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Surge Energy Inc

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FY2020 Annual Report · Surge Energy Inc
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________ 

Annual Information Form 

For the Year Ended December 31, 2020 
Dated March 9, 2021 

 
 
 
 
 
 
Table of Contents 

Select Definitions .......................................................................................................................................... 3 
Abbreviations and Conversion ...................................................................................................................... 4 
Non-IFRS Measures ..................................................................................................................................... 5 
Notes on Reserves Data and Other Oil and Natural Gas Information .......................................................... 5 
Special Note Regarding Forward Looking Statements ................................................................................. 8 
Surge Energy Inc. ....................................................................................................................................... 11 
Development of the Business ..................................................................................................................... 11 
Description of the Business......................................................................................................................... 12 
Principal Producing Properties .................................................................................................................... 15 
Statement of Reserves Data ....................................................................................................................... 17 
Description of Capital Structure .................................................................................................................. 27 
Dividend Policy ............................................................................................................................................ 29 
Market for Securities ................................................................................................................................... 30 
Directors and Officers ................................................................................................................................. 31 
Audit Committee .......................................................................................................................................... 36 
Industry Conditions ..................................................................................................................................... 38 
Risk Factors ................................................................................................................................................ 59 
Legal Proceedings And Regulatory Actions ................................................................................................ 73 
Interest of Management and Others in Material Transactions .................................................................... 74 
Auditor, Transfer Agent and Registrar ........................................................................................................ 74 
Interest of Experts ....................................................................................................................................... 74 
Additional Information ................................................................................................................................. 74 

Schedule “A” –  Form 51-101F2  
Schedule “B”  –  Form 51-101F3  
Schedule “C”  –  Audit Committee Charter  

 
 
 
 
SELECT DEFINITIONS 

Unless the context indicates otherwise, the following terms shall have the meanings set out below when 
used in this Annual Information Form.  Certain other terms and abbreviations used herein, but not defined 
herein, are defined in NI 51-101 or the COGE Handbook and, unless the context otherwise requires, shall 
have the same meanings herein as in NI 51-101 or the COGE Handbook.  

“ABCA” means the Business Corporations Act, R.S.A. 2000, c. B-9, as amended; 

“AIF” or “Annual Information Form” means this annual information form; 

“Audit Committee” means the audit committee of the Board; 

“Board of Directors” or “Board” means the board of directors of the Corporation; 

“COGE Handbook” means the “Canadian Oil and Gas Evaluation Handbook” maintained by the Society of 
Petroleum Evaluation Engineers (Calgary Chapter), as amended from time to time; 

“Common Shares” means the common shares of the Corporation; 

“Corporation” or “Surge” means Surge Energy Inc., a corporation amalgamated under the ABCA; 

“Credit Facilities” means,  collectively, (i)  the  $335  million  extendible  revolving term credit facility  of  the 
Corporation with a banking syndicate led by National Bank of Canada, as amended from time to time; and 
(ii) the $40 million four year term, non-revolving facility of the Corporation with a banking syndicate led by 
National Bank of Canada; 

“Debentures” means, collectively, the Initial Debentures and the Series 2 Debentures, as more particularly 
described under the heading “Description of Capital Structure”; 

“IFRS”  means  International  Financial  Reporting  Standards,  as  issued  by  the  International  Accounting 
Standards Board, as amended from time to time; 

“Indenture” means the debenture indenture dated May 8, 2019 between Surge and Computershare Trust 
Company of Canada, as amended on November 15, 2017 and as supplemented by a first supplemental 
debenture indenture dated May 8, 2019, under which the Debentures are issued;   

“Initial Debentures” means the 5.75% convertible unsecured subordinated debentures due on December 
31, 2022; 

“NI 51-101” means National Instrument 51-101 - Standards of Disclosure for Oil and Gas Activities; 

“Reserves Report” means the independent engineering report with a preparation date of March 3, 2021 
and effective December 31, 2020 prepared by and containing the evaluation of Sproule of the oil, NGL and 
natural gas reserves attributable to the properties of the Corporation; 

“Series 2 Debentures” means the 6.75% convertible unsecured subordinated debentures due on June 30, 
2024; 

“Sproule” means Sproule Associates Limited, independent oil and gas reservoir engineers; 

“TSX” means the Toronto Stock Exchange; and  

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“U.S.” or “United States” means the United States of America. 

Words  importing  the  singular  number  only  include  the  plural,  and  vice  versa,  and  words  importing  any 
gender include all genders. All dollar amounts set forth in this Annual Information Form, including “dollar”, 
“$” and “CAD$” are in Canadian dollars, except where otherwise indicated.  “US$” means United States 
dollars. 

In this Annual Information Form, the abbreviations set forth below have the following meanings: 

ABBREVIATIONS AND CONVERSION 

Oil and Natural Gas Liquids 

Natural Gas 

bbl 
bbls 
Mbbls 
MMbbls 
Mstb 
bbl/d 
NGLs 
stb 

Barrel 
Barrels 
thousand barrels 
million barrels 
1,000 stock tank barrels 
barrels per day 
natural gas liquids 
stock tank barrel 

Mcf 
MMcf 
Mcf/d 
MMcf/d 
MMbtu 
Bcf 
GJ 

thousand cubic feet 
million cubic feet 
thousand cubic feet per day 
million cubic feet per day 
million British Thermal Units 
billion cubic feet 
gigajoule 

The following table sets forth certain standard conversions from Standard Imperial Units to the International 
System of Units (or metric units). 

To Convert From 

To 

Multiply By 

Mcf 
Cubic metres 
Bbls 
Cubic metres  
Feet  
Metres  
Miles  
Kilometres  
Acres  
Hectares  
Gigajoules  
MMbtu  

Cubic metres 
Cubic feet 
Cubic metres 
Bbls  
Metres 
Feet  
Kilometres  
Miles  
Hectares  
Acres  
MMbtu  
Gigajoules  

28.174 
35.494 
0.159 
6.293 
0.305 
3.281 
1.609 
0.621 
0.405 
2.50  
0.950 
1.0526 

Other 

AECO   
API 
°API 

a natural gas storage facility located at Suffield, Alberta 
American Petroleum Institute 
an indication of the specific gravity of crude oil measured on the API gravity scale. Liquid 
petroleum with a specified gravity of 35.1° API or greater is generally referred to as light 
crude oil. Liquid petroleum with a specified gravity of 25.8° to 35° API or greater is generally 
referred to as medium crude oil. Liquid petroleum with a specified gravity of 25.7° API or 
lower is generally referred to as heavy crude oil. 

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boe 

boe/d 
m3 
Mboe 
MMboe  
$000s 
M$ or $M 
MM$ 
WTI 

barrel  of  oil  equivalent  on  the  basis  of  1  boe  to  6  Mcf  of  natural  gas.  Boes  may  be 
misleading,  particularly  if  used  in  isolation.  A  boe  conversion  ratio  of  1  boe  for  6  Mcf  is 
based on an energy equivalency conversion method primarily applicable at the burner tip 
and does not represent a value equivalency at the wellhead  
barrel of oil equivalent per day 
cubic metres 
1,000 barrels of oil equivalent 
1,000,000 barrels of oil equivalent 
thousands of dollars 
thousands of dollars 
millions of dollars 
West Texas Intermediate, the reference price paid in U.S. dollars at Cushing, Oklahoma 
for crude oil of standard grade 

NON-IFRS MEASURES 

This  AIF  contains  the  term  “operating  netback”  which  is  not  defined  by  IFRS  and  therefore  may  not  be 
comparable to performance measures presented by others.  In this AIF, “operating netback” is calculated 
by  deducting  royalties  paid  and  production  costs,  including  transportation  costs,  from  prices  received, 
excluding the effects of hedging.  Management believes that in addition to net income, operating netbacks 
are  a  useful  supplemental  measure  as  it  assists  in  the  determination  of  the  Corporation’s  operating 
performance.  Readers should be cautioned, however, that this measure should not be construed as an 
alternative to both  net income  and  net cash  from (used in) operating  activities, which are  determined  in 
accordance with IFRS, as indicators of the Corporation’s performance. 

NOTES ON RESERVES DATA AND OTHER OIL AND NATURAL GAS INFORMATION 

Caution Respecting Reserves Information 

The  determination  of  oil  and  natural  gas  reserves  involves  the  preparation  of  estimates  that  have  an 
inherent  degree  of  associated  uncertainty.  Categories  of  proved  and  probable  reserves  have  been 
established  to  reflect  the  level  of  these  uncertainties  and  to  provide  an  indication  of  the  probability  of 
recovery.  The estimation and classification of reserves requires the application of professional judgment 
combined  with  geological  and  engineering  knowledge  to  assess  whether  or  not  specific  reserves 
classification criteria have been satisfied. Knowledge of concepts including uncertainty and risk, probability 
and statistics, and deterministic and probabilistic estimation methods is required to properly use and apply 
reserves definitions.  The estimates of reserves and future net revenue for individual properties may not 
reflect the same confidence level as estimates of reserves and future net revenue for all properties, due to 
the effects of aggregation. 

The  recovery  and  reserve  estimates  of  oil,  NGL  and  natural  gas  reserves  provided  herein  are 
estimates only.   Actual reserves may be greater than or less than the estimates provided herein. 
The  estimated  future  net  revenue  from  the  production  of  the  Corporation’s  natural  gas  and 
petroleum reserves does not represent the fair market value of the Corporation’s reserves. 

Caution Respecting Boe 

In this AIF, the abbreviation boe means barrel of oil equivalent on the basis of 1 boe to 6 Mcf of natural gas 
when converting natural gas to boes.  Boes may be misleading, particularly if used in isolation. A boe 
conversion ratio of 6 Mcf to 1 boe is based on an energy equivalency conversion method primarily 
applicable at the burner tip and does not represent a value equivalency at the wellhead. 

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Definitions 

Certain terms used in this AIF in describing reserves and other oil and natural gas information are defined 
below. Certain other terms and abbreviations used in this AIF, but not defined or described, are defined in 
NI 51-101  or  the  COGE  Handbook  and,  unless  the  context  otherwise  requires,  shall  have  the  same 
meanings herein as in NI 51-101 or the COGE Handbook. 

Reserves  

Reserves are estimated remaining quantities of oil and natural gas and related substances anticipated to 
be  recoverable  from known  accumulations,  from  a  given  date  forward,  based  on:  (i)  analysis  of  drilling, 
geological,  geophysical  and  engineering  data;  (ii)  the  use  of  established  technology;  and  (iii)  specified 
economic conditions, which are generally accepted as being reasonable and shall be disclosed.  Reserves 
are classified according to the degree of certainty associated with the estimates as follows: 

“proved  reserves”  are  those  reserves  that  can  be  estimated  with  a  high  degree  of  certainty  to  be 
recoverable.  It  is  likely  that  the  actual  remaining  quantities  recovered  will  exceed  the  estimated  proved 
reserves. 

“probable  reserves”  are  those  additional  reserves  that  are  less  certain  to  be  recovered  than  proved 
reserves. It is equally likely that the actual remaining quantities recovered will be greater or less than the 
sum of the estimated proved plus probable reserves. 

The  qualitative  certainty  levels  referred  to  in  the  definitions  above  are  applicable  to  “individual  reserves 
entities” (which refers to the lowest level at  which reserves calculations are performed) and to “reported 
reserves” (which refers to the highest-level sum of individual entity estimates for which reserves estimates 
are  presented).  Reported  reserves  should  target  the  following  levels  of  certainty  under  a  specific  set  of 
economic conditions: 

  at  least  a  90  percent  probability  that  the  quantities  actually  recovered  will  equal  or  exceed  the 

estimated proved reserves; and 

  at least a 50 percent probability that the quantities actually recovered will equal or exceed the sum 

of the estimated proved plus probable reserves. 

Each of the reserves categories (proved and probable) may be divided into developed and undeveloped 
categories as follows: 

“developed  reserves”  are  those  reserves  that  are  expected  to  be  recovered  from  existing  wells  and 
installed facilities or, if facilities have not been installed, that would involve a low expenditure (e.g., when 
compared to the cost of drilling a well) to put the reserves on production. The developed category may be 
subdivided into producing and non-producing as follows: 

“developed producing reserves” are those reserves that are expected to be recovered from completion 
intervals open at the time of the estimate. These reserves may be currently producing or, if shut-in, they 
must have previously been on production, and the date of resumption of production must be known with 
reasonable certainty. 

“developed non-producing reserves” are those reserves that either have not been on production, or have 
previously been on production but are shut-in and the date of resumption of production is unknown. 

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“undeveloped reserves” are those reserves expected to be recovered from known accumulations where 
a  significant  expenditure  (e.g.,  when  compared  to  the  cost  of  drilling  a  well)  is  required  to  render  them 
capable  of  production.  They  must  fully  meet  the  requirements  of  the  reserves  classification  (proved, 
probable, possible) to which they are assigned. 

In  multi-well  pools,  it  may  be  appropriate  to  allocate  total  pool  reserves  between  the  developed  and 
undeveloped categories or to sub-divide the developed reserves for the pool between developed producing 
and developed non-producing. This allocation should be based on the estimator’s assessment as to the 
reserves that will be recovered from specific wells, facilities and completion intervals in the pool and their 
respective development and production status. 

Interests in Reserves, Production, Wells and Properties 

“gross” means: (i) in relation to an issuer’s interest in production or reserves, its “company gross reserves”, 
which are its working interest (operating or non-operating) share before deduction of royalties and without 
including any royalty interests of the issuer; (ii) in relation to wells, the total number of wells in which an 
issuer has an interest; and (iii) in relation to properties, the total area of properties in which an issuer has 
an interest. 

“net” means: (i) in relation to an issuer’s interest in production or reserves its working interest (operating or 
non-operating)  share  after  deduction  of  royalty  obligations,  plus  its  royalty  interests  in  production  or 
reserves; (ii) in relation  to  an issuer’s interest  in  wells, the number of wells obtained by aggregating the 
issuer’s working interest in each of its gross wells; and (iii) in relation to an issuer’s interest in a property, 
the total area in which the issuer has an interest multiplied by the working interest owned by the issuer. 

“working interest” means the percentage of undivided interest held by an issuer in the oil and/or natural 
gas or mineral lease granted by the mineral owner, Crown or freehold, which interest gives the issuer the 
right to “work” the property (lease) to explore for, develop, produce and market the leased substances. 

Description of Exploration and Development Wells and Costs 

“development  costs”  means  costs  incurred  to  obtain  access  to  reserves  and  to  provide  facilities  for 
extracting, treating, gathering and storing the crude oil and natural gas from the reserves. More specifically, 
development costs, including applicable operating costs of support equipment and facilities and other costs 
of development activities,  are costs incurred to: (i) gain access to and prepare well locations for drilling, 
including surveying well locations for the purpose of determining specific development drilling sites, clearing 
ground,  draining,  road  building,  and  relocating  public  roads,  gas  lines  and  power  lines,  to  the  extent 
necessary in developing the reserves; (ii) drill, complete and equip development wells, development type 
stratigraphic test wells and service wells, including the costs of platforms and of well equipment such as 
casing, tubing, pumping equipment and wellhead assembly; (iii) acquire, construct and install production 
facilities  such  as  flow  lines,  separators,  treaters,  heaters,  manifolds,  measuring  devices  and  production 
storage tanks, natural gas cycling and processing plants, and central utility and waste disposal systems; 
and (iv) provide improved recovery systems. 

“development well” means a well drilled inside the established limits of an oil or gas reservoir, or in close 
proximity to the edge of the reservoir, to the depth of a stratigraphic horizon known to be productive. 

