Alberta’s Site Rehabilitation Program Updates

ESAA has compiled the following updates with regard to the Alberta Site Rehabilitation Program (SRP). ESAA will endeavor to update this page regularly as new information is received. You can send any comments to ESAA via email at: [email protected].

Government of Alberta Page – https://www.alberta.ca/site-rehabilitation-program.aspx

At the January 13th, 2022 SRP Industry Advisory Committee, Alberta Energy announced a number of program funding modifications in hopes of accelerating program spending.  The changes announced include:

1. Sequencing requirements will be removed for all applications being submitted in open and active Periods (Period 4, 5,6,7,8)
2. Going forward, bench-marking requirements for all new applications will be removed, allowing for larger and more complex projects to be considered.
3. The clause requiring work must begin within 3 months of an application being approved has been removed to allow for future planning/seasonal work to take place, as well to accommodate removal of the sequencing requirement.

Additionally, they notified the IAC of the following updates regarding the re-allocation of funds:

1. Period 5: An additional $100 million will be added to this period. Notification from Alberta Energy to Licensees will be sent out shortly to notify them of their allocated amounts.
2. Period 6: An additional $33.33 million will be added to this period as well.
   • The additional amounts for both Period 5 and 6 work out to approximately 1/3^rd of their original funding.
   • Period 5 and 6 were chosen as these periods have larger scopes of work and have had the most active number of applications.

It is worthwhile to note that Alberta Energy will be requesting Licensee’s review all allocated funds and if Licensees do not feel some of the received funds will be spent that they will be asked to return these funds for future re-allocation.

ESAA is pleased with these program modifications. 

This update can also be found online at: https://esaa.org/srp/.  Any comments for ESAA can be sent to: [email protected].

Alberta Site Rehabilitation Program Update November 17th, 2021

Program Extension Request Update

ESAA is looking forward to the next IAC meeting scheduled for Nov 29, 2021 at which time Minister Sonya Savage will be joining the committee.  We wanted to share with our members some recently received communications from the Minister’s office.

The IAC along with other stakeholders in the industry have shared with Alberta Energy the challenges that companies are facing including labour shortages and this may be impacting the ability to accelerate closure spending. Although an extension request has been proposed by several associations to alleviate the pressures of the current timeline, the Government of Alberta is looking into all options to address the challenges including the potential for an extension to the program.  Ultimately, the final decision regarding an extension lies with Federal Government and as such there is no guarantee the program will be extended past March 31, 2022.

The Government of Alberta would like to encourage members of ESAA to continue to work with licensees as an acceleration of spending within the current deadlines is the best approach to avoid returning unspent funds within the SRP to the Federal Government.

ESAA hopes to provide further updates to our members after the Nov 29^th IAC meeting. As always, please do not hesitate to reach out to us if you have any additional feedback, comments or concerns.

Thank you for being an ESAA Member!

Alberta Site Rehabilitation Program Update November 8th, 2021

The Alberta Site Rehabilitation Program (SRP) is scheduled to be completed by March 31st, 2022.  To date, the Government of Alberta has allocated approximately 55% of the funding.  ESAA and other members of the Industry Advisory Committee (IAC) have been advocating for an extension to the program.

This past Friday, ESAA also formally requested an extension to the program on behalf of the ESAA Membership and Environment Industry. 

While ESAA echoes this sentiment of some of the other associations that sit alongside ESAA at the IAC, we would like to see an extension of the SRP pushed to Dec 2023 and not ending in September 2023. September is leading into the busiest time of year for reclamation and remediation work; crops have come off and all hands are on deck to complete as much surface work as possible before the snow flies and the ground starts to freeze.

We need to make sure that we don’t end up with an increased abandoned well inventory and an extension through to December 2023 would allow for much needed surface work to be completed on these well sites.

Once ESAA receives additional information about a possible extension we will share the information with the membership.

ESAA SRP Updates are available at: https://esaa.org/srp/

Thank you for being an ESAA Member!

May 6th, 2021 Meeting

1. Welcoming Remarks and General Update

• As of May 3 Wade Clark is the new Assistant Deputy Minister  of Energy Policy in Alberta Energy, replacing Martin Chamberlain  who has retired. Kate Hovland is the Acting Executive Director until the position is filled. Also until the position is filled, Derek Volker is replacing Wade Clark as the lead for the Site Rehabilitation Program and any program questions that would have gone to Wade should now be directed to Derek.
• Notes correction: In the April 22 Industry  Advisory Committee meeting notes, there is a mistake  The second point under the Future  Periods item should say that it is desirable to get the remaining  $200 million available in July 2021, not June. Details will be posted on the website prior to the Periods launching,  as was the case for Periods 5 and 6.  A revised version will be sent.

2. Program Status Update

• All Periods: 44,785 applications submitted;  44,701 of these have been processed.  Payments made to-date total $142.7 million through 32,153 payments.  17,034 invoices have been received and16,159 have been reviewed.

o   Government  continues to target the 30 day window for payments to be made.

• Period 3:  3,029 applications submitted;  2,582 approved,  422 declined.  Total approved grant value is$59.3 million. Approximately  60% of the total funding available for Period 3 was used.
• Period 4:  5,169 applications submitted;  4,549 approved,  572 declined.  Total approved grant value is $86.3 million.
• Period 5: 827 applications submitted;  586 approved, 144 declined.  Total approved  grant value is $19.7 million.
• Period 6: 226 applications submitted;  205 approved, 21 declined.  Total approved grant value is $6.3 million

3. Period 6 Update

• There have been successful conversations  with many communities  in Period 6, and the remaining community  allocation trackers are well underway  and communities  and licensees  are ready to do work. All Period 5 allocations have been unlocked for the allocation trackers that have been received so far.

Indian Resource Council

• There has been and continues to be good progress. Eight First Nations have submitted  their allocation plans. This represents  $7.12 million in unlocked funding.
• The amount of funding that has been awarded to applicants in Period 6 is $6.3 million and applications are moving quickly once the trackers are in
• There are five other plans on track for submission  and another five First Nations are finalizingtechnical discussions.  It is anticipated that in about two weeks there should be close to 20 allocation plans submitted.
• Some First Nations are working on their second tranche of the allocation plan.

