LAND AND PROPERTY RIGHTS TRIBUNAL
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Citation: |
Bennett v Ember Resources Ltd., 2024 ABLPRT 906028 |
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Date: |
2024-11-14 |
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File No: |
RC2021.2423 |
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Order No: |
LPRT906028/2024 |
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Municipality: |
Lacombe County |
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In the matter of a proceeding commenced under section 36 and 29 of the Surface Rights Act, RSA |
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2000, c S-24 (the “Act”) |
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And in the matter of land in the Province of Alberta within the: |
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SE 1⁄4 -26-40-22-W4M as described in Certificate of Title No. 892 212 165 B (the “Land”), particularly the area granted for a well site in LSD 2 by Alberta Energy Regulator Licence No. 0117500 (the “Licence”), collectively (the “Site”). |
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Between: |
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Ember Resources Inc., |
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Operator, |
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- and - |
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Dennis W Bennett and Sylvia Sawyer, |
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Landowners. |
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Before: |
Susan McRory (“the Panel”) |
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Appearances by written submissions:
For the Applicant: Mr. Dennis Bennett
For Ember Resources Inc. Mr. Tom Owen, OWEN LAW
DIRECTION TO PAY PURSUANT TO
SECTION 36 OF THE ACT
DECISION AND REASONS
SUMMARY
[1] The processing of this application was delayed by reason of errors made in the first application and complicated by an attempt by Ember Resources Ltd. (EMBER) to impose a reduction of compensation without the consent of the landowners.
BACKGROUND
[2] On August 19, 2021, Dennis Bennett filed what he described as a “corrected” application under section 36 of the Surface Rights Act seeking recovery of unpaid compensation due under a surface lease dated March 21, 2006. The reported rate of annual compensation was $2,166.00, but the claim for a missed payment in 2021 was for $1,934.00. There is a handwritten notation to this effect in the comment section of the form: “Upon renewal Ember has reduced fee from $4100 to $2166.”
Attached to the application was a letter dated August 17, 2021:
We have already submitted application and have a file number:
RC2021.0514
We made an error regarding date of year claimed. It should be 2021.
We are re-submitting claim with correct date.
We apologize for the inconvenience
Please note payment reduced $2166.00 but is being paid.
[Emphasis added]
Attached was a letter dated November 19, 2020 to the Applicants from EMBER proposing a reduction, but the letter was not signed by the Landowners.
[3] The Certificate of Title names the Applicants as joint owners of the land.
[4] Records obtained from the Alberta Energy Regulator on September 20, 2024 and June 2, 2020 identify EMBER as the current Licensee and 100% working interest participant for well 0357137. The status of the well license is “Issued”.
[5] A Notice of Proceedings was issued to EMBER requiring a response within 30 days.
[6] On December 5, 2021, EMBER contacted the Tribunal requesting a sixty-day extension to respond on this file and five others. That extension was granted.
[7] On December 17, 2021, EMBER made a request under section 29 of the Act for a reconsideration of the Notice and Demand for Payment based on what were described as “important errors of jurisdiction and an important error of fact” and as being “decided on an unfair process.”
EMBER’s first argument was that a Notice and Demand for Payment is a decision that would be subject to a request for review under section 29.
Under the heading “Errors of Jurisdiction”, Mr. Owen suggested that the Tribunal had made an important error and had breached the rules of natural justice by not giving EMBER notice of the application before making the “decision” to issue the Demand. EMBER also suggested that the Tribunal must make a finding of fact before issuing the Notice, that it had fettered its discretion in “routinely” issuing Notices, that the Tribunal had improperly delegated its authority to administrative staff to issue the Notice and that the Tribunal had failed to provide written reasons for its decision.
Under the heading “Unfair Process” EMBER argued that it had not been given an opportunity to make submissions or to “know the case against” it because no notice had been provided.
Under “Error of Fact” EMBER suggest that the demand for was $2,166 and that the only lease that EMBER has “on this land” was based on annual compensation of “$4,100.00.”
Under “Adverse Effect” EMBER suggests that the decision to issue a Notice has “significant adverse effect” as the “money allegedly owing automatically becomes a debt to the crown” and the right to operate may be terminated.
Under “Landowner breached the Rules” EMBER suggests that the Landowner did not submit “an accurate and complete application” as the amount claimed was less that $4,100.00.