“exploration  costs”  means  costs  incurred  in  identifying  areas  that  may  warrant  examination  and  in 
examining  specific  areas  that  are  considered  to  have  prospects  that  may  contain  oil  and  natural  gas 
reserves,  including  costs  of  drilling  exploratory  wells  and  exploratory  type  stratigraphic  test  wells. 
Exploration costs may be incurred both before acquiring the related property (sometimes referred to in part 
as  “prospecting  costs”)  and  after  acquiring  the  property.    Exploration  costs,  which  include  applicable 

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operating costs of support equipment and facilities and other costs of exploration activities, are: (i) costs of 
topographical, geochemical, geological and geophysical studies, rights of access to properties to conduct 
those studies,  and salaries and  other expenses of  geologists, geophysical crews and others conducting 
those  studies  (collectively  sometimes  referred  to  as  “geological  and  geophysical  costs”);  (ii)  costs  of 
carrying and retaining  unproved properties,  such as  delay  rentals, taxes  (other  than  income and  capital 
taxes) on properties, legal costs for title defence, and the maintenance of land and lease records; (iii) dry 
hole contributions and bottom hole contributions; (iv) costs of drilling, completing and equipping exploratory 
wells; and (v) costs of drilling exploratory type stratigraphic test wells. 

“exploration well” means a well that is not a development well, a service well or a stratigraphic test well. 

“service well” means a well drilled or completed for the purpose of supporting production in  an existing 
field. Wells in this class are drilled for the following specific purposes: gas injection (natural gas, propane, 
butane  or  flue  gas),  water  injection,  steam  injection,  air  injection,  salt  water  disposal,  water  supply  for 
injection, observation or injection for combustion. 

SPECIAL NOTE REGARDING FORWARD LOOKING STATEMENTS 

Certain  statements  or  disclosures  contained  in  this  Annual  Information  Form  constitute  forward-looking 
statements. The use of any of the words “anticipate”, “continue”, “estimate”, “expect”, “may”, “will”, “project”, 
“should”,  “believe”  and  similar  expressions  are  intended  to  identify  forward-looking  statements.  These 
statements involve known and unknown risks, uncertainties and other factors that may cause actual results 
or events to differ materially from those anticipated in such forward-looking statements.  The Corporation 
believes the expectations reflected in those forward-looking statements are reasonable, but no assurance 
can be given that these expectations will  prove to be correct. Since forward-looking statements address 
future  events  and  conditions,  by  their  very  nature  they  involve  inherent  risks  and  uncertainties.  Such 
forward-looking  statements  included  in  this  Annual  Information  Form  should  not  be  unduly  relied  upon. 
These statements speak only as of the date of this Annual Information Form. 

In  particular,  this  Annual  Information  Form  may  contain  forward-looking  statements  and  information 
pertaining to the following: 

the performance characteristics of the Corporation’s oil and natural gas properties; 

 
  oil and natural gas production levels, and expectations of future production rates, volumes and product 

 

mixes; 
the size of the oil and natural gas reserves of the Corporation and anticipated future cash flows from 
such reserves; 

  projections of market prices and costs, and exchange and inflation rates; 
  supply and demand for oil and natural gas; 
  expectations  regarding  the  ability  to  raise  capital  and  to  continually  add  to  reserves  through 

acquisitions and development; 
the Corporation’s dividend policy; 
treatment under governmental regulatory regimes and tax and royalty laws;  

 
 
  criteria and considerations in participations and acquisitions; 
 
 
  estimated abandonment and reclamation costs and the timing thereof; 
  expected land expiries and plans with respect thereto; 
  plans to implement enhanced recovery; and 
  capital expenditure programs, the allocation of such capital and the timing thereof. 

the Corporation’s tax horizon; 
timing of development of undeveloped reserves; 

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With respect to forward looking statements contained in this Annual Information Form, the Corporation has 
made assumptions regarding: 

the success of the Corporation’s operations and exploration and development activities; 
the size of Surge’s oil, natural gas and NGL reserves and the recoverability of its reserves; 

the availability of labour, services and drilling equipment; 
the availability of capital to fund planned expenditures; 
timing and amount of capital expenditures; 
timing of production curtailments; 
future operating costs and future cash flow; 
the Corporation’s future debt levels; 

  oil and natural gas production levels and the timing of new wells coming on-stream; 
 
 
  prevailing weather conditions, commodity prices and exchange rates; 
 
 
 
 
 
 
  general economic and financial market conditions; 
 
 
 
 
  government regulation in the areas of taxation, royalty rates and environmental protection. 

the Corporation’s ability to market production of oil and natural gas successfully to customers; 
the applicability of technologies for recovery and production of the Corporation’s reserves; 
the success, nature and timing of water flood activities; 
the ability of the Corporation to secure necessary capital, personnel, equipment and services; and 

The  actual  results,  performance  or  achievements  of  the  Corporation  may  differ  materially  from  those 
anticipated in these forward-looking statements as a result of the risk factors set forth below and elsewhere 
in this Annual Information Form: 

the impact of the COVID-19 pandemic; 

 
   whether the Corporation can continue as a going concern; 
   uncertainty surrounding the amount that will be available under the Credit Facilities in the future; 
   volatility in market prices for oil and natural gas; 
  volatility in exchange rates; 
 
  uncertainties associated with estimating oil and natural gas reserves and production levels; 
inability to secure labour, services or equipment on a timely basis or on favourable terms;  
 
 
failure to obtain industry partner or other third party consents and approvals, when required; 
  competition for, among other things, capital, acquisitions of reserves, undeveloped lands and skilled 

liabilities inherent in oil and natural gas operations; 

personnel; 
fluctuations in the cost of borrowing; 
the marketability of production and demand of Surge’s products; 
the inability to access sufficient capital from internal and external sources; 

 
 
 
  changes in general economic, market and business conditions; 
  unanticipated  operating  events  which  can  reduce  production  or  cause  production  to  be  shut  in  or 

delayed; 

  unfavourable weather conditions; 
 

incorrect  assessments  of  the  value  of  acquisitions,  dispositions  and  exploration  and  development 
programs; 

  geological, technical, drilling, completion and processing problems; 
  results of water flood responses; 
 

the outcome of litigation or regulatory proceedings brought against the Corporation or other disputes 
involving the Corporation; 

  changes in legislation, including changes in tax laws and incentive programs relating to the oil and 

gas industry;  

- 9 - 

 
  cyber-security issues; 
 
 

failure to realize the anticipated benefits of acquisitions and dispositions; and 
the other factors discussed under “Risk Factors”. 

Statements  relating  to  “reserves”  or  “resources”  are  deemed  to  be  forward-looking  statements,  as  they 
involve  the  implied  assessment,  based  on  certain  estimates  and  assumptions  that  the  resources  and 
reserves described can be profitably produced in the future.  

Readers are cautioned that the foregoing lists of factors are not exhaustive. The forward-looking 
statements  contained in  this  Annual Information  Form are  expressly qualified by  this cautionary 
statement.  The  Corporation  does  not  undertake  any  obligation  to  publicly  update  or  revise  any 
forward-looking statements other than as required under applicable securities laws. 

- 10 - 

 
 
 
Corporate Structure 

SURGE ENERGY INC. 

Surge was incorporated on January 26, 1998 under the ABCA as “Zapata Capital Inc.”  On June 18, 1999, 
the Corporation acquired all of the issued and outstanding shares of 744997 Alberta Ltd. and amalgamated 
with 744997 Alberta Ltd. under the name “Zapata Energy Corporation”.  On June 25, 2010, the Corporation 
changed its name to “Surge Energy Inc.” On December 31, 2010, the Corporation amalgamated with its 
wholly-owned subsidiary, Breaker Resources Ltd.  On December 31, 2012, the Corporation amalgamated 
with is wholly-owned subsidiary, Surge Oil Inc.  On December 31, 2013, the Corporation amalgamated with 
its wholly-owned subsidiaries, Flagstone Energy Inc. and 1779275 Alberta Ltd.  On December 31, 2014, 
the  Corporation  amalgamated  with  its  wholly-owned  subsidiary,  Longview  Oil  Corp.    On  December  31, 
2018, the Corporation amalgamated with its wholly-owned subsidiary, Mount Bastion Oil & Gas Corp. 

The head office of the Corporation is located at 2100, 635 – 8th Avenue S.W., Calgary, Alberta T2P 3M3.  
The registered office of the Corporation is located at Suite 4000, 421 – 7th Avenue S.W., Calgary, Alberta, 
T2P 4K9.  

Intercorporate Relationships 

The Corporation currently has one subsidiary, 1413942 Alberta Ltd., which is wholly-owned by Surge. On 
December 31, 2020, Surge acquired all of the partnership interest of Surge General Partnership held by 
1413942 Alberta Ltd. and the partnership was dissolved on such date.  

General 

DEVELOPMENT OF THE BUSINESS  

The  Corporation  is  an  independent,  Calgary,  Alberta-based  oil  and  gas  company  operating  primarily  in 
Alberta and Saskatchewan.  The Common Shares are listed on the TSX under the symbol “SGY” and the 
Initial  Debentures  and  Series  2  Debentures  are  listed  on  the  TSX  under  the  symbols  “SGY.DB”  and 
“SGY.DB.A”, respectively. 

Three Year History 

Significant developments of the Corporation over the last three completed financial years are as set forth 
below: 

Year ended December 31, 2018 

On January 4, 2018, Surge completed the sale of certain non-core assets in Central Alberta for proceeds 
of $6.7 million.   

On May 31, 2018, Surge completed an acquisition of crude oil producing assets in its core Sparky area of 
Central Alberta for a purchase price of $27.9 million.     

On July 18, 2018, Surge completed an acquisition of crude oil producing assets in its core Valhalla area of 
Northern Alberta for a purchase price of $6.2 million. 

On October 25, 2018, Surge closed its acquisition of Mount Bastion Oil & Gas Corp. (“Mount Bastion”) 
pursuant  to  an  arrangement  under  the  provisions  of  the  ABCA.    See  “Development  of  the  Business  – 
Significant Acquisitions”. 

- 11 - 

 
Year ended December 31, 2019 

On March 28, 2019, Surge completed the sale of certain non-core assets in Northwest Alberta for aggregate 
cash proceeds of $28.1 million. 

On  June  28,  2019,  Surge  disposed  of  a  1.7  percent  gross  overriding  royalty  on  total  revenue  from  the 
Corporation’s Southwest Saskatchewan, Southeast Alberta and North Central Alberta assets, for aggregate 
cash proceeds of $29.1 million. 

On August 13, 2019, Surge completed an acquisition of a gas processing facility in its core Sparky area of 
Southeast Alberta for a purchase price of $12.1 million. 

Year ended December 31, 2020 

On June 26, 2020, Surge completed the sale of certain non-core assets in Northwest Alberta for aggregate 
cash proceeds of $5.3 million. 

Events Subsequent to December 31, 2020 

Subsequent to December 31, 2020, the Corporation executed a binding purchase and sale agreement for 
the disposition of certain core assets in Northeast Alberta and Southeast Alberta for gross cash proceeds 
of $106 million, subject to standard closing adjustments. The sale is scheduled to close on or before March 
25, 2021. 

Significant Acquisitions 

Surge  did  not  complete  any  “significant  acquisitions”  (as  such  term  is  defined  in  NI  51-102)  during  the 
financial year ended December 31, 2020. 

Overview 

DESCRIPTION OF THE BUSINESS 

The Corporation is an oil and gas exploration, development and production company.  Surge holds focused 
and operated light and medium gravity crude oil properties in Alberta and Saskatchewan characterized by 
large oil in place crude oil reservoirs with low recovery factors.  The Corporation has a significant inventory 
of low risk development drilling locations, including several successful water flood projects. 

Corporate Strategy  

The Corporation focuses on assets with the following criteria:  large oil in place with low recovery factors; 
available infrastructure; high working interest; operatorship; all-season access and drilling inventory; water 
flood opportunities; and other upside that provides a definable high rate of return. 

Management believes in controlling the timing and costs of the Corporation’s projects wherever possible.  
Accordingly,  the  Corporation  seeks  to  become  the  operator  of  its  properties.    Further,  to  minimize 
competition within its geographic areas of interest, the Corporation strives to maximize its working interest 
ownership in its properties where reasonably possible. 

In  reviewing  potential  drilling  or  acquisition  opportunities,  the  Corporation  gives  consideration  to  the 
following criteria:  risk capital to  secure  or evaluate  the opportunity; the  potential  return  on the  project, if 
successful; the likelihood of success; and risked return versus cost of capital. 

- 12 - 

 
In general, the Corporation pursues a portfolio approach in developing a large number of opportunities with 
a balance of risk profiles in an attempt to generate sustainable levels of growth.  The Board of Directors of 
the Corporation may, in its discretion, approve asset or corporate acquisitions or investments that do not 
conform to the guidelines discussed above based upon the Board’s consideration of the qualitative aspects 
of the subject properties, including risk profile, technical upside, reserve life and asset quality. 

In addition, the management team of the Corporation, as described below under “Directors and Officers”, 
is  continually  assessing  the  assets  and  operations  of  the  Corporation,  including  its  existing  land  base, 
facilities, reserves, prospects and personnel.   

Competition 

The oil and natural gas industry is competitive in all its phases. The Corporation competes with numerous 
other participants in the search for, and the acquisition of, oil and natural gas properties and in the marketing 
of  oil  and  natural  gas.  The  Corporation’s  competitors  include  resource  companies  which  have  greater 
financial resources, staff and facilities than those of the Corporation.  Competitive factors in the distribution 
and marketing of oil and natural gas include price and methods and reliability of delivery.  The Corporation 
believes that its competitive position is equivalent to that of other oil and gas issuers of similar size and at 
a similar stage of development. 

Cyclical and Seasonal Nature of Industry 

Surge’s operational results and financial condition are dependent on the prices received for oil and natural 
gas  production.    Oil  and  natural  gas  prices  have  fluctuated  dramatically  during  recent  years  and  are 
determined by a number of factors, including global and local supply and demand factors, and including 
weather and general economic conditions, as well as conditions in other oil and natural gas producing and 
consuming  regions.    Surge  attempts  to  mitigate  such  price  risk  through  closely  monitoring  commodity 
markets and establishing disciplined hedging programs.   

The level of activity in the Canadian oil and natural gas industry is influenced by seasonal weather patterns.  
Wet weather and spring thaw may make the ground unstable.  Consequently, municipalities and provincial 
transportation  departments  enforce  road  bans  that  restrict  the  movement  of  rigs  and  other  heavy 
equipment, thereby reducing activity levels.  Also, certain oil and natural gas producing areas are located 
in  areas that are inaccessible  other  than during the  winter months because  the  ground  surrounding  the 
sites in these areas consists of swampy terrain.   

Seasonal  factors  and  unexpected  weather  patterns  may  lead  to  declines  in  exploration  and  production 
activity and corresponding declines in the demand for the goods and services of the Corporation.  Demand 
for natural gas typically rises during cold winter months and hot summer months. 

Environmental Regulation 

The oil and natural gas industry is subject to environmental regulations pursuant to a variety of provincial 
and federal legislation.  Compliance  with such legislation can require significant  expenditures or result in 
operational restrictions. Breach of such requirements may result in suspension or revocation of necessary 
licenses  and  authorizations,  civil  liability  for  pollution  damage  and  the  imposition  of  material  fines  and 
penalties, all of which might have a significant negative impact on earnings and overall competitiveness. 
See  below  under  the  headings  “Industry  Conditions  -  Environmental  Regulation”  and  “Risk  Factors  – 
Environmental Concerns”. 

