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Subject: Draft Revised UNFC-2008 and Draft Accompanying Explanatory Note From: Energy Resources Conservation Board of Alberta, Canada

6 February 2009

Alberta's Energy Resources Conservation Board (formerly the Energy and Utilities Board - EUB) recognizes that the revised UNFC is a simplification of the current standard. The ERCB supports this change as, in previous comments (through other participants), the ERCB had suggested such a simplification as a way of enhancing the usability of the framework. Previously the ERCB had voiced a concern that it was not obvious how an unconventional petroleum resource, early in its development history, could be adequately classified. In such cases the extent of the resource is generally well known (usually able to meet advanced geological criteria) but development is generally targeting only the best of a vast resource. As a result the ERCB suggested that enhancing the classification of in place quantities could strengthen the UNFC. The proposed revision does not, in our view, add much to assist a resource manager, such as the ERCB, in this area. We would support efforts to add greater subdivision or delineation to, for example, those quantities that exist in the ground, those that are unrecoverable because of a technical or socio-economic reason, those that will be left behind (and may or may not be recoverable in the future), and those that exist between observation points, which depending on the scale of review, may be considered discovered. The ERCB is cognizant of the work that has gone in to the creation and revision of the UNFC and thanks the participants for their effort.

Richard Marsh, P.Geol.
Energy Resources Conservation Board of Alberta