Under “Relief Sought” EMBER requested costs against the Landowners but did not provide an invoice.
PRELIMINARY ISSUES
1. Does section 29(1) apply to a Notice and Demand for Payment?
2. In the alternative, is the Demand an interlocutory or interim decision with a limited ability to be challenged?
3. In the alternative, has EMBER established the basic requirements that would allow for re-consideration?
DECISION ON THE PRELIMINARY ISSUE
1. Section 29 (1) does not apply to a Notice and Demand for Payment. Neither reflect a final decision by the Tribunal. Both are issued in advance of the merits of the application being considered.
2. In the alternative, if the Notice and Demand for Payment could be characterized as a “decision” of the Tribunal, then it would be an interlocutory or interim decision. The test provided for in 689799 Alberta v. Edmonton (City) 2018 ABCA 212 (CanLII) which would allow for a review has not been established. As a section 29 application is a discretionary remedy, this Panel would not consider a review in these circumstances.
3. In the alternative, EMBER has not established the basic requirements that would allow for re-consideration.
REASONS FOR THE PRELIMINARY DECISION
[8] Section 29 of the Surface Rights Act gives the Tribunal the discretion to rehear an application, or to review, rescind, amend or replace a decision or order made. This is a discretionary remedy, not a right to appeal as the Court of Queen’s Bench is the appropriate forum for an appeal or judicial review. In a series of cases including McAllister v Long Run Exploration Ltd, 2018 ABSRB 603 the Board has described the process in these terms:
A reconsideration threshold is not an appeal, but rather a further review of a decision where the Board decides whether to reconsider its original decision due to extenuating circumstances. The threshold which must be met in the reconsideration process requires the Board to be satisfied that the original decision should be reopened. It is not sufficient that the party simply disagrees with a decision. Nor is the purpose of the reconsideration process for a party to simply repeat its arguments or bolster the portions of its case which did not persuade the original panel. [Emphasis added]
[9] There are three different approaches to the question of whether section 29 should apply to a Notice and Demand. All three lead to the same result — that the application for re-consideration should be dismissed.
Is the Notice and Demand for Payment a “decision” or “order” within the terms of Section 29(1) (b)?
[10] The starting point for analysis is the oft quoted “modern” rule of statutory interpretation:
Today there is only one principle or approach; namely the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament.
Construction of Statutes, 2nd ed. (1982) Elmer Driedger p. 87 Rizzo & Rizzo Shoes Ltd., Re. 1998 (S.C.C.), Bell Express Vu Ltd. Partnership v. Rex. 2002 (S.C.C.)
[11] The terms “decision” or “order” are not defined in the Act. I turn then to consider the scheme of the Act.
What is the scheme provided for in Section 36?
[12] Section 36 creates a statutory remedy that does not otherwise exist. It does not change the contractual obligations of the parties; it proves relief to landowners in the event that operators do not pay. But the statutory regime prescribes certain steps that must be taken before an application can be heard at all.
First, the person entitled to receive money payable by an operator under a surface lease may submit to the Tribunal written evidence of the non-payment. Without written evidence, the application will be dismissed.
Second, upon receiving evidence, only if the Tribunal “considers that [the evidence] satisfactorily proves the non-payment” is the Tribunal required to send a written notice to the operator demanding full payment. The language is important. The job of the Tribunal is to “consider” whether the evidence provided satisfactorily proves the non-payment. The Legislature has not used the word “decide”.
The “next step” is that the Tribunal shall send “written notice to the operator demanding full payment.” Again the words are important. Written notice is required and the particulars of that written notice must include a demand for payment. There is no discretion in this regard.
However, issuance of the demand is the trigger for other actions to follow, so no immediate consequences flow. Issuing the demand to the Operator is a step in a procedure that is longstanding and equally applicable to all operators. Section 36 provides a scheme of due process and clearly outlines the possible consequences. If the notice is not complied with, the Tribunal may, by written order served on the Operator, take steps to suspend the Operator’s right to enter the site. Only after suspension and “after giving the operator written notice of its intention to do so”, is termination an option. The Operator has a further 30 days after the demand to prove to the Tribunal that full payment has been made (See section 36(6)).
Do the Surface Rights Rules provide any direction?
[13] Section 8(2) of the Act gives the Tribunal the power to establish its own rules governing practice and procedure. While there is no definition of “decision” or “order” in the Rules, there is direction with respect to what constitutes a “hearing” and what “notice” entails.