4. Future Periods Design and Funding

• It is requested not to share details to others outside of the Committee on these future periods at this time. Government would like to test unintended consequences before th is is determined  or communicated and decisions are still underway. The supplemental guidelines will make the requirements and details clear.
• There has been no change in scope for these future periods since the last meeting with thecommittee. Final approval is being sought to move forward with this approach.
• Before the next two future periods launch and accept applications (anticipated for July), there will be additional details provided to help assist with planning.  Government  will also present and clarif y details with the committee throughout  this time frame.
• Comment from the committee that there should be access considerations  for these future periodsand extending  eligibility  through all winter season of 2022-23 would be important  (end date for work under the program is end of December 2022).

Species at Risk Focus Period

• The federal government  has a requirement  for part of the program funding to be focused on species at risk.
• The design of this period is looking to have $100 million in funding available and the targeted speciesare likely to be sage grouse, caribou, and trout.
• Allocation for this Period is intended to be similar to others, which is based on eligible sites. Once all species at risk habitat areas are defined to be eligible, then all sites in these areas will be included and allocations will be available for licensees’ sites based on their proportional share.

o   Details will be posted as well as notifications sent to the licensees regarding the allocations – this will be similar to the approach taken in Periods 5 and 6.

Surface Closure Focus Period

• The design of this period is looking to have $100 million in funding available, targeted towards doing surface closure work.
• Allocations will be based on eligible sites and proportioned  for the licensee, similar to other periods.

Details will be posted as well as notifications sent to the licensees regarding the allocations.

Redeploying Unallocated  Funding from Previous Periods

•  Government  discussions  are underway  to redeploy funds that were not used in earlier periods.

Government  will be engaging the committee in the near future to further explore how best to do this.

Questions and Answers

Q: What will incentive programs  look like for these periods? A: This is still to be confirmed.

• Government  is looking at using similar incentives  of 50% and 100% funding structure  for these periods.

o   For example, incentives may be included around completing surface work or addressing nominated  sites.

o   The specific details for incentives for each of the Periods will be communicated  once finalized.

• Q: For the surface closure focus period what sites will be eligible or what is the criteria to determine the allocation? A: This is still being worked on and analyzed to fully define this. These are sites that are abandoned  but not yet reclaimed, for example.

April 22nd, 2021 Meeting

1. General Update

• All Periods: 44,484 applications submitted; 44,382 of these have been processed.  Payments made to-date total $130.9 million through 30,349 payments.  15,472 invoices have been received and

14,156 have been reviewed.

o   Resources have been shifted to invoices rather than applications as this is the majority of what is being received currently. Government  is trying to stay in the 30 day window for payments to be made.

• Period 3: 3,029 applications submitted; 2,561 approved,  419 declined.  Total approved grant value is

$58.6 million. Period 3 closed on March 31, 2021. There a few more applications that may add t o this total value.

• Period 4: 5,113 applications submitted; 4,487 approved,  572 declined.  Total approved grant value is

$85.1 million. There is still $15 million funding available for Period 4.

• Period 5: 500 applications submitted; 356 approved, 130 declined.  Total approved  grant value is

$12.1 million so far.

• Period 6: 200 applications submitted; 181 approved, 4 declined.  Total approved grant value is $5.5 million so far.

Reminder:   When Prime contractors are submitting  invoices there needs to be proof of payment for all sub-contractors  before invoices will be paid out. This is clear in the Guidelines  but some prime contractors are communicating  that sub-contractors  will only be paid after the SRP grant funding is received.

2. Period 6 Indian Resource Council and Metis Settlement  Update

Indian Resource Council

• 25 out of the 36 First Nations have had meetings with the Indian Resource Council. Challenges relate to some First Nations` election process and fiscal year end requirements.
• A few additional meetings in the next week or so.

Metis Settlements

• Work with the Settlements and the Metis Settlements  General Council continues. The first Community  Allocation Trackers have been received from some Metis Settlements  and ongoing communication with all the Settlements  is ongoing as they develop their trackers.
• Some Settlements focused on winter campaigns but want to get surface work going.

Period 5 Funding Release

• 83% of licensees and 67% of funding has been unlocked in Period 5 to-date. It is anticipated that most if not all Period 5 funds will be unlocked in May. If additional project management support is required for the Metis Settlements,  this will be provided to help meet this target.

o   To help prepare, applicants can start work in the application system and save a draft in ETS that

can be submitted  once the Period 5 funding is unlocked for the licensee.

3.  Follow-up Discussion: Information Requests Proposal on Grants Awarded

• Prototype was shared and vetted by service sector members and licensees interested in viewing this.

Committee consensus was to not proceed. Licensees will move to other ways to get this information. No further action needed by the Industry  Advisory Committee or government.

4.  Future Periods:

• It is requested not to share details to others outside of the Committee on these future periods at this time. Government would like to test unintended consequences before this is determined or communicated and decisions are still underway. The supplemental guidelines will make the requirements and details clear.
• It is desirable to get the remaining  $200 million available prior to July 2021. Details will be shared in advance of the periods opening.  This is similar to the process for Periods 5 and 6 to allow planning for the summer  season but provide the time for Service Alberta to build the necessary technical components for the applications.

Species at Risk Focus Period:

• As part of federal funding, there is a requirement  to target species at risk. There is a desire to target three key species – sage grouse, caribou, and trout.

o   There is currently  a Federal Environmental  Protection Order on sage grouse; ongoing work with

caribou range planning;  and work on trout habitat to identify key priorities and opportunities  in these habitats is well developed.

• Government is finalizing the details on the amount of work and prioritization.  Under the potential

species at risk period, there will likely be a focus on surface closure work to clear the footprint from the landscape, recognizing  it will take time for reclamation certification.

Other Potential Period:

• There is potential and desire in this period to push for more surface closure work. The f ocus on designing this period has been on identifying  areas of the province with abandoned  sites needing reclamation, that have been in this state for a number of years.
• There is some analysis on incentivizing closure on nominated sites as well. Some nominated sites

have been addressed through other periods, others have not. Work is underway to distill eligible sites from the nominated  list.

• This period could be focused on surface closure work combined with incentives for work on

nominated  sites. The intent would be to strike a balance between efficiencies of taking a potential area-based approach, without eliminating  applicants in the program.

• Presentation from committee members on surface decommission,  remediation,  and reclamation.

o   A working group on member  companies for this type of work dedicated to the SRP note there is a need to target surface closure work.

o   A key consideration was to highlight  importance of advancement  of full site closure, especially in response to stakeholder expectations that the SRP program would reduce the inactive inventory and reduce the overall footprint.

o   Focus on dedicated funding round to complete surface work makes sense. In addition to

completing  environmental  work, can aid in employment  of many of the service sector member companies for this work,  as they have not had the opportunities  as downhole companies have.