The  Corporation  is  obligated  to  abandon,  retire  and  reclaim  wells  and  well  sites  in  compliance  with 
applicable environmental laws and regulations.  As of December 31, 2020, the Corporation has recorded 

- 13 - 

 
an  asset  retirement  obligation  of  $294.7  million.  The  Corporation  anticipates  that  the  expenditures 
necessary to satisfy the asset retirement obligation will be incurred over a period of twenty years, with the 
majority  of  the  expenditures  being  incurred  from  years  2021  to  2041.    Other  than  asset  retirement 
obligations and ordinary course operational expenditures necessary to ensure environmental compliance, 
the  Corporation  is  not  aware  of  any  environmental  protection  requirement  that  will  impact  its  capital 
expenditures, earnings or competitive position in a manner disproportionate to that of its peers in its area 
of operations.   

Marketing  

Surge’s crude oil and natural gas  production  are  sold primarily  through marketing  companies  at  current 
market prices.  See also “Interest of Management and Others in Material Transactions”. 

The Corporation also has a hedging policy as described under “Statement of Reserves Data – Other Oil 
and Gas Information – Forward Contracts”. For details of the Corporation’s forward contracts in place as at 
December  31,  2020,  see  the  Corporation’s  audited  annual  financial  statements  for  the  year  ended 
December 31, 2020, which have been filed on SEDAR and may be viewed under the Corporation’s profile 
at www.sedar.com.  See “Risk Factors – Fixed Price Hedging”. 

Personnel 

As at December 31, 2020, the Corporation had 65 head office employees and 6 field employees.   

Health, Safety and Environmental  

Management,  employees and  contractors are  responsible and  accountable for the overall health,  safety 
and environmental program.  Surge operates in compliance with all applicable regulations and ensures that 
all  staff and contractors employ sound practices to protect the environment and to ensure employee and 
public health  and safety.  

Surge maintains a safe and environmentally responsible work place and provides training, equipment and  
procedures to all individuals in adhering to its policies.  It also solicits and takes into consideration input 
from neighbors, communities and other stakeholders in regard to protecting people and the environment. 

In 2020 Surge continued its commitment to environmental, social and governance spending initiatives by 
spending an aggregate of $9.3 million on abandonment activities. 

- 14 - 

 
 
 
PRINCIPAL PRODUCING PROPERTIES 

The  Corporation’s  principal  oil  and  natural  gas  producing  properties  are  located  in  Alberta  and 
Saskatchewan and are focused across five core areas: Greater Sawn, Valhalla, Sparky, Shaunavon and 
Minors.  A description of those properties, as at December 31, 2020, is provided below.   

See “Development of the Business – Three Year History – Events Subsequent to December 31, 2020” 

Greater Sawn 

As at December 31, 2020, the Corporation’s principal properties in the Greater Sawn area included Sawn 
Lake, Otter, Red Earth (which collectively comprise the Greater Sawn Lake assets), Nipisi and Nevis.  At 
Greater  Sawn,  Surge  held  an  average  working  interest  of  approximately  83  percent  in  approximately 
131,928 gross (109,941 net) developed acres and an average working interest of approximately 92 percent 
in  approximately  164,798  gross  (152,344  net)  undeveloped  acres.    As  at  December  31,  2020,  the 
Corporation held interests in 380 gross (316 net) oil wells and 19 gross (13 net) gas wells producing from 
formations  including,  but  not  limited  to,  Slave  Point,  Granite  Wash,  Gilwood,  Wabamun  and  Banff.    In 
addition,  the  Corporation  operates  multiple  oil  batteries  providing  a  strong  infrastructure  base  for  future 
development in the area.  Surge’s fourth quarter 2020 production in Greater Sawn was approximately 4,400 
boe/d (92 percent oil and NGLs). 

Greater Sawn Lake 

The Greater Sawn Lake assets are comprised of three main fields (Sawn Lake, Otter and Red Earth) near 
Red Earth Creek in Northern Alberta.  Production from this property is primarily 40° API light oil from the 
Slave Point and Granite Wash formations.  The majority of the new development is focused on the Slave 
Point formation. The majority of these pools are currently on primary production with horizontal Slave Point 
waterflood being implemented in Sawn Lake.  These assets were acquired on October 25, 2018, with the 
corporate acquisition of Mount Bastion. 

Valhalla 

As at December 31, 2020, the Corporation’s principal property in the Valhalla area is the Valhalla/Wembley 
property. At Valhalla, Surge held an average working interest of approximately 70 percent in approximately 
22,920 gross (16,032 net) developed acres and an average working interest of approximately 74 percent 
in approximately 11,160 gross (8,208 net) undeveloped acres.  As at December 31, 2020, the Corporation 
held  interests  in  94  gross  (56  net)  oil  wells  and  10  gross  (4  net)  gas  wells  producing  from  formations 
including, but not limited to, Doig, Montney, and Charlie Lake.  In addition, the Corporation operates multiple 
oil batteries providing a strong infrastructure base for future development in the area.  Surge’s fourth quarter 
2020 production in Valhalla was approximately 3,300 boe/d (53 percent oil and NGLs). 

The Valhalla/Wembley property is located in northwestern Alberta, approximately 40 kilometres northwest 
of Grand Prairie.  The majority of production from this property was from the horizontal oil wells producing 
from an extensive tight sand, with up to 40 metres of gross light oil pay in the Triassic Doig formation. 

Sparky 

As at December 31, 2020, Surge’s principal properties in the Sparky area included the Sparky assets and 
the  Lloyd/Cummings  zone  waterflood  at  Silver.  At  Sparky,  Surge  held  an  average  working  interest  of 
approximately 76 percent in approximately 105,502 gross (80,213 net) developed acres and an average 
working  interest  of  approximately  96  percent  in  approximately  61,094  gross  (58,598  net)  undeveloped 
acres.  As at December 31, 2020, the Corporation held interests in 555 gross (466 net) oil wells and 32 

- 15 - 

 
gross (10 net) gas wells producing from formations including, but not limited to, Sparky, Lloydminster, and 
Cummings.   In addition, the Corporation  operates  multiple  oil batteries, providing  a  strong  infrastructure 
base  for  future  development  in  the  area.    Surge’s  fourth  quarter  2020  production  in  Sparky  was 
approximately 7,900 boe/d (90 percent oil and NGLs). 

Sparky 

The Sparky assets are comprised of six main fields  spread between Provost and Wainwright in  eastern 
Alberta and western Saskatchewan.  Eye Hill, Provost and Betty Lake are early stage primary development 
properties, while Wainwright, Macklin, Lakeview, and East Sounding are more mature, mostly developed 
waterflood  assets.    Production  from  the  Sparky  assets  is  primarily  crude  oil  (90  percent  oil  and  NGLs) 
ranging from 23° to 28° degrees API.  

In 2020, the Corporation drilled 32 gross (32 net) horizontal, multi-frac, Sparky oil wells. Of these wells, 19 
were on production by year-end 2020, with the remaining wells coming on production in Q1 2021. 

Shaunavon 

The Shaunavon properties are primarily located approximately 100 kilometres southwest of Swift Current, 
Saskatchewan and 140 kilometres east of the Alberta border.  As at December 31, 2020, these operated 
properties  included  an  average  working  interest  of  approximately  100  percent  in  approximately  23,409 
gross (23,409 net) developed acres and an average working interest of approximately 100 percent in 13,698 
gross (13,698 net) undeveloped acres.  As at December 31, 2020, the Corporation held interests in 176 
gross (176 net) oil wells producing from the Upper and Lower Shaunavon formations, among others.  The 
Corporation’s production from this property is weighted 100 percent to medium crude oil (21-26° API).  The 
Corporation  operates  major  facilities  at  this  property  providing  a  strong  infrastructure  base  for  future 
development in the area.  This property’s fourth quarter 2020 production was approximately 1,300 boe/d 
(100 percent oil).   

Minors 

As at December 31, 2020, the Corporation’s principal properties in the Minors area included Edmonton and 
other  minor  areas.  At  Minors,  Surge  held  an  average  working  interest  of  approximately  61  percent  in 
approximately  144,305  gross  (88,178  net)  developed  acres  and  an  average  working  interest  of 
approximately 39 percent in approximately 26,915 gross (10,483 net) undeveloped acres.  As at December 
31,  2020,  the  Corporation  held  interests  in  83  gross  (28  net)  oil  wells  and  83  gross  (7  net)  gas  wells 
producing  from  formations  including,  but  not  limited  to,  Rock  Creek.    This  area’s  fourth  quarter  2020 
production was approximately 400 boe/d (59 percent oil and NGLs).  

- 16 - 

 
 
 
STATEMENT OF RESERVES DATA 

In accordance with NI 51-101, Sproule prepared the Reserves Report based on its evaluation of the oil, 
NGL and natural gas reserves attributable to the properties of the Corporation as at December 31, 2020.  
The Reserves Report has a preparation date of March 3, 2021. 

The  tables  below are  a combined  summary  of  the oil,  NGL and  natural  gas reserves  attributable  to  the 
properties of the Corporation and the net present value of future net revenue attributable to such reserves 
as evaluated in the Reserves Report based on forecast price and cost assumptions. The tables summarize 
the  data contained in the Reserves Report and, as a result, may contain slightly  different numbers than 
such report due to rounding.  Also due to rounding, certain columns may not add exactly. 

The net present value of future net revenue attributable to reserves is stated without provision for interest 
costs and general  and administrative costs, but after providing for estimated royalties, production costs, 
development costs, other income, future capital expenditures and well abandonment costs for only those 
wells assigned reserves by Sproule.  It should not be assumed that the undiscounted  or discounted net 
present value of future net revenue attributable to reserves estimated by Sproule represent the fair market 
value of those reserves evaluated.  Other assumptions and qualifications relating to costs, prices for future 
production and other matters are summarized herein.  The recovery and reserve estimates of oil, NGL and 
natural gas reserves provided herein are estimates only.  Actual reserves may be greater than or less than 
the estimates provided herein.  

The Reserves Report is based on certain factual data supplied by the Corporation and Sproule’s opinions 
of reasonable practice in the industry. The extent and character of ownership and all factual data pertaining 
to petroleum properties and contracts (except for certain information residing in the public domain) were 
supplied by the Corporation to Sproule.  Sproule accepted this data as presented and neither title searches 
nor field inspections were conducted. 

Summary of Oil and Gas Reserves – Forecast Prices and Costs  

Light and 
Medium 
Crude Oil 
(Mbbls) 

Heavy 
Crude Oil 
(Mbbls) 

Gross Reserves 
Natural 
Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

Coalbed 
Methane 
(MMcf) 

Light and 
Medium 
Crude Oil 
(Mbbls) 

Heavy 
Crude Oil 
(Mbbls) 

Net Reserves 
Natural 
Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

Coalbed 
Methane 
(MMcf) 

17997.8 

7,852.2 

811.1 

23,522 

685 

15,957.2 

7,231.3 

636.5 

21,600 

611 

506.9 
20,265.5 
38,770.3 
20,911.5 

361.4 
8,337.9 
16,551.5 
7,903.1 

32.0 
1,125.2 
1,968.3 
860.9 

936 
33,781 
58,240 
27,002 

- 
56 
741 
182 

476.8 
17,842.2 
34,276.1 
17,632.4 

324.2 
7,750.0 
15,305.6 
7,254.5 

23.3 
959.9 
1,619.7 
697.8 

59,681.8 

24,454.6 

2,829.2 

85,241 

924 

51,908.5 

22,560.0 

2,317.5 

872 
31,171 
53,644 
24,696 

78,339 

-   

52 
663 
169 

832 

Proved 

Developed 
Producing 
Developed 
Non-
Producing 
Undeveloped 
Total Proved 
Probable 
Total Proved 
plus Probable 

- 17 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                    
 
 
 
 
Net Present Value of Future Net Revenue – Forecast Prices and Costs  

($M) 
Proved 

Developed Producing 
Developed Non-Producing 
Undeveloped 
Total Proved 
Probable 
Total Proved plus Probable 

($M) 
Proved 

Developed Producing 
Developed Non-Producing 
Undeveloped 
Total Proved 
Probable 
Total Proved plus Probable 

Proved 

Developed Producing 
Developed Non-Producing 
Undeveloped 
Total Proved 
Probable 
Total Proved plus Probable 

Before Future Income Tax Expenses and Discounted at 

0% 

5% 

36,085 
17,387 
477,335 
530,807 
855,403 
1,386,210 

295,965 
13,826 
335,816 
645,607 
576,569 
1,222,175 

10% 

297,694 
11,313 
237,361 
546,369 
413,755 
960,123 

15% 

275,589 
9,471 
168,662 
453,722 
311,114 
764,835 

After Future Income Tax Expenses and Discounted at 

0% 

5% 

36,085 
17,387 
477,335 
530,807 
704,096 
1,234,904 

295,965 
13,826 
335,816 
645,607 
475,785 
1,121,391 

10% 

297,694 
11,313 
237,361 
546,369 
344,014 
890,382 

15% 

275,589 
9,471 
168,662 
453,722 
261,300 
715,021 

20% 

253,321 
8,076 
119,976 
381,373 
242,424 
623,797 

20% 

253,321 
8,076 
119,976 
381,373 
205,886 
587,259 

Unit Value before Income Tax Discounted 
at 10%/year ($/boe) 

10.81 
11.67 
7.47 
9.07 
13.92 
10.67 

Additional Information Concerning Future Net Revenue – Forecast Prices and Costs 
(Undiscounted)  

Revenue  Royalties 
341,838 
3,496,940 

Operating 
Costs 
1,532,364 

Develop-
ment 
Costs 
635,546 

Abandon-
ment 
and Other 
Costs 
456,385 

Future net 
revenue 
before 
income 
taxes 
530,807 

Future 
income 
taxes 

-   

Future 
net 
revenue 
after 
income 
taxes 
530,807 

5,495,629 

597,004 

2,204,887 

839,432 

468,097 

1,386,210 

151,306 

1,234,904 

(Undiscounted) ($M) 
Total Proved 
Total Proved plus 
Probable 

- 18 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Future Net Revenue by Production Group – Forecast Prices and Costs  

Proved 

Light and Medium Crude Oil(1) 
Heavy Crude Oil(1) 
Conventional Natural Gas(2) 
Coalbed Methane(2) 
Proved plus Probable 

Light and Medium Crude Oil(1) 
Heavy Crude Oil(1) 
Conventional Natural Gas(2) 
Coalbed Methane(2) 

Future Net Revenue Before 
Income Taxes and  
Discounted at 10% per 
year ($M) 

Per Unit Future Net Revenue Before 
Income Taxes and Discounted at 
10%(3) per year ($/boe) 

375,999 
169,038 
1,039 
292 

679,648 
278,959 
1,172 
344 

8.60 
10.39 
6.22 
2.64 

10.36 
11.60 
5.54 
2.48 

Notes: 
1. 
2. 
3. 

Including solution gas and other by-products. 
Including by-products, but excluding solution gas from oil wells. 
Based on net reserves volumes. 

Pricing Assumptions – Forecast Prices and Costs 

Sproule  employed  the  following  pricing  and  inflation  rate  assumptions  as  of  December  31,  2020  in  its 
evaluation  in  estimating  reserves  data  using  forecast  prices  and  costs.  The  weighted  average  historical 
prices received by the Corporation for 2020 are also reflected in the table below.  