[14] The Rules define “proceeding” in terms of a pre-hearing dispute resolution conference or hearing. “Hearing” is defined as “a hearing by the Board [Tribunal] under the Act or other legislation authorizing the Board to make a decision.”
[15] There is a separate definition for “Notice of Hearing”:
...a notice from the Board [Tribunal] stating the date, time and place that the Board [Tribunal] will hold a hearing and giving reasonable particulars of the matter in respect of which the hearing will be held.
[16] On a plain reading of the rules, notice of a hearing would seem to be a different “thing” than the hearing itself.
[17] Rule 23(2) provides that: “if the Board [Tribunal] is considering an application by way of written submissions, the Board [Tribunal] may issue a notice to the parties”. Subsections (a) through (f) list the requirements for notice. It must:
(a) be in writing;
(b) briefly describe the subject matter of the application;
(c) indicate the date by which a written submission must be filed;
(d) state that the Board [Tribunal] may grant the application or issue a decision if there are no submissions objecting to the application;
(e) indicate that copies of the application and other documents filed in support of the application are available upon request; and
(f) contain any other information that the Board [Tribunal] considers necessary.
[18] The Rules also provide direction as to what must be included in the decision. Rule 33 specifies that the decision “must be signed on behalf of the panel by a member of that panel”. Decisions also must specify an effective date. Rule 34 states that:
The decision of a panel of the Board [Tribunal] is the official decision of the Board [Tribunal] effective on and after the date the decision is signed, unless otherwise specified by the Board [Tribunal].
Decisions of the Tribunal are also given decision numbers.
[19] The Notice that was provided to EMBER was not signed by a member, did not indicate an effective date and bears no decision number.
[20] The Notice that was provided to EMBER bears none the hallmarks of a decision and all of the hallmarks of a Notice of Hearing.
What is the object or purpose of section 36?
[21] Justice Sirrs in Devon Canada Corp. v. Surface Rights Board 2003 ABQB 7 (CanLII) reflected upon the purpose of section 36:
...the function of section 36(5) and 36(6) appears to me to provide the surface owner with some assurance that if they cooperate with providing the oil industry access to their lands, they need not fear the operator will not pay them.
The sections provide a pragmatic solution whereby the surface owner need only provide the existence of a lease and that rent has not been paid.... (Para 29)
In Provident Energy Ltd. v. Alberta (Surface Rights Board) 2004 ABQB 650 (CanLII), Justice Erb expanded on Justice Sirrs’ comments:
In my opinion, the purpose of Section 36 of the Act is obvious. It is to provide a mechanism by which the surface owner is guaranteed payment of the compensation to which he is entitled whether the compensation has been fixed by an agreement or not. In order to carry out its duties in some sensible fashion, the Board [Tribunal] would have to determine whether the lease was valid and whether compensation was payable to any party and by whom. As Sirrs J. held in the Devon case, the application of Section 36 is discretionary and even if a landowner shows sufficient evidence that a lease exists, the Board [Tribunal] is not bound to order compensation. If the Board [Tribunal] was bound to do so, this would amount to a fettering of its discretion.
[22] Our Court of Appeal has stated that the Tribunal’s process for determining compensation is intended to be “an expeditious yet fair method.” (Imperial Oil Resources Ltd. v. 826167 Alberta Inc. ABCA 131 at Para 16) That same language was used by the Court of Queen’s Bench in Husky Oil Operations v. Scriber 2013 ABQB 74 at Para 11.
Is there any assistance to be found in academic commentary and the case law?
[23] Sara Blake, in her definitive text Administrative Law in Canada 5th Edition, provides this direction:
Before a decision is made, notice must be given to all persons who may be affected by it (except in cases of emergency). Failure to give notice will likely be fatal to any decision. The purpose of notice is to alert persons whose interests may be affected so that they may take steps to protect their interests. (Page 29-30)
Ms. Blake also discusses what sorts of actions by a public official would give rise to judicial review:
Not everything that a public official does is reviewable. A court may decline to review a communication that does not involve the exercise of authority, such as a letter expressing an option, warning the recipient to comply with requirements, proposing a meeting or refusing a request to do something in the absence of an obligation to do it. (Page 177)
[24] In an interesting case from Nova Scotia, the Court held that a warning of what consequences would flow does not constitute a “decision in an administrative law sense” (para 19). The Court went on to consider the alternative argument as well. (See Ranger v. Nova Scotia Association of Social Workers 2000 NSSC 85)
Conclusion
[25] Based on the scheme created in the legislation, Notice and Demand are statutory prerequisites to having the matter put before a panel. Ultimately, the panel hearing the matter may determine that there is insufficient evidence establishing non-payment or identifying the operator. The Notice and Demand do not result in a decision that impacts the rights of the parties. They are part of the legislated process that must be followed in advance of a decision that will affect the rights of the parties.