–     Could help with success of the program, positive impact in addressing  backlog of well sites.

It could also help curb the loss of expertise over the years. Improving  relations with environmental  stakeholders,  landowners,  and Indigenous  communities.

• Q: One issue from the producer standpoint is the time to get a reclamation certificate. How does this

factor in?

o   A: Committee members  discussed  that if we focus on the SRP program, timelines  of the program does not lend itself to complete closure for reclamation certification but may be able to get to the vegetation monitoring  stage rather than needing to get full reclamation certified.

o   The SRP allows for applications for reclamation work done before the sites are fully reclama tion certified.

• There is much consideration involved in the program and balancing funding, doing the work, and

fully closing sites.

• There is a timing concern to get the funding out and the work done. Only $130 million has been spent so far. With rising commodity prices – downhole work may be delayed and shifted as more service activity is going to optimize production  rather than closure. From deemed liability reduction perspective  – abandonments  move the liability away from licensees  most efficiently and are fastest to do.

o   The surface work follows the downhole work and it is believed that the surface work is coming

and there are motivators in the system with municipal  taxes, surface lease payments  etc. to get to the surface work and reduce the footprint even after SRP is done.  Timing is the consideration factor and is key to spend this money and work on as much as possible right away to help this industry,  even if it means just downhole work at this point.

• There was a suggestion to narrow surface work to cultivated lands – to focus on certain types of end

land uses.

• A lack of groundtruthing on the work that needs to be done needs to be considered in the design.
• Producers are looking for maximum flexibility – could put a market-based  incentive to licensees to target surface work, rather than prescribe.  This drives the right type of thinking  but gives maximum flexibility to ensure the money is all granted.
• Government will try to keep this period simple. There is opportunity  to drive metrics in the program

– balancing  the surface and subsurface work.

• A suggestions was made that interim reclamation certificates may help – after revegetation is in place – in interim certificate could be provided.  In its absence, surface work is largely seen as prohibitive  to put the capital forward due to the time for reclamation certification. Need a more attractive position for licensees that want to see recognition for taking the full step towards reclamation.

o   Interim certification would be helpful so that public can also see what is done and this can be

shown for companies that have done the work and invested in their closure.

February 10th IAC Meeting Updates

Status Report on Periods 3 and 4

• In total 42,234 applications have been submitted and 42,000 have been processed. $306.44 million in total funding has been approved, $81.5 milllion in payments have been made over 22,426 transactions.
• Period 3 – 2,204 applications have been received, 1,883 have been approved, 317 have been declined. $38.2 million total has been allocated.
• Period 4 – 4,397 applications have been received, 3,810 have been approved, 488 have been declined. $72.9 million total has been allocated.
• Reassessments – Notifications have all been sent out regarding grant reassessments due to activity maximums being changed. Next step is for recipients to return the signed, revised agreements. Once received, agreements will be finalized and the final copies will be sent out. Expect this to occur over the next few weeks. ETS will be updated with the revised amounts. The extra funding is to be included in the final invoice.
• There are grant agreements from Periods 1, 1b and 2 that have not been signed and returned. In December an email reminder went out to licensees. The next step is to send a notice that the grant offer will be rescinded to make the funding available for future periods.
• Q: Is there clarification on sequencing for Periods 4, 5, and 6 to enable environmental site assessments before the downhole? A: For Periods 5 and after, the system will enable applications for abandonment and phase 1 environmental site assessments simultaneously. To accommodate the timing needed for applications to be submitted for sequenced andseasonal work in Period 4, government is thinking of extending the application period beyond March 31, 2021.
  • Extending the application period will likely be received well by industry, but it needs to be for a minimum of six months.

Periods 5 and 6

• Finalizing details and final allocation calculations. The cut-off for additional information was the start of week. Looking to announce by the end of the week (by February 12).
• Periods 5 and 6 will be rolled-out simultaneously. Indigenous community allocations will be posted with licensees identified next to the community allocation that would be eligible for community work.
• First Nations communities are excited to get their closure programs up and running. Communities without capacity are looking at services listed through the SRP website and reaching out to point of contacts and licensees.
• Licensees will not be able to access their Period 5 allocation until the Indigenous community tracker is submitted for a community where one or more of the licensees’ wells are located. Only one community tracker needs to be submitted.

Additional Items

• Industry noticed that there have been changes in the invoice process (as of February 9) on ETS that eliminates the flexibility of being able to submit varied amounts for multiple sites as long as the total amount submitted was under the grant amount. It now requires each site to be at or under the estimated site amount.
  • The issue is that some sites go as planned, some cost less and some cost more.Collectively the balance works out across the grant when there are multiple sites included. There was no notification on this and it is retroactive. This creates an administrative burden when making applications and submitting invoices.
  • ACTION: Government will follow-up at next week’s meeting.
• Q: How much was spent in Period 2? A: Committed spending was around $20 million. Period1b reassessed applications and provided an additional $115 million to address sequencing challenges.

January 27th IAC Meeting Updates

Period 5 and Period 6 Update

• The application start date has been pushed back to the second week in February to provide additional time for IT and data preparations. The urgency for companies to get in applications and start work is understood.  Both periods will be open until March 31, 2022.
• Supplemental guidelines will be published for each of Periods 5 and 6. This will include details on eligibility and process. Feedback received from public stakeholders, licensees, and program participants has been considered and integrated.

Period 5

• Allocation of $300 million across eligible licensees. Eligibility based on whether the licensee had2019 production and closure spending in either 2019 or 2020.
• Approximately 270 licensees will be eligible for Period 5. The team is working on determining and finalizing allocations.
  • Allocations will be posted online and eligible licensees will also receive an email notification.
  • Some new licensees have been left out of eligibility due to the parameters.
• Mergers and Acquisitions are complicating allocations. Simpler with mergers, acquisitions are more difficult given the need to have consistent BA codes. Licensees who have acquired sites that were held by other licensees will not be able to take over the SRP allocation.

