are progressing – even during period of vegetation recovery.
Conclusion:
Environmental work may lack the excitement of certain exploration and drilling activities or the challenge and quiet satisfaction of pipelines moving product and generating income. But it serves an equally important purpose – and one that is a necessary component to the success and responsibility of any company. It’s rooted in stewardship and respect for the lands and communities where we live and prosper. The strategy, foresight, collaboration and proactive management within a well-designed liability framework ensures that responsibility for the environment is accepted and respected.
At 360EEC, much like the broader energy industry, we have learned, adapted, and successfully partnered with clients to maximize every dollar spent toward liability reduction and environmental enhancement. We strive to do so in a professional and timely manner, optimizing any programs and incentives that may be available to assist our clients in addressing environmental responsibilities and concerns.
I have developed a deep appreciation for the professionalism of our clients – and the industry in general – in terms of their commitment to land remediation and restoration. I have also gained enormous respect for the collaborative efforts among governments, landowners, operators, and environmental companies to advance environmental performance and long-term sustainability. It is their collective determination to address what we can now recognize as historical shortcomings that gives me confidence in this industry moving forward.
From an early age, sports taught me that leaving a dressing room cleaner and better than you found it is a true reflection of an organization’s character and professionalism.
Thanks for reading,
-Christopher
About the Author
Christopher Bruton, MBA, Business Development Representative
Christopher has more than 10 years of business development experience in the oil and gas sector, with a career that has included roles in pipelines, corrosion liner systems, and drilling and completions. He now leads business development efforts for 360’s Environmental business unit, working with producers to meet regulatory requirements and pursue sustainable growth. Christopher’s blend of field experience, sales expertise, and analytical skills gives him a well-rounded perspective on industry challenges and opportunities.