At least according to the Rules, there is a distinction between a hearing as the place where the decision will be made and a Notice of Hearing which outlines the process that will follow, including the process for requesting a copy of the file and a warning that proof of payment and a written response are required within 30 days of the date of the Demand.
Based on the object or purpose of the legislation, the Act creates a unique remedy, but one that can only be accessed if certain statutory requirements are met. Given that the purpose of the Act is to provide a “pragmatic” and “expeditious” process, it would make no sense to characterize those pre-requisites as decisions or orders that are capable of being reconsidered or reviewed. While the word “decision” may apply in everyday situations, we are dealing with a decision in an administrative law context.
There is some support in the case law and academic commentary to suggest that a warning as to what might happen next is not a decision per se.
[26] Accordingly, this Panel concludes that the Notice is not a “decision” to which section 29 would apply.
In the alternative, could it be argued that the statement in the notice to the effect that the “Board considers that it satisfactorily proves the non-payment” is itself a decision?
[27] Following the lead of Chief Justice MacDonald in Ranger, if this Panel is mistaken as to the characterization of the Notice, then the question arises as to whether it is a decision that should be re-considered.
[28] The authors of Practice and Procedure Before Administrative Tribunals, Macaulay, Sprague and Sossin, make this observation:
Every time an agency elects to do something (or to do nothing), it has made a decision. Decisions are the things the agency resolves to do, or not to do, to allow or not to allow. Every question before an agency results in a decision, even if that decision is to do nothing. (Page 22-1)
[29] Arguably then, the Tribunal has decided to do something – it satisfied itself that there was evidence of nonpayment and issued the demand.
[30] But that is by no means the end of the discussion. Macaulay, Sprague and Sossin note that the Courts are loathe to exercise their discretionary power to review what are variously described as interim, interlocutory or preliminary decisions.
[31] The Federal Court in Black v. Canada (Attorney General) 2013 CarswellNat 3386 and our Court of Appeal in 689799 Alberta Ltd. v. Edmonton (City) 2018 ABCA 212 have used the term “interlocutory” to describe a decision that is not determinative of the substantive issue.
[32] The Supreme Court of Canada in Bell Canada v. Canadian Radio-Television and Telecommunications Commission 1989 CanLII 67 (SCC), [1989] 1 S.C.R. 1722 described a decision that does not affect the merits of the case as an interim order. That same term was used by the Court of Appeal in Syncrude Canada Ltd. Alberta (Human Rights and Citizenship Commission) 2008 ABCA 217 and in Encana Corporation v. Alberta (Energy & Utilities Board), 2004 CarswellAlta.
[33] In the context of a designated industrial property assessment, Justice Martin in Canadian Natural Resources Limited v. Wood Buffalo (Regional Municipality) 2011 ABQB 220 used the term “preliminary” decision.
[34] But regardless of the nomenclature, the result is the same.
[35] In Black, the Court refused to interfere with a decision by an adjudicative board in determining whether notice had been provided “forthwith”. Interestingly, there was no challenge to the issuance of the notice itself, only its timeliness.
[36] In 689799 Alberta Ltd. our Court of Appeal reviewed the case law and the underlying rationale of the rule. The first consideration is that the court typically gives deference to the administrative decision-maker. The second relates to efficiency, cost and the preservation of the administrative regime.
When considering the language in the Expropriation Act, which provides for an appeal to the Court of Appeal of “any determination or order”, the Court focused on the context in the legislation as “evinces the goal of expedience resolution” that “does not support a legislative intention to provide for multiple appeals.” The Court held that matters such as rulings on undertakings, disclosure of information, and production of financial information should be left to the Tribunal.
[37] In Syncrude, although the Court was dealing with what was clearly characterized as an “order”, the Court did not intervene.
