Alberta Energy Regulator Announces New Editions of Directive 071 and Manual 026

Building on our previous blog regarding the AERH2S model, this update addresses the new editions of Alberta Energy Regulator (AER) Directive 071: Emergency Preparedness and Response and the associated Manual 026: Emergency Preparedness and Response Guide, which were announced by the AER on December 1, 2025 through Bulletin 2025-39. This announcement followed the AER's November 4, 2025 release of its new AERH2S model for calculating emergency planning zones (EPZs) under Directive 071. 

Now, the AER has turned to revising its requirements for how approval holders must plan for and respond to emergencies. The AER also intends to offer training and information sessions to support the implementation of the new Directive 071 and Manual 026, which come into effect on February 2, 2026.

Background and Stakeholder Consultation

Directive 071 establishes emergency preparedness and response requirements for AER approval holders, including requirements specific to EPZs, while Manual 026 provides detailed guidance to support compliance with the Directive 071 requirements.

In July of 2024, the AER released updated drafts of Directive 071 and Manual 026 and invited approximately four months of public consultation on the proposed changes. Bulletin 2025-39 notes that the new editions incorporate comments received through this process which, among other things, asked the AER to expand the scope of Directive 071 and provide clarity on a number of terms used therein. According to the AER, the new editions reflect the AER's expanded mandate, which now includes geothermal, minerals and carbon capture, utilization and storage.

Overview of Key Changes

The scope of Directive 071 has been expanded significantly. Historically, Directive 071 applied to activities under the Oil and Gas Conservation Act, Pipeline Act, Oil Sands Conservation Act and Geothermal Resource Development Act. The updated Directive 071 now captures AER-regulated operations under the Coal Conservation Act and Mineral Resources Development Act. The application of Directive 071 is also no longer limited to active operations and now includes all operations, regardless of life cycle phase.

Directive 071 now incorporates several elements from CSA Z246.2: Emergency Preparedness and Response for Petroleum and Natural Gas Industry Systems (CSA Z246.2). While the previous version of Directive 071 stated that the use of CSA Z246.2 alongside Directive 071 was recommended when developing emergency preparedness and response programs, certain provisions of CSA Z246.2 are now embedded directly in Directive 071 and will become mandatory for approval holders. This update aligns Directive 071 with what are considered the best practices for modern emergency management in Canada.

Another significant change is the requirement for all AER approval holders, formerly referred to as duty holders, to maintain a comprehensive Emergency Management Program (EMP). The previous Directive 071 emergency preparedness framework was centered on the Emergency Response Plan (ERP) and the need for adequate plans, personnel and equipment to respond effectively to incidents. The new Directive 071 introduces a mandatory EMP for all approval holders, with the ERP now serving as just one component of this broader program. The new EMP framework also imposes senior management sign-off requirements and continuous improvement obligations, and also requires approval holders to use a unified Incident Command System (ICS). Previously, Directive 071 strongly encouraged ICS use within ERPs, but it was not mandatory.

With respect to ERPs, the AER has introduced a new terminology: "AER-approved" ERPs are now referred to as "operation-specific" ERPs, while the corporate ERP maintains its previous name. Corporate ERPs still do not require AER approval, but remain subject to AER review and audit. Under the new Directive 071, approval holders are required to submit their corporate ERP via the designated information submission system. This submission requirement applies to approval holders with operations starting after February 2, 2026, as well as approval holders with existing operations (in which case the submission must be made by the time of the next scheduled 12-month update unless otherwise permitted in writing by the AER).

The new Directive 071 also raises the technical standard for hazard identification and consequence analysis. These assessments must now be performed by a competent and qualified individual and, in higher-risk situations, such as operations involving potentially catastrophic consequences or involving H2S or HVP products requiring EPZ calculations, the analysis must be certified by a licensed professional or an APEGA permit holder. Operators must identify all defined emergency scenarios and provide evidence of this licensed professional certification through the new "Professional Declaration for Hazard Identification and Consequence Analysis" form.

In the context of hazard identification and consequence analyses, the AER now requires approval holders to consider both worst-case and worst-credible scenarios, representing a more detailed and variable assessment methodology that captures a wider range of potential emergency consequences. The AER has also revised the incident classification matrix to incorporate broader language reflecting the AER's expanded regulatory mandate across multiple resource sectors. The updated consequence examples introduce a subtle, but important shift: more severe consequences now appear in lower-ranked incident categories, increasing the sensitivity of incident classification and promoting more conservative escalation practices.

What This Means for AER Approval Holders

As the revised Directive 071 and Manual 026 move toward implementation, AER approval holders should consider the practical impacts of these changes on their operations. Below are several key operational implications for approval holders.

All operators, including those with smaller or lower-risk asset bases, must now adopt the ICS and maintain a fully compliant EMP. Although this introduces new regulatory obligations in many cases, the AER acknowledges that the level of detail required for each program or plan will vary based on the scale and complexity of a given operation, providing some flexibility in implementation.

The revised Directive 071 also places greater emphasis on licensed professionals and senior-level oversight. Hazard identification and consequence analyses that exceed certain risk thresholds must now be certified by a licensed professional, while annual performance reporting and senior leadership declarations raise internal governance expectations. Collectively, these requirements demand a more structured approach to emergency planning oversight and may result in added compliance costs.

While the AER has strengthened its ability to monitor, audit and enforce compliance, which may increase regulatory exposure for operators, the revised Directive 071 and Manual 026 now contain more clear and prescriptive requirements (with respect to ICS, for example). Also, incorporating requirements from CSA Z246.2 improves consistency in emergency management across the industry and aligns Alberta with other Canadian jurisdictions that already apply CSA Z246.2. Such alignment is particularly noteworthy for companies operating across multiple provinces.

The Energy Regulatory practice group at Bennett Jones has extensive experience advising operators on emergency preparedness, regulatory compliance and operational risk management. If you have questions about how the revised Directive 071 and Manual 026 may affect your operations, please contact the authors of this post.