Medium and Light  
Crude Oil 

Natural 
Gas 

NGL 

Canadian  
Light 
Sweet 
Crude 40 
API ($/bbl) 
45.39 
54.55 
57.14 
63.64 
64.91 
66.21 
67.53 
68.88 
70.26 
71.66 
73.10 
74.56 

Western 
Canada 
Select 
20.5 
API ($/bbl) 
35.59 
43.51 
46.10 
52.60 
53.65 
54.72 
55.82 
56.93 
58.07 
59.23 
60.42 
61.63 

Alberta 
AECO 
Gas Price 
($/MMBtu) 
2.24 
2.86 
2.78 
2.69 
2.75 
2.80 
2.86 
2.91 
2.97 
3.03 
3.09 
3.15 

Edmonton 
Pentanes 
plus 
($/bbl) 

Edmonton 
Butane 
($/bbl) 

Edmonton 
Propane 
($/bbl) 

Operating 
Cost 
Inflation 
rates 
(%/Yr) 

49.85 
55.84 
58.40 
64.82 
66.11 
67.44 
68.78 
70.16 
71.56 
72.99 
74.45 
75.94 

21.87 
29.87 
34.29 
39.92 
40.72 
41.53 
42.37 
43.21 
44.08 
44.96 
45.86 
46.78 

16.31 
19.36 
21.35 
24.56 
25.06 
25.56 
26.07 
26.59 
27.12 
27.66 
28.22 
28.78 

-5.0% 
0.0% 
1.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 

Capital 
Cost 
Inflation 
rates 
(%/Yr) 
-5.0% 
0.0% 
1.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 
2.0% 

Exchange 
rate 
($US/$Cdn) 
0.75 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 
0.77 

Year 
2020 (Historic) 
2021 
2022 
2023 
2024 
2025 
2026 
2027 
2028 
2029 
2030 
2031 

Note: 
1. 

Escalated thereafter at a rate of +2.0% per annum. 

- 19 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of Changes in Reserves  

The following table sets forth a combined reconciliation of the Corporation’s gross reserves as at December 
31,  2020,  derived from the  Reserves Report using  forecast prices and cost  estimates,  reconciled  to  the 
gross reserves of the Corporation as at December 31, 2020.  

Proved 
Balance at December 31, 2019 
Product Type Transfer 
Extensions and Improved Recovery 
Infill Drilling 
Technical Revisions 
Acquisitions 
Dispositions 
Economic Factors 
Production 
Balance at December 31, 2020 

Probable 
Balance at December 31, 2019 
Product Type Transfer 
Extensions and Improved Recovery 
Infill Drilling 
Technical Revisions 
Acquisitions 
Dispositions 
Economic Factors 
Production 
Balance at December 31, 2020 

Light and 
Medium Crude 
Oil (Mbbls) 

Heavy Crude 
Oil 
(Mbbls) 

Natural Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

Coalbed 
Methane 
(MMcf) 

Boe 
(Mboe) 

43,914 
- 
576 
297 
1,495 
- 
(960) 
(2,680) 
(3,872) 
38,770 

20,051 
- 
720 
415 
(1,870) 
- 
- 
(1,380) 
(1,456) 
16,552 

2,381 
- 
35 
2 
(32) 
- 
(74) 
(125) 
(220) 
1,968 

66,468 
- 
2,626 
 279 
1,067 
- 
(2,709) 
(3,389) 
(6,103) 
58,240 

- 
- 
- 
- 
944 
- 
- 
(118) 
(85) 
740.6 

77,424 
- 
1,768 
761 
(72) 
- 
(1,485) 
(4,697) 
(6,579) 
67,120 

Light and 
Medium Crude 
Oil (Mbbls) 

Heavy Crude 
Oil 
(Mbbls) 

Natural Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

Coalbed 
Methane 
(MMcf) 

Boe 
(Mboe) 

23,083 
- 
407 
261 
(1,355) 
- 
(1,,96) 
(288) 
- 
20,912 

9,954 
- 
630 
77 
(2,535) 
- 
- 
(223) 
- 
7,903 

1,046 
- 
22 
4 
(109) 
- 
(82) 
(19) 
- 
861 

31,837 
- 
1,625 
121 
(2,796) 
- 
(3,035) 
(749) 
- 
27,002 

170 
- 
- 
- 
49 
- 
- 
(37) 

182 

39,417 
- 
1,329 
363 
(4,457) 
- 
(1,784) 
(661) 
- 
34,206 

Proved plus Probable 
Balance at December 31, 2019 
Product Type Transfer 
Extensions and Improved Recovery 
Infill Drilling 
Technical Revisions 
Acquisitions 
Dispositions 
Economic Factors 
Production 
Balance at December 31, 2020 

Light and 
Medium Crude 
Oil (Mbbls) 

Heavy Crude 
Oil 
(Mbbls) 

Natural Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

Coalbed 
Methane 
(MMcf) 

Boe 
(Mboe) 

66,997 
- 
982 
558 
140 
- 
(2,156) 
(2,967) 
(3,872) 
59,682 

30,005 
- 
1,350 
234 
(4,147) 
- 
- 
(1,531) 
(1,456) 
24,455 

3,427 
- 
57 
6 
(141) 
- 
(156) 
(144) 
(220) 
2,829 

98,305 
- 
4,251 
189 
(1,518) 
- 
(5,744) 
(4,138) 
(6,102) 
85,243 

170 
- 
- 
- 
993 
- 
- 
(155) 
(85) 
924 

116,841 
- 
3,097 
829 
(4,235) 
- 
(3,269) 
(5,357) 
(6,579) 
101,327 

- 20 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Additional Information Relating to Reserves Data  

First Attributed Undeveloped Reserves 

The following table sets forth the volumes of proved undeveloped reserves that were first attributed in each 
of the three most recent financial years: 

Proved 
2018 
2019 
2020 

Light and 
Medium Crude 
Oil (Mbbls) 

Heavy Crude Oil 
(Mbbls) 

Natural Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

7,495.4  
4,388.5 
674.0 

2,242.0  
1,685.3 
795.0 

209.5  
104.9 
21.0 

5,167.0  
5,434.0 
1,587.0 

The following table sets forth the volumes of probable undeveloped reserves that were first attributed  in 
each of the three most recent financial years: 

Probable 
2018 
2019 
2020 

Light and 
Medium Crude 
Oil (Mbbls) 

Heavy Crude Oil 
(Mbbls) 

Natural Gas 
Liquids 
(Mbbls) 

Conventional 
Natural Gas 
(MMcf) 

5,787.5  
3,769.8 
537.0 

1,777.3  
1,289.7 
673.0 

170.2  
84.2 
20.0 

5,051.0  
1,308.0 
1,435.0 

Proved undeveloped reserves  are generally  those  reserves related  to  infill  wells that have not  yet  been 
drilled or wells further away from gathering systems requiring relatively high capital to bring on production.  
Probable  undeveloped  reserves  are  generally  those  reserves  tested  or  indicated  by  analogy  to  be 
productive,  infill  drilling  locations  and  lands  contiguous  to  production.    This  also  includes  the  probable 
undeveloped wedge from the proved undeveloped locations. 

The  Corporation  currently  plans  to  pursue  the  development  of  its  proven  and  probable  undeveloped 
reserves within the next two years through ordinary course capital expenditures. However, the Corporation 
may choose to delay development depending on  a number of circumstances, including the existence of 
higher priority expenditures and prevailing commodity prices and cash flow. 

Significant Factors or Uncertainties Affecting Reserves Data 

The process of estimating reserves is complex. It requires significant judgments and decisions based on 
available  geological,  geophysical,  engineering,  and  economic  data.  These  estimates  may  change 
substantially as additional data from ongoing development activities and production performance becomes 
available and as economic conditions impacting oil and gas prices and costs change. The reserve estimates 
contained herein are based on current production forecasts, prices and economic conditions.  

As  circumstances  change  and  additional  data  becomes  available,  reserve  estimates  also  change. 
Estimates  made  are  reviewed  and  revised,  either  upward  or  downward,  as  warranted  by  the  new 
information. Revisions are often required due to changes in well performance, prices, economic conditions 
and governmental restrictions. 

Although every reasonable effort is made to ensure that reserve estimates are accurate, reserve estimation 
is an inferential science. As a result, subjective decisions, new geological or production information and a 
changing environment may impact these estimates.  Revisions to reserve estimates can arise from changes 
in year-end oil and gas prices and reservoir performance.  Such revisions can be either positive or negative.  

- 21 - 

 
 
 
 
 
 
 
 
 
 
 
Future Development Costs 

The table below sets out the combined total development costs deducted in the estimation in the Reserves 
Report  of  future  net  revenue  attributable  to  proved  reserves  and  proved  plus  probable  reserves  (using 
forecast prices and costs). 

2021 
2022 
2023 
2024 
2025 
Remaining Years 

Total Undiscounted 

Forecast Prices and Costs 

Proved Reserves  
($M) 
69,669 
160,751 
144,851 
128,666 
73,595 
58,014 

Proved plus 
Probable 
Reserves ($M) 
84,789 
200,491 
183,710 
172,175 
93,661 
104,606 

635,546 

839,432 

The Corporation has four sources of funding available to finance its capital expenditure programs: internally 
generated cash flow from operations, funds raised from the sale of non-core assets, debt financing when 
appropriate and new issues of Common Shares, if available on favourable terms. The Corporation expects 
to fund the above future development costs primarily through internally generated cash flow, funds raised 
from the  sale  of non-core  assets and  debt.   There can  be  no guarantee that  the Board  of  Directors  will 
allocate funding to develop all of the reserves attributed in the Reserves Report.  Failure to develop those 
reserves could have a negative impact on the Corporation’s future cash flow.  

Other Oil and Gas Information 

Oil and Gas Wells 

The  following  table  sets  forth  the  number  and  status  of  the  Corporation’s  wells  effective  December  31, 
2020.  

Producing 

Non-Producing 

Oil 

Natural Gas 

Coalbed 
Methane 

Water Inj/Disp 

Oil 

Natural 
Gas 

Coalbed 
Methane 

Water 
Inj/Disp 

Gross 

Net 

Gross 

Net  Gross 

Net  Gross 

Net 

Gross 

Net 

Gros
s 

Net  Gross 

Net 

Gross 

Net 

Alberta 

Saskatchewan 

1,089 

199 

843 

199 

62 

75 

Total 

1,288 

1,042 

137 

25 

5 

30 

7 

- 

7 

4 

- 

4 

308 

21 

329 

219 

19 

238 

2,096 

1,742 

421 

320 

91 

64 

16 

7 

2,187 

1,806 

437 

327 

1 

- 

1 

1 

- 

1 

277 

11 

288 

223 

9 

232 

- 22 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Properties with no Attributed Reserves  

The  following  table  summarizes,  effective  December  31,  2020,  the  gross  and  net  acres  of  unproved 
properties  in  which  the  Corporation  has  an  interest  and  also  the  number  of  net  acres  for  which  the 
Corporation’s rights to explore, develop or exploit will, absent further action, expire within one year.  

Alberta 
Saskatchewan 
Total 

Gross  
Undeveloped 
Acres 

Net  
Undeveloped 
Acres 

Net 
Undeveloped 
Acres Expiring 
within One Year 

258,629 
19,037 
277,666 

226,230 
17,101 
243,331 

21,885 
- 
21,885 

Additional Information Concerning Abandonment and Reclamation Costs  

The Corporation typically estimates well abandonment costs area by area.  Such costs are included in the 
Reserves Report as deductions in arriving at future net revenue.  The expected total abandonment costs 
included in the Reserves Report for 4,075 net wells under the proved reserves category is $456.4 million 
undiscounted ($50.4 million discounted at 10 percent), of which a total of $11.7 million is estimated to be 
incurred  in  2021,  2022  and  2023.  This  estimate  includes expected reclamation  costs  for  surface  leases 
which  have  existing  wells  with  economic  developed  reserves  assigned  or  future  development  drilling 
locations.   The  Corporation  will  be  liable  for  its  share  of  ongoing  environmental  obligations  and  for  the 
ultimate  reclamation  of  the  properties  held  by  it  upon  abandonment.  Subject  to  pending  changes  in 
applicable regulations regarding the abandonment and reclamation, ongoing environmental obligations are 
expected to be funded out of cash flow. 

Forward Contracts 

Surge is exposed to market risks resulting from fluctuations in commodity prices, foreign exchange rates 
and interest rates in the normal course of operations. A variety of derivative instruments are used by Surge 
to reduce its exposure to fluctuations in commodity prices and foreign exchange rates. Surge is exposed 
to losses in the event of default by the counterparties to these derivative instruments. Surge manages this 
risk by diversifying its derivative portfolio amongst a number of financially sound counterparties. 

For details of the Corporation’s forward contracts in place as at December 31, 2020, see the Corporation’s 
audited  annual  financial  statements  for  the  year  ended  December  31,  2020,  which  have  been  filed  on 
SEDAR and may be viewed under the Corporation’s profile at www.sedar.com.  See “Risk Factors – Fixed 
Price Hedging”. 

Tax Horizon 

Based  on  planned  capital  expenditures  and  the  forecast  commodity  pricing  employed  in  the  Reserves 
Report, the Corporation estimates that it will not be required to pay current income taxes before 2025. 

- 23 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
Costs Incurred 

The  following  table  summarizes capital expenditures incurred  by the  Corporation during the  year  ended 
December 31, 2020.  

Property Acquisition Costs 
Unproved 
Properties 
- 

Proved 
Properties 
- 

Property 
Dispositions 
(6,038) 

Exploration 
Costs 
- 

Development 
Costs 
52,773 

Total ($M) 

Drilling Activity 

The following table sets forth the gross and net exploration and development wells drilled by the Corporation 
based on rig release date during the year ended December 31, 2020.  

Light and Medium Crude Oil 
Heavy Crude Oil 
Conventional Natural Gas 
Service 
Dry 
Total 

Planned Capital Expenditures 

Exploration Wells 

Gross 

Development Wells 

Net 

Gross 

- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 

32.00 
- 
- 
- 
- 
32.00 

Net 

32.00 
- 
- 
- 
- 
32.00 

The  Corporation  has  announced  a  planned  capital  expenditure  budget  of  approximately  $55  million  for 
2021.   

Production Estimates 

The following table discloses for each product type the total volume of production estimated by Sproule in 
the Reserves Report for 2020 in the estimates of future net revenue from gross proved and gross proved 
plus probable reserves disclosed above.  

Light and 
Medium 
Crude Oil 
(bbls/d) 

Heavy 
Crude Oil 
(bbls/d) 

Conventional 
Natural Gas 
(Mcf/d) 

Coalbed 
Methane 
(Mcf/d) 

Natural 
Gas 
Liquids 
(bbls/d) 

Proved 
Greater Sawn 
Valhalla 
Sparky 
Shaunavon 
Minors 
Total Proved 

Proved Plus Probable 
Greater Sawn 
Valhalla 
Sparky 
Shaunavon 
Minors 
Total Proved Plus Probable 

3,992 
1,371 
5,130 
- 
97 
10,590 

4,215 
1,499 
5,880 
- 
108 
11,700 

- 
- 
2,876 
1,237 
67 
4,180 

- 
- 
3,014 
1,295 
70 
4,379 

1,210 
8,947 
5,581 
- 
534 
16,271 

1,256 
9,705 
6,350 
- 
560 
17,871 

367 
- 
- 
- 
- 
367 

373 
- 
- 
- 
- 
373 

85 
322 
95 
- 
6 
508 

89 
349 
111 
- 
6 
555 

Boe 
(boe/d) 

4,340 
3,184 
9,031 
1,237 
259 
18,050 

4,575 
3,465 
10,063 
1,295 
277 
19,675 

% 

24% 
18% 
50% 
7% 
1% 
100% 

23% 
18% 
51% 
7% 
1% 
100% 

- 24 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Production History 

The  following  table  discloses,  on  a  quarterly  basis  for  the  year  ended  December  31,  2020,  certain 
information  in  respect  of  production,  product  prices  received,  royalties  paid,  operating  expenses  and 
resulting operating netback for the Corporation.  