The Act does not contemplate multiple appeals. The legislative scheme must be read to further the goal of speedy and inexpensive resolution of human rights complaints (Para 13)
[38] In Encana at para. 25 the Court ruled:
...appeals of interim decisions, particularly where the appeal will not resolve any final or significant issues, are generally to be discouraged. In addition to delay, there are many pragmatic reasons not to hear such appeals including added cost, waste of judicial resources and the need to discourage other premature applications. (Para 25)
[39] In the Wood Buffalo case, Justice Martin was very blunt: “The Alberta courts have adopted a strong policy against litigation in installments”. (Para 26)
[40] However, in each case, the Courts have recognized that there may be “rare and exceptional circumstances” which would justify a review.
[41] How does this direction from the Court assist this Panel in determining whether to permit a reconsideration? This Panel recognizes that this is not a request for judicial review, but as this is a discretionary remedy it would be inappropriate to disregard the logic of the superior courts.
[42] There is no doubt that the “decision” as to the sufficiency of evidence is an interim, interlocutory or preliminary decision. There is no doubt that the courts are, to use the words from Macaulay & Sprague, “generally reluctant” to interfere.
[43] Although there may be extenuating circumstances which would justify re-consideration, the Applicant in this case has provided no basis upon which this Panel could come to that conclusion. This Panel also concludes that pursuing multiple reviews on matters preliminary to the Tribunal’s final decision would not, in the words of Justice Sirrs and our Court of Appeal, be “pragmatic”,” “inexpensive” or “expeditious,” especially given that the option of reconsideration is a discretionary one.
In the alternative, have the basic requirements for reconsideration been met?
[44] If this Panel is mistaken that reconsideration of an interim or interlocutory decision is appropriate, has the Applicant established that the basic requirements for reconsideration have been met?
Reconsideration is a two-step process. An applicant must first establish the prerequisites for reconsideration on a balance of probabilities. (Canadian Natural Resources Limited v. Main 2020 ABSRB 735) Rule 37(3) provides as follows:
The Board [Tribunal] may only decide to review a decision or order if one of the following requirements for review are met:
(a) the decision or order shows an obvious and important error of law or jurisdiction; or
(b) the decision or order shows an important error of fact, or an error of mixed fact and law, in the decision or order that affects the decision or order; or
(c) the decision or order was based on a process that was obviously unfair or unjust;
(d) the decision or order is inconsistent with an earlier Board decision or order, binding judicial authority, or provision of the legislation, regulation or rules; or
(e) there was evidence at the time of the hearing that was not presented because it was unavailable to the party asking for review, and which is likely to make a substantial difference to the outcome of the decision or order.
[45] EMBER suggests that in issuing the Notice, the Tribunal:
• has not provided notice prior to the Notice;
• has not made findings of fact upon which the Notice is based;
• has fettered its discretion in “routinely” issuing Notices;
• has improperly delegated its authority to staff, and
• that no reasons have been provided.
[46] The fundamental problem with these arguments is that the statute prescribes the process to be followed and the Notice itself answers the issues that EMBER has raised.
Section 36(3) provides as follows:
Where any money payable by an operator under a compensation order or surface lease has not been paid and the due date for its payment has passed, the person entitled to receive the money may submit to the Tribunal written evidence of the non-payment.
On receiving the evidence, if the Tribunal considers that it satisfactorily proves the non-payment, the Tribunal shall send a written notice to the operator demanding full payment.
There is no requirement for notice prior to the “notice.”
Furthermore, the Notice itself explains the rationale as to why the Notice was issued:
The Tribunal has received a completed application for unpaid compensation due under section 36 of the Act. You are receiving this demand because you have been identified as a Licensee or Working Interest Participant as per the Alberta Energy Regulator Well Summary Report and therefore an operator under section 36(1) of the Act. Operators are responsible for making payments under a surface lease or compensation order. ...
The Tribunal has prepared a Hearing Document Package for this application. You can obtain a copy of the Hearing Document Package (HDP) through the Surface Rights E-file Portal or by contacting Tribunal Administration...
[Emphasis in the original]
[47] The suggestion that there is a mistake of fact in the application is offensive. The “mistake” in requested compensation is based on an attempt by EMBER to reduce the rate of annual compensation without the Landowner’s consent. The Applicants, to their own prejudice, have claimed less than the full lease amount of $4,100 because EMBER has made a partial payment. For EMBER to now suggest that the application should be dismissed with costs is untenable.
