Pre-Application Engagement for Oil & Gas Activities


Pre-Application Engagement for Oil & Gas Activities


An important action as a result of the January 2023 Blueberry River First Nations Implementation Agreement is now taking place.

The Implementation Agreement requires changes to consultation with Blueberry on oil and gas activities. It responds to a B.C. Supreme Court decision on June 29, 2021, that found the Province had infringed upon Blueberry’s Treaty 8 rights due to the cumulative impacts of decades of industrial development in its traditional territory.

The purpose of the Implementation Agreement is to develop a new approach to natural resource management and the protection of Treaty rights, with goals to enhance restoration to heal the land, create new protected areas and set new rules for development activities. The Implementation Agreement and upcoming Watershed Management Basin and High Value area plans seek to establish a new balance between Treaty rights and healing of the environment with a sustainable regional economy.

Starting June 30, 2023, a new BRFN/BCER consultation process, which includes pre-application engagement with Blueberry, is needed to obtain Blueberry’s views on proposed development early in the planning phase, before the application is submitted to the BC Energy Regulator (BCER). This includes identifying acceptable locations for oil and gas activities, and the conditions under which new development in Blueberry’s claim area may occur.

New Engagement Process

Pre-application engagement meetings between proponents and Blueberry should be scheduled with the Blueberry Lands Department well before applications are prepared. Industry engagement with trapline holders is also part of the new process. Blueberry Lands Department will coordinate Trapline Holder engagement where required.

Proponents will be required to complete a Pre-engagement Record spreadsheet after their engagement meetings which reflects the content of these meetings, and to send a draft to Blueberry for approval.

Following this, proponents will need to complete a BCER BRFN Implementation Agreement Form, outlining important information about their application, including steps taken to minimize and consolidate new disturbance and ensure compliance with new plans that will establish areas for protection. This new Form, along with the new BRFN/BCER consultation process, aims to create an efficient and easy-to-use system, which condenses large amounts of information into easily reviewable formats without compromising meaningful engagement  and in-depth understanding of all proposed activities.

Proponents will then be able to submit their development application to BCER, including their completed BCER BRFN Implementation Agreement Form, in addition to any supporting documents or other application materials required by BCER.

Important Note

Pre-application engagement that discusses proponents’ development plans as a whole fulfils proponent’s engagement requirements, provided the specific location and impacts of the subject application are discussed with Blueberry. Individual meetings on each component of an applied for activity or project are not required when a meeting to discuss the project as a whole occurs (i.e. a single pre-application engagement process can discuss a facility and associated well pads, roads and other infrastructure, and as such individual meetings on each project component are not required). The Blueberry Lands Department does not require pre-application engagement to occur on an application-by-application basis, but expects to see proponents identify all project and activity components requiring authorization, whether they are part of a subject application or not. When in doubt, ask the Blueberry Lands Department whether further engagement is required.

Pre-Application Engagement Steps

  1. Before getting started, read the BCER BRFN Guidance Document  for the BCER BRFN Implementation Agreement Form.
  2. Arrange a pre-application engagement meeting with the Blueberry Lands Department.
    • To arrange a meeting, please email
    • Blueberry recommends attaching relevant documents, including .kmz files for development plans, when requesting a meeting.
  3. Meet with the Blueberry Lands Department, have follow-up discussions and share additional information as needed.
  4. Incorporate the outcomes of those discussions into your Pre-engagement Record spreadsheet and send a draft to Blueberry’s Lands Department for review and comment.
  5. Incorporate any final comments, objections or concerns from Blueberry into the final Pre-engagement Record prior to submission to Blueberry.
  6. After pre-application engagement meetings between proponents and Blueberry, proponents will then need to fill out a BCER BRFN Implementation Agreement Form, in addition to any other application documents required by BCER.
  7. Proponents can now send their whole application to BCER.

      Important notes for all proponents and industry partners

      • Please allow 30 business days for a reply from the Blueberry Lands Department. If you have not heard from someone in 30 days, please follow up via email at
      • Please do not reach out to Blueberry’s reception, Chief & Council or any other staff or members to follow up.

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