Period 6

• $100 million will be allocated amongst Métis Settlements ($15 million) and First Nations Reserves ($85 million). Data is being finalized so that allocations can be calculated. When released, the allocations will be listed for the communities, and a list of licensees will accompany it.
• Applications will not be accepted until a community allocation plan has been submitted, as this plan identifies the sites that will be tackled using the allocation.
  • Licensees are required to be part of a community allocation plan for Period 6 if they have wells on a First Nations Reserve or Metis Settlement before they are able to apply for Period5.
• If a licensee has sites on multiple communities, only one of each of the First Nations and Metis Settlements they have wells on needs to submit a community allocation form in Period 6 before the licensee can apply in Period 5, they do not have to wait for all of the allocation plans.
• Do not foresee a large risk of communities not submitting allocation plans – communities are eager to move on the work.
• The departments of Energy and Indigenous Relations are working with the Métis Settlements General Council to help finalize allocations and facilitate conversations on settlements. The Indian Resource Council is doing this for First Nations Reserves.

Period 3 and 4 Update

• Applications close on March 31, 2021. Pace of spending appears a little slow for Period 3, possibly because Period 3 licensees (100% funding level) may have been a bit challenged with respect to capacity to plan out work and mobilize plans.
• Likely that full $100 million will not be used in Periods 3 or 4. Unused allocations may be used for a clean-up round, which we would look to get underway mid-2021. Looking at approaches in other jurisdictions to determine if there is a way to fast track the process fairly.
• To encourage applicants to get applications in, government will provide an update on the remaining allocation amount for each licensee and let them know there are about 5-6 weeks before the application period closes (target mid-February).
• Period 4 has received a steady pace of applications.
• Q: Is there an easy way to obtain a list of who the point contacts are within a company? Yes, CAPP and EPAC can help facilitate gathering this info.
• Q:  Did we resolve the sequencing issue? Yes, for Period 5 and 6 applicants will be able to apply at the same time for abandonments and phase 1 environmental site assessments. The rest of the sequencing requirements will remain in place. Want to continue to stage funding to enable licensees to have flexibility to apply for further stages as they uncover work requirements. This will reduce the risk of stranding grant funding in case unexpected costs are encountered by contractors. Application turnaround times are faster than before, which will hopefully give clients the ability to sequence their applications faster.

The governments of Alberta and Canada are advancing their commitment to ensure Indigenous businesses and communities play a meaningful role in Alberta’s post-pandemic energy strategy by targeting $100 million of federal Site Rehabilitation Program (SRP) grant funding to clean up inactive oil and gas sites in Indigenous communities across Alberta.

Alberta’s government worked with Indigenous communities, Indigenous businesses, the Indian Resource Council and the Metis Settlements General Council to develop the details of this grant allotment, which includes $85 million for First Nations reserves and $15 million for Metis Settlements to work with licensees to close sites located on or around their lands.

“The Site Rehabilitation Program is cleaning up legacy oil and gas sites across the province and creating thousands of much-needed jobs. As stewards of the land, this funding will ensure that Indigenous people benefit from resource development on land that was first inhabited by their ancestors.”

“Working with Minister Savage and the Government of Alberta, we are creating jobs, cleaning up our environment, and supporting the hard-working people in our oil and gas sector – including in First Nations and Métis communities.”

“This is an investment in a strong future for Indigenous people in Alberta, who will benefit from the jobs created and the reclaimed lands in their communities. Programs like this are game-changers for Indigenous communities.”

“First and foremost, I am thankful to the Creator for another day and for the bounty that Mother Earth provides. The SRP Indigenous set aside will allow Alberta First Nations and Metis Settlements to reduce liabilities by decommissioning and cleaning up well sites across Alberta. During this time, First Nations-owned companies and member-owned companies, along with existing and new partnership creations, can get working to create gainful employment in a difficult period as this pandemic and downturn of the oil industry has caused hardships for many. We look forward to working with the province, ministers, industry, Indian Resource Council and service providers to make this program a success. ‘Our Mother Earth takes care of us, as her children, we need to take care of her.’”

“This $100-million collaboration between First Nations represented by the Indian Resource Council, the Metis Settlements and the Government of Alberta shows unprecedented progress towards reconcili-action in the protection of land, lives and livelihoods.”

A second new funding allotment will provide up to $300 million to oil and gas producers who had production in 2019 and paid for closure work in 2019 or 2020. This is the program’s largest grant period and is designed to give contractors and licensees the funding and time to work on closure projects of all scopes and sizes – leading to the cleanup of a significant number of oil and gas sites across the province. As with all rounds of the Site Rehabilitation Program, only new work conducted after May 1, 2020 is eligible for grant funding. 

“Closure work creates jobs and positive environmental outcomes that enhance Alberta’s ESG record and provides valuable economic benefits to rural communities. PSAC has long advocated for a mechanism to accelerate the decommissioning of orphan and inactive sites to provide the sector with jobs during this prolonged downturn. We are pleased that the Governments of Canada and Alberta have heard us and responded with this important program.”

Including these two rounds, which will open to applications on Feb. 12, $800 million in SRP grants have been made available to eligible applicants since launching in May 2020. In total, the program is expected to generate almost 5,300 direct jobs and lead to indirect employment – and economic benefits – across the province.

The Alberta government continues to work with an Industry Advisory Committee and an Indigenous Roundtable to help make continuous improvements to the program and its processes.

Alberta’s Recovery Plan is a bold, ambitious long-term strategy to build, diversify, and create tens of thousands of jobs now. By building schools, roads and other core infrastructure we are benefiting our communities. By diversifying our economy and attracting investment with Canada’s most competitive tax environment, we are putting Alberta on a path for a generation of growth.

Quick facts

• • Through the Site Rehabilitation Program (SRP), launched in May 2020, the Alberta government is directing up to $1 billion of federal oil and gas COVID-19 economic stimulus over two years to get Albertans back to work by speeding up well, pipeline and site closure efforts in the energy sector.
  • As of Feb. 12, $310.3 million of grant funding has been allocated to 633 Alberta-based companies for periods 1 through 4 of the program.
  • Applications for grant periods 5 and 6 will remain open until March 31, 2022.
  • During period 6, Indigenous communities will be provided a community-specific allocation.
  • Contractors have until Dec. 31, 2022, to complete their work through the program.
  • Remaining grant periods for the balance of the $1-billion funding commitment will be announced in the coming months.

Related information

Alberta Energy has provided the SRP Industry Advisory Committee with the following update:

Period 5 and Period 6 preview details were posted late yesterday November 26 to give industry the opportunity to begin planning for the application periods, which open February 1, 2021.