Average Daily Production Volume  

Conventional Natural Gas (Mcf/d) 
Light and Medium Crude Oil (bbls/d) 
NGL (bbls/d) 
Coalbed Methane (Mcf/d) 
Total (boe/d) 

Mar 31, 2020 

Jun 30, 2020 

Sep 30, 2020 

Dec 31, 2020 

Three Months Ended 

17,281 
16,891 
564 
128 
20,357 

16,539 
13,813 
528 
125 
17,118 

16,251 
13,759 
582 
252 
17,092 

16,630 
13,788 
726 
420 
17,356 

Prices Received, Royalties Paid, Production Costs and Operating Netback – Crude Oil  

($ per Bbl) 

Prices Received 
Royalties Paid 
Production Costs 
Transportation Costs 
Operating Netback(1) 

Mar 31, 2020 

Jun 30, 2020 

Sep 30, 2020 

Dec 31, 2020 

Three Months Ended 

34.24 
(4.62) 
(14.28) 
(1.61) 
13.73 

19.42 
(2.06) 
(14.49) 
(1.67) 
1.21 

36.02 
(4.01) 
(14.17) 
(1.36) 
16.48 

37.24 
(4.14) 
(15.77) 
(1.17) 
16.17 

Note: 
1. 

Including solution gas and associated natural gas liquids revenue. 

Prices Received, Royalties Paid, Production Costs and Operating Netback – Conventional Natural 
Gas  

($ per Mcf) 

Prices Received 
Royalties Received 
Production Costs 
Transportation Costs 
Operating Netback 

Mar 31, 2020 

Jun 30, 2020 

Sep 30, 2020 

Dec 31, 2020 

Three Months Ended 

0.90 
0.19 
(0.05) 
(0.21) 
0.83 

0.94 
0.01 
(0.09) 
(0.20) 
0.67 

1.17 
0.06 
0.06 
(0.20) 
1.08 

1.66 
0.40 
(1.30) 
(0.07) 
0.69 

Prices Received, Royalties Paid, Production Costs and Operating Netback – Combined  

($ per boe) 

Prices Received 
Royalties Paid 
Production Costs 
Transportation Costs 
Operating Netback 

Mar 31, 2020 

Jun 30, 2020 

Sep 30, 2020 

Dec 31, 2020 

Three Months Ended 

34.39 
(4.59) 
(14.29) 
(1.64) 
13.87 

19.58 
(2.06) 
(14.50) 
(1.70) 
1.32 

36.21 
(4.00) 
(14.16) 
(1.39) 
16.66 

37.52 
(4.07) 
(15.99) 
(1.18) 
16.28 

Note: 
1. 

Operating Netback is calculated by deducting royalties paid and production costs, including transportation costs, from prices 
received, excluding the effects of hedging. 

- 25 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Production Volume by Field 

The following table indicates the average daily net production from the Corporation’s important fields for 
the year ended December 31, 2020. 

Light and 
Medium 
Crude Oil 
(bbls/d) 

3,801 
1,689 
7,339 
1,506 
223 
14,558 

Conventional 
Natural Gas 
(Mcf/d) 

Natural Gas 
Liquids 
(bbls/d) 

Coalbed 
Methane 
(Mcf/d) 

1,352 
10,173 
4,552 
- 
598 
16,675 

133 
353 
101 
- 
14 
600 

- 
- 
- 
- 
231 
231 

Field 

Greater Sawn 
Valhalla 
Sparky 
Shaunavon 
Minors 
Total 

Boe 
(boe/d) 

4,159 
3,737 
8,199 
1,506 
375 
17,976 

% 

23% 
21% 
46% 
8% 
2% 
100% 

- 26 - 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DESCRIPTION OF CAPITAL STRUCTURE 

Share Capital 

The Corporation is authorized to issue an unlimited number of Common Shares and an unlimited number 
of preferred shares, issuable in series. 

Common Shares 

The holders of Common Shares are entitled to: (i) one vote for each Common Share held at all meetings 
of  shareholders  of  the  Corporation  other  than  meetings  of  the  holders  of  any  class  or  series  of  shares 
meeting as a class or series; (ii) receive any dividends declared by the Corporation on the Common Shares; 
and  (iii)  subject  to  the  rights  of  shares  ranking  prior  to  the  Common  Shares,  to  receive  the  remaining 
property of the Corporation on dissolution, after the payment of all liabilities. 

Preferred Shares 

Preferred  shares  may  be  issued  in  one  or  more  series.  The  Board  of  Directors  is  authorized  to  fix  the 
number  of  shares  in  each  series  and  to  determine  the  designation,  rights,  privileges,  restrictions  and 
conditions attached to the shares of each series. Preferred shares of the Corporation are entitled to a priority 
over the Common Shares with respect to the payment of dividends and the distribution of assets upon the 
liquidation, dissolution or winding-up of the Corporation. 

Debentures 

The  Debentures,  including  the  Initial  Debentures  and  the  Series  2  Debentures,  are  issued  under  and 
pursuant to the provisions of the Indenture among Computershare Trust Company of Canada and Surge.  
The following is a summary of the material attributes and characteristics of the Debentures.  This summary 
does not purport to be complete and is subject to and qualified in its entirety by reference to the terms of 
the Indenture which may be viewed under Surge’s profile on SEDAR at www.sedar.com.  

The Debentures are direct, subordinated, unsecured obligations of the Corporation, subordinated to any 
existing and future senior indebtedness of the Corporation and ranking equally with one another and with 
all  other  existing  and  future  subordinated  unsecured  indebtedness  of  the  Corporation  to  the  extent 
subordinated on the same terms. 

Initial Debentures 

The  Initial  Debentures  will  mature  and  be  repayable  on  December  31,  2022  (the  “Initial  Debenture 
Maturity Date”) and will accrue interest at the rate of 5.75% per annum payable semi-annually in arrears 
on  December  31  and  June  30  of  each  year  (each  an  “Initial  Debenture  Interest  Payment  Date”), 
commencing on June 30, 2018 and computed on the basis of a 365-day year.  The June 30, 2018 interest 
payment will represent accrued interest for the period from and including November 15, 2017 up to, but 
excluding, June 30, 2018.  Interest on the Initial Debentures will be payable in lawful money of Canada.  

At the holder’s option, the Initial Debentures may be converted into Common Shares at any time prior to 
5:00 p.m. (Calgary time) on the earlier of the business day immediately preceding (i) the Initial Debenture 
Maturity  Date;  and  (ii)  if  called  for  redemption,  the  date  fixed  for  redemption  by  the  Corporation,  at  a 
conversion  price  of  $2.75  per  Common  Share,  subject  to  adjustment  in  certain  events  (the  “Initial 
Debenture Conversion Price”). This represents a conversion rate of approximately 363.6364 Common 
Shares for each $1,000 principal amount of Initial Debentures, subject to certain anti-dilution provisions. 
Holders who convert their Initial Debentures will receive, in addition to the applicable number of Common 

- 27 - 

 
Shares,  accrued  and  unpaid  interest  in  respect  thereof  for  the  period  up  to,  but  excluding,  the  date  of 
conversion from, and including, the most recent Initial Debenture Interest Payment Date. If a holder elects 
to convert its Debentures in connection with a change of control that occurs prior to the Initial Debenture 
Maturity Date, the holder will be entitled to receive additional Common Shares as a make-whole premium 
on conversion in certain circumstances (as more fully described in the Indenture). 

The  Initial  Debentures  may  not  be  redeemed  by  the  Corporation  prior  to  December  31,  2020  except  in 
certain  circumstances  following  a  change  of  control.  On  and  after  December  31,  2020  and  prior  to 
December 31, 2021, the Initial Debentures may be redeemed by the Corporation, in whole or in part, from 
time to time, on not more than 60 days and not less than 30 days prior written notice at a redemption price 
equal to their principal amount plus accrued and unpaid interest, if any, up to but excluding the date set for 
redemption, provided that the volume weighted average trading price of the Common Shares on the TSX 
for the 20 consecutive trading days ending five trading days prior to the date on which notice of redemption 
is provided is at least 125 percent of the Initial Debenture Conversion Price. On or after December 31, 2021 
and prior to the Initial Debenture Maturity Date, the Initial Debentures may be redeemed by the Corporation, 
in whole or in part, from time to time, on not more than 60 days and not less than 30 days prior notice at a 
redemption price equal to their principal amount plus accrued and unpaid interest, if any, up to but excluding 
the date set for redemption. 

The Initial Debentures were listed and posted for trading on the TSX under the symbol “SGY.DB” at the 
open of markets on November 15, 2017.   

Series 2 Debentures 

The  Series  2  Debentures  will  mature  and  be  repayable  on  June  30,  2024  (the  “Series  2  Debenture 
Maturity Date”) and will accrue interest at the rate of 6.75% per annum payable semi-annually in arrears 
on  December  31  and  June  30  of  each  year  (each  a  “Series  2  Debenture  Interest  Payment  Date”), 
commencing on December 31, 2019 and computed on the basis of a 365-day year.  The December 31, 
2019 interest payment will represent accrued interest for the period from and including May 8, 2019 up to, 
but excluding, December 31, 2019.  Interest on the Series 2 Debentures will be payable in lawful money of 
Canada.  

At the holder’s option, the Series 2 Debentures may be converted into Common Shares at any time prior 
to  5:00  p.m.  (Calgary  time)  on  the  earlier  of  the  business  day  immediately  preceding  (i)  the  Series  2 
Debenture Maturity Date; and (ii) if called for redemption, the date fixed for redemption by the Corporation, 
at a conversion price of $2.25 per Common Share, subject to adjustment in certain events (the “Series 2 
Debenture Conversion Price”). This represents a conversion rate of approximately 444.4444 Common 
Shares for each $1,000 principal amount of Series 2 Debentures, subject to certain anti-dilution provisions. 
Holders who convert their Series 2 Debentures will receive, in addition to the applicable number of Common 
Shares,  accrued  and  unpaid  interest  in  respect  thereof  for  the  period  up  to,  but  excluding,  the  date  of 
conversion  from,  and  including,  the  most  recent  Series  2  Debenture  Interest  Payment  Date.  If  a  holder 
elects to convert its Series 2 Debentures  in connection with a change of control that occurs prior to the 
Series 2 Debenture  Maturity Date, the holder will be entitled to receive additional Common Shares as a 
make-whole premium on conversion in certain circumstances (as more fully described in the Indenture). 

The Series 2 Debentures may not be redeemed by the Corporation prior to June 30, 2022 except in certain 
circumstances following a change of control. On and after June 30, 2022 and prior to June 30, 2023, the 
Series 2 Debentures may be redeemed by the Corporation, in whole or in part, from time to time, on not 
more than 60 days and not less than 30 days prior written notice at a redemption price equal to their principal 
amount plus accrued and unpaid interest, if any, up to but excluding the date set for redemption, provided 
that the volume weighted average trading price of the Common Shares on the TSX for the 20 consecutive 
trading days ending five trading days prior to the date on which notice of redemption is provided is at least 

- 28 - 

 
125 percent of the Conversion Price. On or after June 30, 2023 and prior to the Series 2 Debenture Maturity 
Date, the Series 2 Debentures may be redeemed by the Corporation, in whole or in part, from time to time, 
on not more than 60 days and not less than 30 days prior notice at a redemption price equal to their principal 
amount plus accrued and unpaid interest, if any, up to but excluding the date set for redemption. 

The Series 2 Debentures were listed and posted for trading on the TSX under the symbol “SGY.DB.A” at 
the open of markets on May 8, 2019. 

DIVIDEND POLICY 

The  Credit  Facilities  contain  restrictions  on  Surge’s  ability  to  pay  dividends.  In  addition,  the  payment  of 
dividends  by  a  corporation  is  governed  by  the  liquidity  and  insolvency  tests  described  in  the  ABCA.  
Pursuant to the ABCA, after the payment of a dividend, a corporation must be able to pay its liabilities as 
they become due and the realizable value of the assets of the corporation must be greater than the liabilities 
and the legal stated capital of its outstanding securities. 

On March 9, 2020, the Corporation announced it was reducing monthly dividend by 90%, from $0.10 per 
Common  Share  per  year to $0.01  per Common Share per  year,  effective with the March  2020  dividend 
payable in April 2020.  On April 14, 2020, the Corporation suspended the Corporation’s dividend program 
in  its  entirely.    The  final    cash  dividend  payment  prior  to  suspension  was  made  on  April  15,  2020  for 
Shareholders of record as at March 31, 2020, as declared on March 16, 2020. 

The following monthly cash dividends on Common Shares were declared in respect of the periods indicated:   

Month 

January 
February 
March 
April 
May 
June 
July 
August 
September 
October 
November 
December 

Total 

2021 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 

- 

- 

Dividends per Common Share ($) 

2020 

0.008333 
0.008333 
0.000833 
- 
- 
- 
- 
- 
- 
- 
- 
- 

0.017499 

2019 

0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 

0.099996 

2018 

0.007917 
0.007917 
0.007917 
0.007917 
0.007917 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 
0.008333 

0.097916 

Unless otherwise specified, all dividends paid are designated as “eligible dividends” under the Income Tax 
Act (Canada). 

The  amount  of  future  cash  dividends,  if  any,  will  be  subject  to  the  discretion  of  the    Board  of 
Directors and will otherwise depend on a variety of factors, including the removal of the restrictions 
on the payment of dividends contained in the Credit Facilities, prevailing economic and competitive 
environment,  results  of  operations,  fluctuations  in  working  capital,  the  price  of  oil  and  gas,  the 
taxability  of  the  Corporation,  the  Corporation’s  ability  to  raise  capital,  the  amount  of  capital 
expenditures,  the  satisfaction  of  solvency  tests  imposed  by  the  ABCA  for  the  declaration  and 
payment of dividends, applicable law and other factors. See “Dividend Policy”. 

- 29 - 

 
 
MARKET FOR SECURITIES 

The Common Shares are listed and posted for trading on the TSX under the trading symbol “SGY”.  The 
following table sets forth the market price ranges and the trading volumes for the Common Shares for the 
periods indicated, as reported by the TSX, for the year ended December 31, 2020.  

Price Range ($) 

Period 

High 

January  
February 
March 
April 
May 
June 
July 
August 
September 
October 
November 
December 

1.18 
1.03 
0.90 
0.33 
0.32 
0.54 
0.36 
0.36 
0.31 
0.20 
0.33 
0.39 

Low 

0.99 
0.78 
0.19 
0.20 
0.24 
0.26 
0.30 
0.30 
0.19 
0.14 
0.19 
0.28 

Trading 
Volume 

14,546,958 
11,453,169 
35,067,095 
36,331,017 
21,180,626 
48,773,178 
10,188,258 
18,536,129 
11,683,939 
18,924,044 
27,131,909 
24,879,662 

The Initial Debentures are listed and posted for trading on the TSX under the trading symbol “SGY.DB”.  
The following table sets forth the market price ranges and the trading volumes for the Initial Debentures for 
the periods indicated, as reported by the TSX, for the year ended December 31, 2020.  

Period 

January 
February 
March 
April 
May 
June 
July 
August 
September 
October 
November 
December  

Price Range ($) 

High 

98.74 
98.20 
91.50 
47.99 
45.00 
64.99 
55.00 
60.00 
53.02 
38.00 
55.98 
68.00 

Low 

96.01 
88.00 
18.21 
23.00 
33.00 
39.00 
50.50 
51.00 
30.00 
27.75 
30.00 
50.00 

Trading 
Volume 

465,999 
297,000 
1,248,000 
1,062,999 
349,000 
487,000 
253,000 
385,000 
464,000 
1,741,999 
2,457,000 
566.999 

- 30 - 

 
 
 
 
 
 
 
The Series 2 Debentures are listed and posted for trading on the TSX under the trading symbol “SGY.DB.A”.  
The following table sets forth the market price ranges and the trading volumes for the Series 2 Debentures 
for the periods indicated, as reported by the TSX, for the year ended December 31, 2020.  