[48] Accordingly, this Panel dismisses the application for reconsideration.
ISSUES AS TO THE MERITS
1. Who is an Operator for the purpose of section 36 of the Act?
2. Is there money past due and unpaid by the Operator to the Applicants under a Right of Entry Instrument?
3. Should the Tribunal direct the Minister to pay the Applicants any of the money past due under section 36 of the Act?
4. Should the Tribunal suspend and terminate the Operator’s rights?
DECISION ON THE MERITS
1. For the purposes of section 36 of the Act, the Operator is Ember Resources Inc.
2. The written evidence proves compensation in the amount of $1,934.00 is payable to the Applicants by the Operator.
3. Without further notice, the Tribunal directs the Minister to pay the Applicants the Compensation in the amount of $1,934.00 from the General Revenue Fund.
4. The decision to suspend or terminate the Operator’s rights is reserved.
ANALYSIS
Who is an operator for the purpose of section 36 of the Act?
[49] Section 36(1) and (2) expands the definition of “operator” so that it has a broader meaning than in the rest of the Act.
Under section 36(1)(c), the holder of a licence issued by the AER and its successors are Operators. The Licence for the Site has been in the name of EMBER since November 15, 2013. Therefore, the Panel finds this party is an Operator under section 36(1)(c) for 2021. EMBER admits that it is the Licensee.
Under s. 36(1)(d), working interest participants and successors are Operators. The Panel finds that EMBER is an Operator under section 36(1)(d) for 2021 because the AER Well Summary Report dated September 20, 2024 shows that it was the 100% working interest participant on the Site as of November 15, 2013.
[50] The Tribunal gave notice to EMBER pursuant to s. 36(4). This Panel is satisfied that the demand for payment and notice meets the requirements of the Act pursuant to s. 36(4) and the Interpretation of Section 36(4) Surface Rights Act Guideline, ABSRB 2020-1.
Is there money past due and unpaid by the Operators to the Applicants under a Right-of-Entry Instrument?
[51] The Certificate of Title confirms that the Applicants are the owners. Therefore, the Panel finds that they are the persons entitled to receive the money. David Sengaus has provided evidence of a Right-of-Entry Instrument, and the compensation is supported by the Application and supporting documentation. The Applicants have declared in writing that the full Compensation has not been paid for 2021 but that $2,166.00 “is being paid.”
The Panel is satisfied that compensation is owed to the Applicants for annual payment due under the Right-of-Entry Instrument in 2021. This amount is calculated as one payment of $4,100.00 minus the $2,166.00 that EMBER has reportedly paid, for a shortfall of $1,934.00. The Site is not reclaimed, and the Right-of-Entry Instrument remains in effect. The Panel finds that at the time the Compensation became due, the Operator was liable for the Compensation due to the Applicants.
Should the Tribunal direct the Minister to pay the Applicant any of the money past due from the General Revenue Fund under section 36 of the Act?
[52] The November 2023 decision of the Court of King’s Bench in Bateman v Alberta (Surface Rights Board), 2023 ABKB 640 has dramatically changed the state of the law with respect to the discretion of the Tribunal under section 36(4) of the Act. Justice Carruthers held that applicants need only prove there is a Right of Entry Instrument and a default on the payment and that absent exceptional circumstances, the Minister should be directed to pay the full amount owing.
This applicant pre-dates the Bateman decision. However, the status of the well was “Issued” as recently as September 20, 2024. On a pre-Bateman analysis there would be no reason to reduce the amount that the Minister is directed to pay. Therefore, the Panel directs the Minister to pay the full amount owing of $1,934.00 from the General Revenue Fund.
Should the Tribunal suspend and terminate the Operator’s rights?
[53] The Tribunal can suspend and terminate an operator’s rights to access the Site when appropriate. While EMBER is an active company and the status of the well is “Issued”, this is a matter that dates back to 2021. To avoid a further delay, this Panel will reserve its decision to suspend and terminate EMBER’s access rights.
Dated at the City of Edmonton, in the Province of Alberta this 14th day of November, 2024.
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LAND AND PROPERTY RIGHTS TRIBUNAL |
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Romeo Rojas, Member Authorized to sign for Susan McRory, Chair (s. 14 of the Land and Property Rights Tribunal Act)
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