1. Next steps on Period 5 will include Alberta Energy contacting by email licensees identified in Period 3 to inform them of the criteria for Period 5 allocations as described on the website.  This will take place over the next two weeks.  Alberta Energy will ask licensees that have been identified as potentially not having allocations to provide evidence of closure spending as set out on the website.  Alberta Energy will complete their final licensee allocation calculations in January.  As contact information can be challenging to keep updated, Alberta Energy asks that CAPP and EPAC remind their members that Alberta Energy will be sending information via licensees’ contact emails of record with AER or Petrinex, or both.

2. Next steps on Period 6 will include community discussions with licensees and oil field service companies.  Indian Resource Council will be supporting discussions with First Nations.  Final details on next steps are being worked out with Metis Settlements and Alberta Energy before work gets underway to set up their community discussions.

3. Period 6 funding is in addition to all previous rounds, and may be spent on or off reserve and on or off settlement.  Contracts for eligible activities on First Nations or Metis Settlements that were part of, or are intended for, Period 3, 4, or 5 applications will not reduce the funding available for those licensees’ remaining sites under Period 6.  Communities will identify which sites will receive allocated funding for eligible activities in Period 6.

4. Period 5 and 6 are both 50% of contract face value grant funding levels, with the potential for grants issued at 100% of contract face value where Indigenous contractors are the applicants.  This will enable licensees who may be unable to contribute to closure costs to have up to 100% of eligible costs covered by SRP grants.

5. Finally, benchmarks have been updated this week, too.  All new applications under Period 3 and 4 are being reviewed through the lens of the new cost reasonableness structures.  Grants issued to date at less than applied-for, or that were rejected, based on the previous benchmarks will be reassessed over the coming weeks.  Alberta Energy will focus their priority on new applications, but will notify grant recipients of any top-up amounts as soon as the reassessment is complete.  This is expected to generate additional field work from Periods 1-4 that may have stalled due to lower funding levels as a result of the previous cost benchmarks.

The next SRP IAC meeting is December 01, 2020.

Full program information available at: https://www.alberta.ca/site-rehabilitation-program-apply-for-a-grant.aspx

Summarized Minutes of the September 22nd IAC meeting.

Status Update

• Periods 1B:
  • Reviews were completed around September 15th. Decline notices have been sent out to companies who had not received a decline notice before (under Period 1). The website has been updated to state if applicants have not received an approval notice by September 15, 2020, they are likely declined for Period 1B.
  • Question: If applicants haven’t heard yet then it can be assumed that they’ve been declined? What is the rationale for not notifying all companies of the decline?
    •  Correct. All companies would hear back from Alberta Energy once – rejection reasons for period 1b would be the same as provided in the period 1 decline notice.
• Many grant agreements that were not coming back from applicants for Period 1 are starting to be submitted. At the last meeting it was discussed that Alberta Energy would provide applicants a reasonable amount of time to respond to grant agreements in order to re- allocate any funding that is not going to be used.
• Period 2 – reviews and notifications are completed
• 11,000 applications have been approved for Periods 1 (4,650), 1B(6,300) and 2(338). The full
• $200 million available for those periods has been allocated amongst approved agreements.

• Periods 3 and 4
  • Period 3 – 940 applications received to date, 642 reviewed, 67 approvals. The rest are not necessarily declines, Energy will be reaching out to applicants for missing information and clarifications. Approvals will begin to go out to applicants this week
  • Period 4 – 527 applications so far; these applications are far much larger allocations and add complexity in terms of review. Some applications have been work work that exceeds $3 million. Approximately 20 applications have been reviewed so far.
• Updates and Reporting
  • Mapping function enabled and posted on website to show geographical distribution of site locations for approved applications.
    • ACTION – Alberta Energy would like to hear from Committee members on whether or not this function is useful, any suggestions for improvement, and any potential impacts to stakeholders.
• Future Periods
  • This remains a standing discussion item. Work continues internally to evaluate the success of periods 3 and 4, determine automation capacity, and in general ensure that the systems in place can handle the level of funding for Period 5.
  • Alberta Energy encourages companies not to wait for period 5 if they have closure work that can be conducted now. Period 5 will be incremental to the other rounds, and want to get spending out to service companies now.
  • Alberta Energy is still targeting Fall for the launch of period 5, assuming we can get period development completed.
  • Question: Has there been any thought to removing the sequential rollout of funding (for abandonment work before surface work).
    •  Sequential aspect of Period 1B was designed to mitigate risk of stranding approved grant funding money for surface work (if downhole work isn’t approved and licensees can’t provide their own funding to fill the gap). This risk remains, and we’re actively considering the best way to move forward. We are trying to make program administration as straightforward as possible and avoid project managing.
• o Comment: Releasing eligibility details as soon as possible will be beneficial to the program. Producers are not likely to contribute their own spending on closure when it may be eligible for additional funding in Period 5.

Issues

• Alberta Energy has been asked about instances where applicants who were unsuccessful under Period 1 and 1B have been re-applying using the same contracts under Period 3 or Period 4 without talking to the licensee. Licensees who have changed or expanded their closure plans after receiving allocations in Period 3 or 4 may be surprised to learn that their allocations have gone towards companies with old contracts developed for previous periods.
  • – Alberta Energy has been in contact with licensees regarding Periods 3 and 4 and has been asked to provide copies of applications made under a licensee’s allocation. We are looking into what additional steps can be taken, including checking the authenticity of contract documents or reaching out to licensees to confirm.
• Potential challenge that licensees may be using SRP funds to cover closure costs, but still charging their Working Interest Partners for the full portion of closure costs. WIPs would not necessarily know whether grants had been approved, or how much grant funding had been approved for that site.
  • SRP Government and Agency Advisory Group is working together to ensure there is no double dipping on Working Interest Claims.
• Alberta Energy has heard that some service companies are creating concerns for landowners by causing crop damage and other damaging impacts by not respecting right of ways. When approached by landowners, these service companies have claimed that issues should be sent to the Government of Alberta as the work is funded through a government program. Alberta
• Energy will be clarifying on the SRP website that any site impacts are the responsibility of the licensee, and that the contract for work is between the licensees and the service companies.