Price Range ($) 

Period 

High 

Low 

January 
February 
March 
April 
May 
June 
July 
August 
September 
October 
November 
December 

100.00 
101.21 
96.03 
46.50 
45.00 

63.00 
57.50 
58.75 
52.00 
40.00 
53.99 
67.00 

98.00 
96.00 
19.00 
25.00 
38.00 
45.00 
50.00 
49.80 
39.00 
26.00 
26.00 
46.00 

Trading 
Volume 

775,000 
357,999 
480,000 
271,000 
270,000 
420,998 
115,000 
269,999 
67,000 
751,999 
1,438,998 
426,000 

DIRECTORS AND OFFICERS 

The  name,  municipality  of  residence,  principal  occupation  for  the  prior  five  years  and  position  with  the 
Corporation of each of the directors and officers of the Corporation are as follows:  

Name and 
Residence 

Paul Colborne 
Alberta, Canada 

Position 

Principal Occupation During Previous Five Years 

President and 
Chief Executive 
Officer  

Director since 
April 13, 2010 

President  and  Chief  Executive  Officer  of  the  Corporation.  He  is  also  the 
President of StarValley Oil and Gas Ltd., a private, Calgary-based oil and 
gas company founded in November 2005. Mr. Colborne currently serves as 
Chairman of the board of directors of Rising Star Resources Ltd., a private 
oil and gas company. In 1993, after nine years practicing securities, banking 
and  oil  and  gas  law,  Mr.  Colborne  directed  his  focus  to  the  oil  and  gas 
industry and founded an oil and gas company called Startech Energy Ltd., a 
publicly traded company, which grew to 15,000 boe/d. Eight years later in 
2001,  Startech  was  acquired  by  ARC  Energy  Trust  for  more  than  C$500 
million.  From  September  2003  to  January  2005,  Mr.  Colborne  was  the 
President and Chief Executive Officer of StarPoint Energy Trust, a 36,000 
boe/d publicly  traded energy  trust. From 1996 to  May 2013,  Mr.  Colborne 
was  on  the board  of directors  of  Crescent  Point  Energy  Corp.,  a  110,000 
boe/d publicly traded oil and gas company. Until its sale in July of 2009, Mr. 
Colborne  served  as  Chairman  of  TriStar  Oil  &  Gas  Ltd.  He  was  also 
previously a Director for Westfire Energy Ltd., Twin Butte Energy Ltd., Red 
River Oil Inc., Cequence Energy Ltd., and Chairman of Seaview Energy Ltd. 
Until its sale in December of 2009, he also served as a Director of Breaker 
Energy Ltd. Mr. Colborne was also Chairman and a Director of Mission Oil 
and Gas Inc. until its sale in February 2007. In May of 2014, Paul stepped 
down from the board of Legacy Oil + Gas. In June of 2014, Paul completed 

- 31 - 

 
 
 
 
Name and 
Residence 

Position 

Principal Occupation During Previous Five Years 

James Pasieka 
Alberta, Canada 

Director since 
April 13, 2010 

Chairman of the 
Board since 
January 7, 2015 

Marion Burnyeat 
ICD.D(2)(4) Alberta, 
Canada 

Director since 
July 16, 2018 

Daryl Gilbert(2)(3) 
Alberta, Canada 

Director since 
June 5, 2014 

Michelle 
Gramatke(1) 
Alberta, Canada 

Director since 
May 2019 

his term as Chairman of a private company called New Star Energy Ltd., and 
stepped down as a Director. 

Counsel  to  the  national  law  firm  McCarthy  Tétrault  LLP  since  January  1, 
2020.  Prior  thereto,  partner at  McCarthy  Tétrault  LLP  since  September  1, 
2013. Prior to that, partner of the national law firm Heenan Blaikie LLP since 
January  1,  2001.  Mr.  Pasieka  has  served  as  an  officer  and  director  of  a 
number of public energy companies, and chairman of the board of several 
oil and gas companies. 

Director, SECURE Energy Services since April 2020 and Calgary Academy 
and  Headwater  Learning  Group  since  June  2018.    Consultant  with  Inter 
Pipeline  on  mergers  and  acquisitions  from  April  to  June  2018.    Vice 
President of Field Services at Westcoast Energy Inc. from January 2013 to 
March  2017.    Prior  thereto,  Ms.  Burnyeat  served  as  Vice  President  of 
Midstream of Westcoast Energy Inc. from May 2008 to January 2013. She 
served as Vice President Strategic Development and Stakeholder Relations 
at Westcoast Energy Inc. from January 2007 to May 2008. Ms. Burnyeat has 
nearly  thirty  years  in  the  energy  sector  primarily  with  Spectra  Energy 
Corporation  and 
increasingly 
responsible executive roles in leading Midstream business units, Strategic 
Development,  Stakeholder  Relations  and  Business  Development.  Ms. 
Burnyeat  holds  the  ICD.D  designation  from  the  Institute  of  Corporate 
Directors,  a  Bachelor  of  Commerce  degree  from  the  University  of  Alberta 
and a Master of Business Administration degree from Edinburgh University, 
Scotland. She  has  held positions on  not for profit boards and  is  an active 
volunteer for several charitable organizations including Freestyle Alberta. 

its  predecessor  companies.  She  held 

Chair  of  the  Reserves  Committee  for  the  Corporation.  Managing  Director 
and  Investment  Committee  member  of  JOG  Capital  Inc.  since  May  2008.  
Mr.  Gilbert has also been an independent businessman and investor, and 
serves as a director for a number of public and private entities, since 2005.  
Mr.  Gilbert  has  been  active  in  the  Western  Canadian  oil  and  natural  gas 
sector  for  over  40  years,  working  in  reserves  evaluation  with  Gilbert 
Laustsen  Jung  Associates  Ltd.  (now  GLJ  Petroleum  Consultants  Ltd.) 
(“GLJ”),  an  engineering  consulting  firm,  from  1979  to  2005.  Mr.  Gilbert 
served as President and Chief Executive Officer of GLJ from 1994 to 2005. 

Ms.  Gramatke  is  a  Chartered  Accountant  with  over  25  years  of  financial 
experience.  She  was  most  recently  the  Chief  Financial  Officer  of  JOG 
Capital (a private equity investment firm based in Calgary) from 2004 until 
August 2020. Prior to working for JOG Capital, Ms. Gramatke held several 
executive 
of 
PricewaterhouseCoopers Central Asia, Deputy Chief Financial Officer for an 
American NASDAQ-listed telecommunications company with operations in 
Russia and Manager with PricewaterhouseCoopers Moscow. Ms. Gramatke 
began her career with KPMG in Calgary focusing on Canadian upstream oil 
and gas, construction and mining companies. 

Financial 

positions 

including 

Officer 

Chief 

- 32 - 

 
 
 
Name and 
Residence 

Position 

Principal Occupation During Previous Five Years 

Robert Leach(1)(2) 
Arizona, United 
States of America 

Director since 
April 13, 2010 

Allison Maher(1)(3) 
Alberta, Canada 

Director since 
July 16, 2018 

P. Daniel 
O’Neil(3)(4) 
Alberta, Canada 

Director since 
April 13, 2010 

Murray Smith(2)(4) 
Alberta, Canada 

Director since 
June 25, 2010 

Murray Bye 
Alberta, Canada 

Chief Operating 
Officer 

Jared Ducs  
Alberta, Canada 

Chief Financial 
Officer 

Chief  Executive  Officer  of  Custom  Truck  Sales  Ltd.,  a  private  company 
operating Kenworth truck dealerships in Saskatchewan and Manitoba since 
1986, and Vice President of ReNue Properties Arizona Inc. since 2015.  Mr. 
Leach was formerly the Chairman of the board of directors of Breaker Energy 
Inc. 

Chair of the Audit Committee. President, Director and Co-founder of Family 
Wealth  Coach  Planning  Services  since  January  2009.    Prior  thereto,  Ms. 
Maher  worked  at  other  financial-advisory  and  estate-planning  companies 
such as Great-West Life (London Life) for almost two decades.  Ms. Maher 
began  her career  at  KPMG  in  the  areas of  Tax  and  Corporate  Audit.  Ms. 
Maher  has  her  Certified  Corporate  Director,  Chartered  Professional 
Accountant  and  Certified  Financial  Planner  designations.  Ms.  Maher 
received  her  Bachelor  of  Commerce  degree,  with  Distinction,  from  the 
University  of  Calgary.  Ms.  Maher  is  an  active  member  of  the  Institute  of 
Corporate  Directors,  Chair of TIGER21  Calgary  and  currently  holds  board 
positions on several not for profit boards. 

Chair of the Environment, Health and Safety Committee for the Corporation. 
Independent  businessperson  since  his  retirement  on  May  8,  2013.    Prior 
thereto, President and Chief Executive Officer of the Corporation from April 
13, 2010 until his retirement.  Prior thereto, President and Chief Executive 
Officer of Breaker Energy Ltd., a publicly traded oil and natural gas company, 
from its formation in September 2004 until its acquisition by NAL Oil & Gas 
Trust in December 2009.  Mr. O’Neil was also a director of Cathedral Energy 
Services Ltd.   Prior to their sales, Mr. O’Neil was also a Director of Hyperion 
Exploration Corporation and Cequence Energy Ltd  

Chair  of  the  Compensation  Committee  for  the  Corporation.    President  of 
Murray  Smith  and  Associates.  Mr.  Smith  also  serves  on  the  board  of  two 
private companies and Williams Companies Inc. (WMB.nyse), a Tulsa based 
midstream company.  Prior thereto, Mr. Smith was an Official Representative 
of the Province of Alberta to the United States of America until 2007.  Prior 
thereto,  he  was  a  member  of  the  Legislative  Assembly  in  the  Province  of 
Alberta serving in four different Cabinet portfolios – Energy, Gaming, Labour, 
and Economic Development from 1993 to 2005. 

Chief Operating Officer of the Corporation since August 2018.  Prior thereto, 
Mr. Bye was Vice President, Production of the Corporation from May 2013.  
Prior thereto, Mr. Bye was Asset Team Lead – West at Surge since June 
2010.  Prior  to  his  role  at  Surge,  Mr.  Bye  held  a  number  of  positions  at 
EnCana Corporation between the years 2000 to 2010 including: Group Lead 
of  Development,  Exploitation Engineer, and Production  Engineer. Mr.  Bye 
received a Petroleum Engineering degree from Montana Tech. 

Chief Financial Officer of the Corporation since August 2019. Prior thereto, 
Vice President, Finance of the Corporation since August 2018.  Prior thereto, 
Mr. Ducs has held several progressively more senior roles at Surge since 
April 2010 including Director of Corporate Development, Assistant Controller 
and Manager of Financial Reporting.  Preceding his role at Surge, Mr. Ducs 
was a senior member of the Finance group at Breaker Energy Ltd., prior to 
its sale  to  NAL  Oil &  Gas Trust  in  2009.   Prior thereto,  Mr. Ducs held  the 
position  of  Senior  Associate  with  Ernst  &  Young  LLP.  Mr.  Ducs  holds  a 
Charted Accountant Designation and received his Bachelor of Management 

- 33 - 

 
 
 
Name and 
Residence 

Position 

Principal Occupation During Previous Five Years 

Derek Christie 
Alberta, Canada 

Senior Vice 
President – 
Geosciences 

Margaret Elekes 
Alberta, Canada 

Senior Vice-
President, Land 
and Business 
Development 

Rod Monden 
Alberta, Canada 

Controller 

in Accounting and Finance from the University of Lethbridge.  

Senior  Vice  President,  Geosciences  of  the  Corporation  since  November 
2019. Prior thereto, Mr. Christie was the Senior Vice President of Exploration 
& Corporate Development at Crescent Point Energy and was employed with 
that  company  since  February  2007.    During  this  period  he  held  various 
Senior  Management  positions  in  exploration,  geosciences  and  corporate 
development. 

Senior Vice-President, Land and Business Development of the Corporation 
since August 2018.  Prior thereto, Ms. Elekes was Vice-President, Land and 
Business Development of the Corporation from August 2016.  Prior thereto, 
Vice-President,  Land  of  the  Corporation  at  Surge  since  April  2010.    Prior 
thereto,  Consulting  Landman  for  Breaker  Energy  from  its  formation  in 
September 2004 until its acquisition by NAL Oil & Gas Trust in December 
2009. Prior thereto, Landman and US Land Manager for Upton Resources 
from  December 1995  until  its acquisition  by  StarPoint  Energy  in  February 
2004.  

Controller of the Corporation.  Prior thereto, Mr. Monden held the position of 
Controller for Breaker Energy Ltd. from January 2008 until its acquisition by 
NAL  Oil  &  Gas  Trust  in  December  2009.  Prior  thereto,  he  was  the  VP 
Finance and Chief Financial Officer of a private junior oil and gas company 
from September 2006 to October 2008. Prior thereto, Mr. Monden worked 
as  Manager,  Financial  Reporting  &  Budgets  at  Burlington  Resources 
Canada  Ltd.  from  September  2002  to  August  2006.  Mr.  Monden  is  a 
Chartered Professional Accountant (C.A.). 

Notes: 
1. 
2. 
3. 
4. 

Member of the Audit Committee.   
Member of the Compensation, Nominating and Corporate Governance Committee of the Board. 
Member of the Reserves Committee of the Board.  
Member of the Environment, Health and Safety Committee of the Board. 

As at March 9, 2021, the directors and executive officers of the Corporation, as a group, beneficially own, 
control or direct, directly or indirectly, 16,295,099 Common Shares, representing approximately 4.8 percent 
of the outstanding Common Shares.  

The terms of office of each of the directors of the Corporation will expire at the next annual general meeting 
of the shareholders of the Corporation. 

Cease Trade Orders, Bankruptcies, Penalties or Sanctions 

Other than as set forth below, to the knowledge of management of the Corporation: 

a) 

no director or executive officer of the Corporation is, or within the 10 years before the date of this 
AIF, has been, a director, chief executive officer or chief financial officer of any other issuer that: (i) 
was the subject of a cease trade or similar order or an order that denied the other issuer access to 
any  exemptions  under  Canadian  securities  legislation  that  lasted  for  a  period  of  more  than  30 
consecutive days that was issued while the director or executive officer was acting in the capacity 
as director, chief executive officer or chief financial officer; or (ii) was subject to a cease trade or 
similar order or an order that denied the relevant issuer access to any exemption under securities 
legislation  that  lasted  for  a  period  of  more  than  30  consecutive  days  that  was  issued  after  the 

- 34 - 

 
 
b) 

c) 

director or executive officer ceased to be a director, chief executive officer or chief financial officer 
and  which  resulted  from  an  event  that  occurred  while  the  person  was  acting  in  the  capacity  as 
director, chief executive officer or chief financial officer; 

no director or executive officer, or any shareholder holding a sufficient number of securities of the 
Corporation to affect materially the control of the Corporation, or a personal holding company of 
any such person: (i) is, at the date of this AIF or has been within the 10 years before the date of 
this AIF, a director or executive officer of any company that, while that person was acting in that 
capacity or within a year of that person ceasing to act in that capacity, became bankrupt, made a 
proposal under any legislation relating to bankruptcy or insolvency or was subject to or instituted 
any proceedings, arrangement or compromise with creditors or had a receiver, receiver manager 
or trustee appointed to hold its assets; or (ii) has, within the 10 years before the date of this AIF, 
become bankrupt, made a proposal under any legislation relating to bankruptcy or insolvency, or 
was subject to or instituted any proceedings, arrangement or compromise with creditors, or had a 
receiver,  receiver  manager  or  trustee  appointed  to  hold  the  assets  of  the  director,  officer  or 
shareholder; and 

no director or executive officer, or any shareholder holding a sufficient number of securities of the 
Corporation to affect materially the control of the Corporation, has: (i) been subject to any penalties 
or  sanctions  imposed  by  a  court  relating  to  Canadian  securities  legislation  or  by  a  Canadian 
securities  regulatory  authority  or  has  entered  into  a  settlement  agreement  with  the  Canadian 
securities regulatory authority; or (ii) been subject to any other penalties or sanctions imposed by 
a court or regulatory  body  that  would  likely  be considered  important  to  a  reasonable  investor in 
making an investment decision. 

