• Apply requirements to selected areas of the province, for example, where shallow aquifers are currently being used. Limit requirements to areas where coalbed methane activity is occurring.

• The EUB believes that a need exists within the entire province to obtain information on the shallow geologic strata that will enable geologic mapping and characterization of these strata.

• Limit requirements in areas of dense drilling, such as pads or reduced spacing.

• Licensees may make application pursuant to Section 11.140(1)(3) of the Oil and Gas Conservation Regulations, which states: “The Board may on application allow substitution or grant relief from the requirements of this section where special circumstances warrant.”

Each circumstance is evaluated on its own merits when requests are received. Very rarely are total logging exceptions granted. Most wells granted relief from the requirements are required to run a cased hole gamma ray neutron log.

• When permission is granted to substitute logs within the open hole interval, would it apply to the surface casing interval?

• Any substitution granted would pertain to the interval under consideration (i.e., the open hole or surface casing interval). As stated previously, most wells granted relief from the requirements are required to run a cased hole gamma ray neutron log.

• Data quality would be poor due the effects of casing on the log response.

• The EUB recognizes that there will be some attenuation of the logging tool response. However, information obtained would be useful from a qualitative perspective. It will enable identification of sands, shales, coals, and potential gas intervals.

• Advice received by the EUB indicates that meaningful data can be obtained when both the conductor pipe and surface casing are cemented to surface. Current EUB regulations require that both be cemented to surface (Directive 009: Casing Cementing Minimum Requirements, Section 3).

• Terminate logging at the same depth for both the gamma ray and neutron log (25 metres [m] below the ground surface).

• A significant number of aquifers exist within 25 m of the surface. Obtaining the requested information over this interval is important, since it will enable the mapping and characterization of the aquifers. Information available to the EUB indicates that termination of the neutron log at 25 m below the surface ensures worker safety. The EUB has been advised that terminating the recording of neutron response at 25 m and the gamma response at surface can be easily accomplished operationally.

• Log the cased surface hole at the same time the remainder of the open hole is logged.

• Timing of logging is at the operator’s discretion. It is anticipated that most operators would log the cased surface hole in conjunction with the open hole logging operation.

• Concerns were expressed about the additional logging costs.

• The EUB maintains its view that the proposed logging requirements are the most cost-effective means of obtaining the required information. Cost data made available to the EUB indicate that additional logging costs are minimal.

• How will these requirements be enforced?

• Existing systems monitor compliance of current open hole logging requirements required by Section 11.140(1) of the Oil and Gas Conservation Regulations. These systems will be used to monitor compliance with any new logging requirements.

• If implemented, will the new requirements apply to existing wells?

• The new requirements only apply to new wells finished drilling after the effective date of the directive.

• Logging of the surface hole is not consistent with the open hole logging requirements. For ease of interpretation, amend the current open hole logging requirements that encompass all logging requirements.

• A review of 2005 well logging data indicates that about 95 per cent of the wells drilled pursuant to the minimum requirements of the resistivity and SP logs were also logged with a gamma ray neutron. This suggests that there is no need to revise the existing open hole logging requirements.