ESAA has selected 8 members to be a part of the ESAA SRP Working Group. ESAA thanks everyone who expressed interest in being a part of the Working Group. The following individuals were selected:

• Chair – Stacy Thygesen, Principal, JSK Consulting
• Co-Chair – Darren Cherniak, President, North Shore Environmental Consulting
• Member – Marissa Reckman, CEO, AGAT Laboratories
• Member – Daniela Felske, Senior Consultant, Esker Consulting
• Member – Amiele Thibault, Associate Group Lead – Prairies, Golder Associates
• Member – Scott Purves, VP Operations, Matrix Solutions
• Member – Cory Summer, Senior Environmental Scientist, Millennium EMS Solutions
• Member – Michael Parker, Manager, Environmental Consulting, Tervita
• Member – Lance Hayman, VP, TR3
• Member – Michelle Taylor, VP Client Services, Waterline Resources

Summarized Minutes of the September 8th IAC meeting.

Status Update

Alberta Energy has processed over 35,000 applications of the approximate 37,000 received. – 7,883 applications have been approved, representing $198 million in grant funding.

Period 1b review is complete. 10,460 applications have been re-assessed and all funding has been allocated.

– 3,500 approval notifications are remaining to be sent out to applicants.

Notifications are expected to be sent by September 15. Of the $195 million in total approved grants (across all periods) so far:

– 65% of approved applications are for abandonment work

– 35% of approved applications are for remediation and reclamation work (including phase 1 and phase 2 Environmental Site Assessments)

Period 3 – 788 applications submitted; Period 4

– 289 applications submitted A map showing all approved Site Rehabilitation projects across Alberta has been added to the Site Rehabilitation Program website under Grant Funding Status. This will be updated weekly.

Issues Discussion

Future period design

– Government is clarifying design and next steps for Period 5 development. Intent is to launch Period 5 this fall.

– Allocation continues to be preferred approach by licensees. Government is assessing outcomes of Periods 3 and 4 to see if outcomes are being met with these allocations.

– The ability to automate as many features as possible (especially determining incentive/funding level) remains a consideration in future design.

Government is finding that there are grant agreements that have been sent to applicants but have not been received back (approximately 850).

– Unsigned/unreturned grant agreements may be a result of applicants waiting for Period 1b review (i.e. may be checking to ensure they have their program planned before signing agreement).

– Depending on the grant amount approved, contractors may decide not to proceed with the work as licensees may not have the funds to cover the remaining balance.

– Government wants to make sure that we are using all of the available funding within the set time frame. Any allocated funds tied to unsigned/unreturned grant agreements will be pulled back and rolled forward into future periods. Applicants will be contacted prior to this to provide a final opportunity for them to submit the grant agreement.

Cost overruns

– Some stakeholders have been asking for a contingency for cost overruns. The main concern from Government is that we risk stranding this money and forfeiting this amount from the Federal Government.

– There are risks to contractors with carrying cost overruns in addition to the risks already discussed regarding prime contractors carrying costs while they are waiting for interim/final funding.

– Providing contingent funding based on potential cost overruns would be challenging to administer, especially in a fair and equitable manner. What would the bounds be as there are some very extreme and costly cases? How would this be fairly allocated? Ultimately the responsibility should be on the licensees and oilfield service companies, not built into the grant funding.

– Is there potential for an emergency supplemental allocation? In other words, is there a way to fast track approvals given new information acquired (i.e. for environmental or public safety reasons). Example of groundwater contamination discovered during remediation work as that would not have been discovered in a Phase 2 environmental site assessment.

– There may be some flexibility Government can look at building in for work undertaken in good faith that may not hit a grant milestone.

Summarized Minutes of the August 25th IAC meeting.

SRP Status Update

• Alberta Energy has received over 36,000 applications to date and has awarded $162 million in grant funding.
• Period 1b reviews are ongoing and are anticipated to be completed by the end of August.
• Approximately 8000 applications have been re-assessed; the success rate of applications under Period 1b is 69-70%.
• All applications received under Period 2 have been processed. Alberta Energy has reached out to applicants in cases where information is missing from applications. Approximately half have responded so far.
• Emphasis has been on getting Round 1 and Round 2 reviews completed before proceeding with reviews under Period 3.
• Request from member for Alberta Energy to consider providing the weekly website update information by period rather than collectively.

Follow-up on action items (Alberta Energy)

• We are working to determine how we can present more information as part of the weekly website updates, specifically looking at ability to report on geographic location of approved work and the type of work being funded.
• Follow-up item on how to ensure licensees are paying the remaining 50% in the event that a contractor receives 50% funding under Period 4 of the SRP. Alberta Energy presumes that contracts would be in place to ensure work is done and paid for, any contract disputes would be between the licensee and the oilfield service provider. If there are any specific examples or circumstances where this has occurred we can assess and determine if any mitigative action can be taken.

Future Periods

• Alberta Energy will be assessing period 3 and 4 results with respect to the allocation-model of grant funding, including how well the review process works with this model (versus the first come first served model of Periods 1 and 2).
• Also assessing capacity to automate (regarding 25, 50, 100% funding increments), which will also influence how the next round is scoped.
• Work is ongoing. Any input on the next period can be discussed at this Committee.

Issues discussion

• Identified a potential data glitch with sites that have been recently abandoned but are labeled as reclamation exempt.
• Have any members encountered issues where the sub-surface rights didn’t transfer with the surface rights (particularly in bulk sales)? One Committee member will check in on possible occurrences and report back.
• Wanting to get producer representatives participating on the Indigenous roundtables to connect operators with the Indigenous communities. We’ve seen a great deal of readiness and communities have been keen to hear more from producers about how to get in to the procurement process and plan work for future rounds.

The Environmental Services Association of Alberta (ESAA) is forming a Working Group to assist ESAA’s representatives on the Site Rehabilitation Program Industry Advisory Committee (IAC).

As the province of Alberta prepares to launch the largest phase of the program this fall, it is asking each committee member’s organization to provide input for this phase.  This is not an opportunity to comment or raise concerns about previous phases.  It is our opportunity to take some lessons learned from earlier phases to help Alberta Energy deliver this largest phase successfully.

Working Group Terms of Reference

• Chair: ESAA IAC representatives – Stacy Thygesen (JSK Consulting) and/or Darren Cherniak (North Shore Environmental Consultants)
• Membership: 7 – 9 ESAA members representing a diverse cross section of the membership
• Mandate: To develop a list of recommendations for the largest phase of the SRP to be released in late 2020.
• Term:  The working group will have its first meeting in mid-September and will meet every two weeks and may move to monthly following the release of the phase until December 31st.  The ESAA Board may extend the term of the committee depending on additional feedback that may be required from Alberta Energy.
• Compensation:  These are voluntary positions. There is no compensation for participating as a member of the working group.
• Meeting Format:  Meetings will be held virtually via GoTo Meeting or conference call.