Mr. Gilbert was a director of LGX Oil and Gas Inc. (“LGX”), a public oil and gas company, from August 2013 
until June 2016. On June 7, 2016 a consent receivership order was granted by the Alberta Court of Queen’s 
Bench  (the  “Court”) upon  an application by  LGX’s senior  lender.  LGX’s stock was  cease  traded shortly 
thereafter and a receiver manager was appointed. Mr. Gilbert was a director of Connacher Oil & Gas Limited 
(“Connacher”) from October 2014 until February 2019. On May 17, 2016, Connacher applied for and was 
granted protection from its creditors by the Court pursuant to the Companies’ Creditors Arrangement Act 
(Canada), (“CCAA”). On February 16, 2019, Connacher announced that it was proceeding to close on a 
credit bid transaction with its supporting lenders. Mr. Gilbert resigned from the Board shortly thereafter. Mr. 
Gilbert was a director of Trident Exploration Corp. (“Trident”) from 2010 through year end 2018. On April 
30, 2019, Trident announced it had ceased operations and had transferred all assets to the Alberta Energy 
Regulator. On May 3rd, 2019, PricewaterhouseCoopers LLP was appointed receiver. A liquidation process 
is currently underway. 

Mr. Pasieka was also a director of LGX. Mr. Pasieka resigned as a director of LGX in July 2015. LGX was 
placed into receivership nearly twelve months later in June 2016 and, in connection therewith, a receiver 
was appointed under the Bankruptcy and Insolvency Act (Canada). Cease trade orders in respect of LGX 
were issued shortly after the appointment of the receiver. 

Conflicts of Interest 

As at the date hereof, the Corporation is not aware of any existing or potential material conflicts of interest 
between the Corporation and a director or officer of the Corporation.   

- 35 - 

 
Composition of the Audit Committee, Charter and Review of Services 

AUDIT COMMITTEE 

The  Audit  Committee  of  the  Board  of  Directors  operates  under  a  written  charter  that  sets  out  its 
responsibilities and composition requirements.  A copy of the charter is attached to this AIF as Schedule 
“C”. 

The members of the Audit Committee of the Board of Directors are Allison Maher (Chair), Robert Leach 
and Michelle Gramatke. The Audit Committee charter requires all members of the Audit Committee to be 
“financially literate” and “independent” within the meaning of applicable securities laws.  All members of the 
Audit  Committee  meet  these  requirements.    The  relevant  education  and  experience  of  each  Audit 
Committee member is outlined below: 

Name 

Independent 

Financially 
Literate 

Relevant Education and Experience 

Allison Maher 

 

 

Robert Leach 

 

 

Ms.  Maher  is  currently  the  President  and  Director  of  her  own 
advisory firm, Family Wealth Coach Planning Services.  She is 
highly  involved  in  matters  related  to  succession  planning,  as 
well as family governance, estate and risk management.  Ms. 
Maher  began  her  career  with  KPMG  in  the  areas  of  Tax  and 
Corporate Audit. 

Ms. Maher is presently a member of the Chartered Professional 
Accountants  of  Alberta,  as  well  as  an  active  member  of  the 
Institute of Corporate Directors, Chair of TIGER21 Calgary and 
currently holds board positions on several not for profit boards.  
Ms. Maher also holds Certified Corporate Director and Certified 
Financial Planner designations. 

Ms.  Maher  has  been  a  member  of  the  board  of  the  Calgary 
Health Foundation since February 2020 and was a member of 
the board of the Heritage Park Foundation since June 2014 to 
June 2020.  Ms. Maher has been a  trustee for the Cidel Donor 
Advised Fund since June 2014. From May 2011 to May 2017, 
she served as chairperson and advisory board member for the 
Alberta Business Family Institute (University of Alberta). 

Ms.  Maher  holds  a  Bachelor  of  Commerce  degree,  with 
Distinction, from the University of Calgary. 

Mr.  Leach  is  currently  the  President  of  Sonoma  Valley  LLC 
Arizona Inc., a Phoenix based real estate investment company. 
Mr. Leach was formerly the Chairman of the board of Breaker 
Energy  Ltd.  and  holds  a  Bachelor  of  Commerce  degree, 
majoring in accounting, from the University of Saskatchewan. 

Mr.  Leach  has  experience  reviewing  and  assessing  financial 
statements from his tenure on the audit committee of Breaker, 
as a member of the Board of Surge, and through his years of 
experience  at  Custom  Truck  Sales  Ltd.  and  International 
Fitness Holdings. 

- 36 - 

 
 
 
 
Name 

Independent 

Financially 
Literate 

Relevant Education and Experience 

Michelle 
Gramatke 

 

 

Ms.  Gramatke  was  Chief  Financial  Officer  and  Chief 
Compliance  Officer  of  JOG  Capital,  a  Calgary  based  private 
equity investment fund advisor which invests in Canadian oil & 
gas companies from 2004 to August 2020.  Ms. Gramatke was 
responsible for JOG Capital’s financial reporting, treasury, tax 
and  regulatory  compliance.Ms.  Gramatke 
is  presently  a 
member of the Chartered Professional Accountants of Alberta 
and  holds  a  Bachelor  of  Management  degree  from  the 
University of Lethbridge. 

Pre-Approval of Policies and Procedures 

The Audit Committee charter requires that any non-audit services by the Corporation’s auditors must be 
pre-approved  by  the  Audit  Committee.  The  Audit  Committee  has  passed  a  resolution  providing  the 
Chairman of the Audit Committee with delegated authority to approve the provision of non-audit services 
by the Corporation’s auditors from time to time, provided that: (i) such services are provided pursuant to a 
written engagement letter setting out the services to be provided and the applicable fees; (ii) the provision 
of such services is otherwise in compliance with the Audit Committee’s charter; (iii) such services could not 
be reasonably seen to result in the auditors performing any management function, auditing their own work 
or serving in an advocacy role on behalf of the Corporation; (iv) the fees for such services do not exceed 
$50,000 per engagement; and (v) the Chairman reports to the Committee at the next regularly scheduled 
meeting any approval of non-audit services made pursuant to the authority delegated under the resolution.  
The Audit Committee also pre-approves all audit services and the fees to be paid. 

External Auditor Service Fees   

KPMG LLP are the auditors of the Corporation.  KPMG LLP have been the auditors of the Corporation since 
May 5, 2010. 

The following table sets out the aggregate fees billed by KPMG LLP to the Corporation in each of the last 
two fiscal years. 

Year 

2020 

2019 

Audit Fees(1)  Audit-Related Fees 

Tax Fees(2) 

All Other Fees 

$262,150 

$250,000 

$nil 

$nil 

$54,300 

$72,000 

$nil 

$145,000 

Notes: 
1. 

2. 

Audit fees consist of fees for the audit of annual financial statements or services that are normally provided in connection 
with statutory and regulatory filings or engagements.  The services provided in this category included quarterly review fees. 
Fees for tax compliance, tax advice and tax planning. 

- 37 - 

 
 
 
 
 
 
Restrained Pipeline Capacity and Differential Volatility 

INDUSTRY CONDITIONS 

Western  Canada  has  seen  significant  growth  in  crude  production  volumes  over  recent  years.  This  has 
resulted in pressure on the pipeline take-away capacity, leading to apportionment on the main lines and, in 
turn, backed-up local feeder pipelines.  This has contributed to a widening of, and increased volatility in, 
the  light  oil  pricing  differential  between WTI and  Edmonton  Par and  the  medium/heavy crude  oil pricing 
differential between WTI and Cromer/WCS/Hardisty.  Although pipeline expansions and optimizations are 
ongoing and producers are increasingly turning to rail as an alternative means of transportation, the lack of 
firm pipeline capacity continues to affect the oil and natural gas industry in Western Canada and limit the 
ability to produce and to market production.  In addition, the pro-rationing of capacity on the interprovincial 
pipeline systems also continues to affect the ability to export oil and natural gas. 

Under  the  Canadian  constitution,  interprovincial  and  international  pipelines  fall  within  the  federal 
government’s  jurisdiction  and  require  approval  by  both  the  Canada  Energy  Regulator  (“CER”)  and  the 
cabinet of the federal government. On August 28, 2019, Bill C-69 and related legislation came into force, 
creating  a  new  regulatory  regime  pursuant  to  the  Canadian  Energy  Regulator  Act  (“CER  Act”);  the 
Canadian  Navigable  Waters  Act;  and  the  Impact  Assessment  Act  (“IAA”).  The  CER  Act  replaced  the 
National  Energy  Board  (“NEB”)  with  the  CER.  The  CER  has  similar  oversight  over  federal  energy 
infrastructure projects as the NEB had. However, approvals for projects requiring an impact assessment 
will now be conducted by a review panel established under the IAA instead of the CER. The focus of the 
new CER Act is greater Indigenous and public participation as well consideration for a broader range of 
impacts  beyond  just  environmental  impacts.  Even  when  projects  are  approved  on  a  federal  level,  such 
projects often face further delays due to interference by provincial and municipal governments as well as 
court  challenges  on  various  issues  such  as  Indigenous  title,  the  government’s  duty  to  consult  and 
accommodate Indigenous peoples and the sufficiency of environmental review processes, which creates 
further uncertainty. Export pipelines from Canada to the United States face additional uncertainty as such 
pipelines require approvals of several levels of government in the United States.  

In the face of this regulatory transition, the Canadian crude oil and natural gas industry has experienced 
significant difficulty expanding the existing network of transportation infrastructure for crude oil, natural gas 
and  NGLs,  including  pipelines,  rail,  trucks  and  marine  transport.  Improved  access  to  global  markets, 
especially the  Midwest United  States and export shipping terminals on the west coast of Canada, could 
help  to  alleviate  the  downward  pressures  affecting  commodity  prices.  Several  proposals  have  been 
announced  to  increase  pipeline  capacity  out  of  Western  Canada  to  reach  Eastern  Canada,  the  United 
States and international markets via export terminals. While certain projects are proceeding, the regulatory 
approval  process  and  other  economic  and  socio-political  factors  related  to  transportation  and  export 
infrastructure has led to the delay, suspension or cancellation of many pipeline projects or their cancellation 
altogether. 

With respect to the current state of the transportation and exportation of crude oil from Western Canada to 
domestic  and  international  markets,  the  Enbridge  Line  3  Replacement  and  Expansion  from  Hardisty, 
Alberta, to Superior, Wisconsin, formerly expected to be in-service in late 2019, continues to experience 
permitting  difficulties  in  the  United  States.  The  Minnesota  portion  of  the  line  began  construction  in 
December  of  2020  with  opposition  parties  challenging  the  commencement  of  the  construction.  The 
Canadian portion of the pipeline began commercial operation on December 1, 2019. 

The Trans Mountain Pipeline expansion received Cabinet approval in November 2016. Following a period 
of sustained political opposition in British Columbia, the federal government entered into an agreement with 
Kinder Morgan Cochin  ULC  in  May  2018  to purchase the  shares  and units of the  entities that  own  and 
operate  the  Trans  Mountain  Pipeline  system.  The  shareholders  subsequently  voted  to  approve  the 

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transaction in August 2018. However, the Trans Mountain Pipeline expansion experienced a setback when, 
in August 2018, the Federal Court of Appeal identified deficiencies in the NEB’s environmental assessment 
and the Government’s Indigenous consultations. The Federal Court of Appeal quashed the accompanying 
certificate of public convenience and necessity and directed Cabinet to correct these deficiencies. Following 
the Federal Court of Appeal’s direction, Cabinet ordered the NEB to reconsider its recommendation in light 
of  the  Federal  Court  of  Appeal  decision,  including  the  environmental  effects  of  project-related  marine 
shipping.  On  February  22,  2019,  the  NEB  delivered  an  updated  report  to  Cabinet,  recommending  that 
Cabinet  approve  the  pipeline  expansion,  subject  to  156  conditions  and  16  new  recommendations, 
notwithstanding the fact that project-related marine shipping may have a significant adverse effect on the 
marine environment. On June 18, 2019, Cabinet approved the pipeline expansion, and on July 25, 2019, 
the  NEB  (now  the  CER)  outlined  how  the  regulatory  process  for  the  pipeline  expansion  would  resume. 
Construction  commenced  on  the  Trans  Mountain  Pipeline  in  late  2019,  and  is  proceeding  concurrently 
alongside  CER  hearings  with  landowners  and  affected  communities  to  determine  the  final  route  for  the 
Trans Mountain Pipeline. 

In  December  2019,  the  Federal  Court  of  Appeal  heard  a  judicial  review  application  brought  by  six 
Indigenous  applicants  challenging  the  adequacy  of  the  federal  government’s  further  consultation  on  the 
Trans  Mountain  Pipeline  expansion.  Two  First  Nations  subsequently  withdrew  from  the  litigation  after 
reaching  a  deal  with  Trans  Mountain.  On  February  4,  2020,  the  Federal  Court  of  Appeal  dismissed  the 
remaining four appellants’ application for judicial review, upholding the Cabinet’s second approval of the 
Trans Mountain Pipeline expansion from June 2019. 

On  January  16,  2020  the  Supreme  Court  of  Canada  unanimously  rejected  British  Columbia’s  appeal  to 
regulate  the flow of heavy  oil  in British Columbia.  The Supreme  Court found that interprovincial trade  is 
federal  jurisdiction  and  the  flow  of  commodities  such  as  heavy  oil  and  bitumen  should  be  overseen  by 
federal regulators. 

On April 25, 2018, the British Columbia Government submitted a reference question to the British Columbia 
Court  of  Appeal,  seeking  to  determine  whether  it  has  the  constitutional  jurisdiction  to  amend  the 
Environmental  Management  Act (the  BC EMA) to  impose a  permitting requirement on carriers of heavy 
crude oil within British Columbia. On January 16, 2020, the Supreme Court of Canada heard the Attorney 
General of British Columbia’s appeal. The Supreme Court unanimously dismissed the appeal and adopted 
the reasons of the British Columbia Court of Appeal. 

Construction commenced on the Trans Mountain Pipeline throughout 2020, however, the project was halted 
in December of 2020 resuming in January of 2021 with work commencing on the twinning of the existing 
1,500 km line between Alberta to British Columbia.  

While it was expected that construction on the Keystone XL Pipeline would commence in the first half of 
2019,  preconstruction  work  was  halted  in  late  2018  when  a  U.S.  Federal  Court  Judge  determined  the 
underlying  environmental  review  was  inadequate.  This  decision  has  been  appealed;  however,  in  March 
2019,  a  new  permit  was  issued  by  the  U.S.  Government  effectively  lifting  the  injunction  blocking 
construction.  In  August  2019,  the  Nebraska  Supreme  Court  affirmed  the  approval  of  the  Keystone  XL 
Pipeline application. Construction commenced on the Alberta portion of the pipeline in summer of 2020. 