If you are interested in being a member of the working group and are an employee of a member company in good standing with ESAA and are a positive, forward looking person, please email: [email protected] along with your contact info, brief company profile and rationale on why you should be a part of the committee. Please respond by no later than September 4th, 2020.

ESAA Management and Board will pick members that reflect a cross section of the industry and may add people if a sub-sector is not represented in the submissions.

We thank everyone in advance for your offers to support ESAA and the Industry.

Summarized Minutes of the August 11th IAC meeting.

SRP Status Update

As of August 7th, $137 million worth of grant applications have been approved to 214 companies.

Period 1b – $66.4 million approved.

• Approximately 4000 applications have been approved so far (73% acceptance rate). Notifications for accepted applications will begin going out within the next week and continue throughout the remainder of the review of Period 1b.
• The Department is still targeting end of August for completing Period 1b reviews.

Period 2 – 308 accepted, 74 declined. On August 7 the Department sent letters to applicants with declined applications to give them an opportunity to provide missing information. Approval letters have also started to go out.

Period 3 – Just under 500 applications have been submitted to date. The application period is open until March 31, 2021. The Department will begin reviewing these applications once Period 1b reviews are complete.

Period 4 launched Friday August 7th. The allocated amounts for each company are posted on the website. This is the first period with 50% funding, and also the first round to include incentives to get 100% funding if Indigenous OFS companies are doing the work. The supplemental guidelines provide additional details on these incentives.

Other updates

• Interim Invoicing –interim invoicing is currently being accepted by e-mail and Government is working towards setting up an automated process for this.
• Additional detail on invoicing will be posted on the website as there are updates or examples available.
• A declaration form will be added to the website for companies to complete once reclamation work is finished. This will allow companies to submit reclamation work for the final invoicing before a reclamation certificate can be obtained.
• Through the Indigenous Roundtable, a list of Indigenous companies and where they operate has been compiled and will be available on the website so companies can connect and create partnerships. The Department will reach out to IRC to confirm the list before it is finalized.

Issues and Discussion

Discussion on how much downhole work has been completed, whether the GOA tracks the type and amount of work that has been carried out, and on reporting and transparency of the program more generally.

• It was noted that to date, in general, there has been a good distribution in the approved applications between subsurface and surface work.
• The Government publishes quarterly reports on grant funding that is distributed.
• The intent is to be transparent in reporting. More information will be published in the future as it is gathered by Government
• FOLLOW-UP ACTION for Department of Energy: Provide an update at the next meeting on any more detailed reporting data that can be shared (committee members noted the following information would be helpful: geographic distribution of grant funding, type of work being completed, and the status of work completed).

Discussion on whether there is a way to ensure licensees pay OFS companies the other 50% of contract costs (in the 50% co-pay funding scenario. Does the Government want to see that invoices have been paid by licensees or have confirmation that licensees have paid the remaining funding amount? If confirmation is needed from the licensee, but is withheld, is there a mechanism for OFS companies to receive the final grant funding?

• FOLLOW-UP ACTION for Department of Energy: will follow up on this and report back.

Question on committed spend targets under the Area-based closure program: Does grant funding count towards committed spend, and do licensees need to spend their committed spend in 2020? Does funding have to be used for the Area-based closure program that was submitted?

• The AER has suspended the Area-based closure spend targets for the 2020 year. The committed spend was used by the Department to calculate grant allocations, but companies are not held to these spend targets. Grant funding can be spent on
• addressing any closure obligations of the licensee, not just those committed in the Area- based closure spend.
• FOLLOW-UP ACTION for Department of Energy: Clarify this information on website.

Question on whether there are timelines for submitting interim invoicing.

• There are not, only the requirement that 60% of the work is done. The big timing consideration is to make sure that all work is complete and final invoicing submitted by the end of 2022. Detailed invoicing information is available on the website.

Suggestion from a committee member on dedicating additional funds to Period 1b to get more people in the field working. Need to understand how much of the approved grant funding is in the hands of OFS workers (and report on this). Are there tools that the GOA can look at that help to refocus or drive the program’s goals and get Alberta’s labour force back to work more quickly? Are there ways to incentivize and accelerate work?

• FOLLOW-UP ACTION for Department of Energy: connected to data reporting action item

Future Periods

Work is ongoing, scope has not yet been determined. We will be reaching out to this committee, as well as our Indigenous roundtable and GOA/Agency committee for feedback.

ESAA has received a number of requests for additional information about the SRP Industry Advisory Committee. ESAA has received permission from Alberta Energy to share the terms of reference for the committee. Terms of Reference – download (PDF)

On July 30th, ESAA representatives attended their first Industry Advisory Committee Meeting. The following are updates from that meeting:

SRP Status / Updates

• Reviews for Period 1b and Period 2 are continuing, we’re tracking close to $100 million in grant funding allocated.
  • For Period 1b there are 421 accepted applications and 96 declined.
  • For Period 2 there have been 298 accepted and 84 declined. Staff will be going through the declined applications and contacting applicants to revise issues and re-assess based on criteria for re-assessment being used in Period 1b.
  • Approval/decline statistics may change as applications undergo QA/QC processes.

• Review for Period 3 will begin as soon as Period 1b is done. On the advice of the Committee, Alberta Energy is focusing resources on 1b to get back to applicants as soon as possible.

• The Government of Alberta is working diligently to launch Period 4, however technical issues with the way the system processes grant request amounts have delayed the launch temporarily.

Issues and Discussion

• Discussion on the merits of the Saskatchewan model for distributing grant funding and whether Alberta could adopt a similar model to alleviate challenges for oilfield services companies with respect to cashflow and timely receipt of grant funding and help ensure there are no missed opportunities for companies to participate.

• Several members felt that large changes to the model at this point in time are not practical, but tweaks to improve issues can continue.
  • It was expressed that some of the challenges faced in previous Periods will be minimized moving forward (ie. allocation system for Periods 3 and 4 is more aligned with current company planning practices, progress in adapting current system to make the application process more straightforward, and that more information sharing and increased user awareness would lead to better outcomes going forward).
  • The Government of Alberta connects with Saskatchewan and BC on the program and will remain open to learning and adapting.

• The week of July 28 Alberta Energy rolled out the interim invoicing process on the website. It is currently a manual process that has an approximate 14 calendar day turnaround time. An automated solution is underway.
  • Clarification that the invoice should be made out to the producer, not the Government.
  • The Producer must acknowledge that the work has been done before the invoice is submitted to the GOA.
    • Member to provide a PDF example of what constitutes an acknowledgement of work complete. Alberta Energy will check internally and determine if we’re on the same page with what constitutes an acknowledgement of work. Further clarification will be provided if needed.

• Discussion on how to connect Indigenous companies and producers, especially those operating on Reserve and on Settlement. Alberta Energy wants to onboard producers onto our Indigenous Roundtable meetings, looking for advice on how we can do that (who within the company would participate).

• A comment was made on the application turnaround time. At the last meeting it was noted that about 500 applications are being completed per day, but this is not matching up with the updated statistics for applications reviewed.

Liability Management Framework update

• Government announced updates to the Liability Management Framework today (June 30).

• This includes:
  • Replacing the LLR with a new system to assess capabilities of operators in meeting obligations.
  • Annual spending targets (future roll-out, targeted engagement with regulated community to determine practical implementation timeline).
  • Opt-in function for landowners, including Indigenous communities on Reserve and Settlement.
  • Panel to provide input on legacy and post-closure site management.
  • Note: the news release can be found here

On Friday, ESAA’s Board of Directors met with a senior representative of Minister Savage’s office and a member of the SRP team.  Over the past few weeks, ESAA has had a number of meetings with the Alberta Energy team working on the SRP and expressing the concerns of the environment industry sector.

ESAA is please to announce that effective immediately, ESAA will be joining the SRP Industry Advisory Committee.  The Committee meets bi-weekly and is responsible for providing input on the operation of the SRP, providing feedback for future improvements in the program and providing recommendations to the Government for future SRP Increments.

ESAA will be represented on the Committee by ESAA President, Stacy Thygesen, JSK Consulting Ltd. and alternate member, Darren Cherniak, ESAA Director, North Shore Environmental Consultants Inc.

“ESAA would like to thank the Government of Alberta for understanding the important role the Environment Industry will play in Alberta’s Site Rehabilitation Program and including our association to represent our members on the SRP’s Industry Advisory Committee. ESAA is confident our collaborative approach to managing inactive and abandoned well sites, facilities, pipelines and surface leases in Alberta is the most productive path forward.   On behalf of our members and industry, ESAA will continue to work hard to ensure it clearly communicates the concerns and opportunities available at the committee meetings and provide beneficial updates to the program” – Stacy Thygesen, ESAA President, JSK Consulting Ltd.

ESAA has created an information page, where we will post regular updates.  The page can be found at: https://esaa.membeesites.net/srp/

In addition, ESAA has created an email address for the program, [email protected] . We kindly ask that you use this email address for all comments, feedback and suggestions regarding the SRP for the ESAA representatives instead of emailing them directly.

Thank you for your continued support of ESAA!

• Phase / Period 3: Opens Friday, July 17th. Full details about this next round of funding available in the information below.
• Phase / Period 4: Will open at the end of July.  Funding details below.
• Phase / Period 5: Will open later this fall and will be the largest of the phases
• Two more potential Phases / Periods in early 2021
• ESAA continues to work with Alberta Energy to express the importance of ESAA Member involvement and is working to get a presentation from Alberta Energy at RemTech 2020.

CAODC Update Period 1 Update

• 35,376 applications reviewed, 4,355 verified (approved), 4,021 notifications and grant agreements sent out.
• $64.6 million in grant funding approved & allocated to 140 companies in Alberta.
• Payments will be processed once the grant agreements are signed and returned. Grant installments will be paid based on invoice submission.

Period 2 Update

• Currently undergoing quality checks.
• All 382 applications have been reviewed.
• Guidelines will be updated online in V.2.0 for clarification.
• Member reporting portal will come to fruition as a result of member request.
• Still very little clarification surrounding reasons for rejected applications.
• A helpline for guidance, feedback, and questions would be helpful.

Period 1B Update

• Period 1B is redeploying unused funds from Periods 1 & 2.
• There are no new applications being accepted. Period 1B involves reassessment of rejected Period 1 downhole work. Rejected applications from Period 1 will automatically be reassessed.
• Supplemental guidelines for Period 1B will be released shortly.
• Intention of $30,000 grant limit in Period 1 was to capture smaller programs; Government of Alberta did not expect some service companies to break down their applications into smaller chunks.
• Project start date must be prior to December 31, 2022.
• Third party companies cannot apply on behalf of a company.
• There are now 80 people reviewing Part 1B applications.
• If applicants have not yet received a response, their application may be in “holding” for consideration for Part 1B.

Reasons for Application Rejection in Previous Periods

• A termination clause was included in the contract.
• All work must be completed by December 31, 2022.
• Missing Master Service Agreement (MSA) attachment or MSA number. (Re-evaluation will include CAODC MSA number being approved).
• Government of Alberta cannot be listed as a party in the contract.
• Reviewers may have misunderstood a contractor applying on behalf of a licensee, and mistaken the situation as the contractor being a “middleman”.
• Scope and or pricing details were broken down in a way that confused reviewers. These cases will be reviewed again going forward.

Period 3

• Part 3 funding allocation breakdown has not yet been released.
• $130,000 – $150,000 per licensee can be used to leverage further spending. ($100,000,000 divided by 720 oil companies/licensees).
• Part 3 will be released at the same time as period 1B.

Period 4

• Focus will be on area-based closures.
• Up to 50% coverage.
• Incentives for companies that use local indigenous companies (up to 100% funding).
• Indigenous companies are defined as:
  • at least 50% owned and at least 50% of their employees or contractors being Indigenous, or;
  • at least 50% executives being Indigenous and at least 50% of employees or contractors being Indigenous.

Additional Information

• Guidelines will be clarified and released within the next two weeks.
• Companies are encouraged to apply ASAP for future Parts, i.e. no need to wait until Part 4 to apply for Part 4.
• Some applications have been withheld and will be reviewed by UWI. Going forward applications will be grouped by UWI.
• Programs don’t need to be limited to $150,000, co-paying is permitted, i.e. a portion funded by the licensee, and a portion funded by the Government of Alberta.
• Several companies have cancelled spending based on anticipated funds from the AB SRP.
• Part 3 & Part 4 application periods will be open until March 31, 2021.
• Prime contractors are permitted to submit applications on behalf of subcontractors.