The Alberta Government has invested $1.5 billion in the Keystone XL Pipeline to accelerate construction in 
the hopes of having it operational by 2023. The investment by the Alberta Government includes $1.5 billion 
in equity investment in 2020, followed by a $6 billion  loan guarantee in 2021. On January 20, 2021, the 
President of the United States revoked the permit for the Keystone XL Pipeline. Accordingly, unless a permit 
for the Keystone XL Pipeline is reissued, the project will not be completed. There is no indication that the 
position  of  the  current  President  of  the  United  States  with  respect  to  the  Keystone  XL  Pipeline  will  be 
reconsidered or reversed. 

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Bill  C-48,  the  Oil  Tanker  Moratorium  Act  (the  “OTMA”),  came  into  force  on  June  21,  2019.  The  OTMA 
imposes  a  moratorium  on  tanker  traffic  transporting  certain  crude  oil  and  NGLs  products  from  British 
Columbia’s north coast. The OTMA is subject to a review after five (5) years. See “Industry Conditions –
Environmental Regulation – Federal”. 

The  Government  of  Alberta  has  also  sought  to  alleviate  these  transportation  constraints  by  pursuing 
different transportation modalities and creating new markets. On February 19,  2019, the Government of 
Alberta announced that it would lease 4,400 rail cars capable of transporting 120,000 bbls/d of crude oil out 
of the province. Following the Alberta provincial election on April 16, 2019, the new United Conservative 
Party (“UCP”) Government announced that it was in negotiations to divest the rail contracts. On February 
12, 2020, the Government of Alberta announced that it had sold off $10.6 billion in crude-by-rail contracts 
to the private sector. In the Government of Alberta’s August 2020 fiscal update, it was reported the Alberta 
Government had lost $2.1 billion in crude-by-rail contracts. 

Natural gas prices in Alberta have also been constrained in recent years due to increasing North American 
supply, limited access to markets and limited storage capacity. While companies that secure firm access to 
transport their  natural gas production  out of Western Canada may be able to access more markets and 
obtain better pricing, other companies may be forced to accept spot pricing in Western Canada for their 
natural gas, which in the last several years has generally been depressed (at times producers have received 
negative pricing for their natural gas production). Required repairs or upgrades to existing pipeline systems 
have also led to further reduced capacity and apportionment of firm access, which in Western Canada may 
be further exacerbated by natural gas storage limitations. Additionally, while a number of LNG export plants 
have been proposed for the west coast of Canada, government decision-making, regulatory uncertainty, 
opposition from environmental and Indigenous groups, and changing market conditions have resulted in 
the cancellation or delay of many of these projects. In October 2018, the proponents of the LNG Canada 
liquefied natural  gas export  terminal announced  a  positive final investment decision to proceed  with the 
project. 

Legislation and Regulation 

The oil and natural gas industry is subject to extensive controls and regulations governing its operations 
(including  land  tenure,  exploration,  development,  production,  refining,  transportation  and  marketing) 
imposed by legislation enacted by various levels of government and with respect to pricing and taxation of 
oil and natural gas by agreements among the governments of Canada, Alberta and Saskatchewan, all of 
which should be carefully considered by investors in the oil and natural gas industry. It is not expected that 
any of these controls or regulations will affect the operations of Surge in a manner materially different than 
they would affect other oil and natural gas producers of similar size.  All current legislation is a matter of 
public record and Surge is unable to predict what additional legislation or amendments may be enacted. 
Some of the principal aspects of legislation, regulations and agreements governing the oil and natural gas 
industry are described further below. 

Pricing and Marketing – Oil 

The producers of oil are entitled to negotiate sales contracts directly with oil purchasers, with the result that 
the market determines the price of oil. Oil prices are primarily based on worldwide supply and demand. The 
specific  price  depends  in  part  on  oil  quality,  prices  of  competing  fuels,  distance  to  market,  the  value  of 
refined products, the supply/demand balance, and contractual terms of sale. Oil exporters are also entitled 
to enter into export contracts with terms not exceeding one year in the case of light crude oil and two years 
in the case of heavy crude oil, provided that an order approving such export has been obtained from the 
CER.  Any  oil  export  to  be  made  pursuant  to  a  contract  of  longer  duration  (to  a  maximum  of  25  years) 
requires an exporter to obtain an export licence from the CER and the issuance of such a licence requires 
a public hearing and the approval of the Governor in Council.   

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Pricing and Marketing – Natural Gas  

Alberta’s natural gas market has been deregulated since 1985. Supply and demand determine the price of 
natural gas and price is calculated at the sale point, being the wellhead, the outlet of a gas processing plant, 
on a gas transmission system such as the Alberta “NIT” (Nova Inventory Transfer), at a storage facility, at 
the inlet to a utility system or at the point of receipt by the consumer. Accordingly, the price for natural gas 
is  dependent  upon  such  producer’s  own  arrangements  (whether  long  or  short  term  contracts  and  the 
specific point of sale). As natural gas is also traded on trading platforms such as the Natural Gas Exchange 
(NGX), Intercontinental Exchange or the New York Mercantile Exchange (NYMEX) in the United States, 
spot and future prices can also be influenced by supply and demand fundamentals on these platforms. 

The price of natural gas is determined by negotiation  between buyers and sellers. Natural gas exported 
from Canada is subject to regulation by the CER and the Government of Canada.  Exporters are free to 
negotiate prices and other terms with purchasers, provided that the export contracts must continue to meet 
certain  other  criteria  prescribed  by  the  CER  and  the  Government  of  Canada.  Natural  gas  (other  than 
propane, butane and ethane) exports for a term of less than two years or for a term of two to 20 years (in 
quantities  of  not  more  than  30,000  m3/day),  must  be  made  pursuant  to  an  CER  order.  Any  natural  gas 
export  to  be  made  pursuant  to  a  contract of  longer duration  (to  a  maximum  of  25  years) or  for a  larger 
quantity requires an exporter to obtain an export licence from the CER and the issuance of such a licence 
requires a public hearing and the approval of the Governor in Council. 

The government of Alberta also regulates the volume of natural gas that may be removed from the province 
for consumption elsewhere based on such factors as reserve availability, transportation arrangements, and 
market  considerations.  Natural  gas  prices  in  Alberta  have  been  constrained  in  recent  years  due  to 
increasing supply in North America, limited access to markets and limited storage capacity. 

Curtailment 

On December 2, 2018, the Government of Alberta announced that, commencing January 1, 2019, it would 
mandate  an  8.7%  short-term  reduction  in  provincial  crude  oil  and  crude  bitumen  production.  As 
contemplated  in  the  Curtailment  Rules,  the  Government  of  Alberta  will,  on  a  monthly  basis,  direct  oil 
producers  producing  more  than  10,000  bbl/d  to  curtail  their  production  according  to  a  pre-determined 
formula that apportions production limits proportionately amongst those operators subject to a curtailment 
order.  The first curtailment order took effect on January 1, 2019 limiting province-wide production of crude 
oil and crude bitumen to 3.56 million bbl/d—a reduction of approximately 8.7% from the total daily average 
oil production in Alberta during December 2018As a result of decreasing price differentials and volumes of 
crude oil and crude bitumen in storage, the Government of Alberta announced on January 30, 2019, that it 
would  ease the  mandatory production  curtailment beginning  February  1,  2019,  increasing  the allowable 
production cap by 75,000 bbl/d to a maximum output of approximately 3.63 million bbl/d.  Surge is subject 
to  a  curtailment  order.    Starting  December  2020,  the  Government  of  Alberta  will  only  put  monthly  oil 
production limits into effect if emerging market conditions make it absolutely necessary. This means that 
industry is free to produce at their discretion for the foreseeable future. The Curtailment Rules are set to be 
repealed by December 31, 2021.   

The North American Free Trade Agreement 

The  North  American  Free  Trade  Agreement  (“NAFTA”)  among  the  governments  of  Canada,  the  United 
States and Mexico came into force on January 1, 1994. The three NAFTA signatories have been working 
towards replacing NAFTA. On November 30, 2018, Canada, Mexico, and the United States signed a new 
trade  agreement,  widely  referred  to  as  the  United  States  Mexico  Canada  Agreement  (“USMCA”), 
sometimes referred to as the Canada United States Mexico Agreement (“CUSMA”). Legislative bodies in 
the three signatory countries must ratify the USMCA before it comes into force. Mexico’s senate ratified the 
USMCA in June 2019. In late December 2019, the United States’ House of Representatives approved the 

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USMCA  and  the  USMCA  received  approval  from  the  United  States  Senate  on  January  16,  2020.  On 
January 29, 2020, the Government of Canada tabled Bill C-4 to ratify the USMCA. Bill C-4 received royal 
assent on March 13, 2020 and the USMCA entered into force on July 1, 2020. As the United States remains 
Canada’s primary trading partner and the largest international market for the export of crude oil, natural gas 
and NGL from Canada, the effects of the USMCA could have an impact on Western Canada’s petroleum 
and natural gas industry at large, including the Corporation’s business.  

Under  the  terms  of  NAFTA’s  Article  605,  a  proportionality  clause  prevents  Canada  from  implementing 
policies that limit exports to the United States and Mexico, relative to the total supply produced in Canada. 
Canada remains free to determine whether exports of energy resources to the United States or Mexico will 
be  allowed,  provided  that  any  export  restrictions  do  not:  (i)  reduce  the  proportion  of  energy  resources 
exported relative to the total supply of goods of Canada as compared to the proportion prevailing  in the 
most  recent  36  month  period;  (ii)  impose  an  export  price  higher  than  the  domestic  price  (subject  to  an 
exception with respect to certain measures which only restrict the volume of exports); and (iii) disrupt normal 
channels  of  supply.  Further,  all  three  signatory  countries  are  prohibited  from  imposing  a  minimum  or 
maximum price requirement on exports (where any other form of quantitative restriction is prohibited) and 
imports  (except  as  permitted  in  the  enforcement  of  countervailing  and  anti-dumping  orders  and 
undertakings). NAFTA also requires energy regulators to ensure the orderly and equitable implementation 
of any regulatory changes and to ensure that the application of such changes will cause minimal disruption 
to  contractual  arrangements  and  avoid  undue  interference  with  pricing,  marketing  and  distribution 
arrangements.  

The Government of Alberta’s curtailment program complies with NAFTA’s Article 605, under which Canada 
must make available a consistent proportion of the crude oil and bitumen produced to the other NAFTA 
signatories. As a result of the proportionality rule, reducing Canadian supply reduced the required offering 
under NAFTA, with the result that the amount of crude oil and  bitumen that Canada is required to offer, 
while Canadian crude oil prices are depressed, may be reduced.  

The  USMCA  does  not  contain  the  proportionality  rules  of  NAFTA’s  Article  605.  The  elimination  of  the 
proportionality clause removes a barrier in Canada’s transition to a more diversified export portfolio. While 
diversification depends on the construction of infrastructure allowing more Canadian production to reach 
Eastern Canada, Asia, and Europe, the USMCA may allow for greater export diversification than currently 
exists under NAFTA.  

Other Trade Agreements 

Canada has also pursued a number of other international free trade agreements with other countries around 
the  world.  As  a  result,  a  number  of  free  trade  or  similar  agreements  are  in  force  between  Canada  and 
certain other countries while in other circumstances Canada has been unsuccessful in its efforts. Canada 
and the European Union recently agreed to the Comprehensive Economic and Trade Agreement (“CETA”), 
which provides for duty-free, quota-free market access for Canadian crude oil and natural gas products to 
the European Union. Although CETA remains subject to ratification by 14 of the 28 national legislatures in 
the European Union, provisional application of CETA commenced on September 21, 2017. In light of the 
United Kingdom’s official departure from the European Union on January 31, 2020, CETA ceased to apply 
to  Canada-United  Kingdom  Trade  on  January  1,  2021.  The  Canada-United  Kingdom  Trade  Continuity 
Agreement (“Canada-UK TCA”) replicates the CETA on a bilateral basis and is meant to maintain the status 
quo of in the Canada-United Kingdom trade relationship.  

Canada and ten other countries have agreed on the text of the Comprehensive and Progressive Agreement 
for Trans-Pacific Partnership (“CPTPP”), which is intended to allow for preferential market access among 
the countries that are parties to the CPTPP. The CPTPP is in force among the first seven countries to ratify 
the  agreement  –  Canada,  Australia,  Japan,  Mexico,  New  Zealand,  Vietnam,  and  Singapore.  While  it  is 
uncertain what effect CETA, CPTPP, or any other trade agreements will have on the petroleum and natural 

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gas industry in Canada, the lack of available infrastructure for the offshore export of crude oil and natural 
gas  may  limit  the  ability  of  Canadian  crude  oil  and  natural  gas  producers  to  benefit  from  such  trade 
agreements. 

Extractive Sector Transparency Measures Act 

The Extractive Sector Transparency Measures Act (“ESTMA”), a federal regime for the mandatory reporting 
of payments to government, came into force on June 1, 2015. ESTMA contains broad reporting obligations 
with respect to payments to governments and state owned entities, including employees and public office 
holders, made Canadian businesses involved in resource extraction. Under ESTMA, all payments made to 
payees (broadly defined to include any government or state owned enterprise) must be reported annually 
if the aggregate of all payments in a particular category to a particular payee exceeds $100,000 per financial 
year.  The  categories  of  payments  include  taxes,  royalties,  fees,  bonuses,  dividends  and  infrastructure 
improvement payments. Failure to comply with the reporting obligations under ESTMA are punishable upon 
summary conviction with a fine of up to $250,000. In addition, each day that passes prior to a non-compliant 
report being corrected forms a new offence, and therefore, a payment that goes unreported for a year could 
result in over $9,000,000 in total liability. 

Provincial Royalties and Incentives 

General 

In  addition  to  federal  regulation,  each  province  has  legislation  and  regulations  that  govern  land  tenure, 
royalties, production rates, environmental protection and other matters. The royalty regime is a significant 
factor  in  the  profitability  of  crude  oil,  natural  gas,  natural  gas  liquids  and  sulphur  production.  Royalties 
payable  on  production  from  lands  other  than  Crown  lands  are  determined  by  negotiations  between  the 
mineral  owner  and  the  lessee,  although  production  from  such  lands  is  also  subject  to  certain  provincial 
taxes and royalties. Operations not on Crown lands and subject to the provisions of specific agreements 
are also usually subject to royalties negotiated between the mineral owner and the lessee. These royalties 
are  not  eligible  for  incentive  programs  sponsored  by  various  governments  as  discussed  below.  Crown 
royalties are determined by governmental regulation and are generally calculated as a percentage of the 
value  of  the  gross  production.  The  rate  of  royalties  payable  generally  depends  in  part  on  prescribed 
reference prices, well productivity, geographical location, field discovery date, method of recovery and the 
type or quality of the petroleum product produced. Other royalties and royalty-like interests are from time 
to time carved out of the working interest owner’s interest through non-public transactions. These are often 
referred to as overriding royalties, gross overriding royalties, net profits interests or net carried interests. 

From  time  to  time  the  governments  of  the  Western  Canadian  provinces  have  established  incentive 
programs for exploration and development. Such programs often provide for royalty rate reductions, royalty 
holidays  and  tax  credits  for  the  purpose  of  encouraging  oil  and  natural  gas  exploration  or  enhanced 
recovery  projects.  The  programs  are  designed  to  encourage  exploration  and  development  activity  by 
improving earnings and cash flow within the industry. 

In addition, the federal government may from time to time provide incentives to the oil and gas industry. In 
November of 2018, the federal government announced its plans to implement an accelerated investment 
incentive,  which  will  provide  oil  and  gas  businesses  with  eligible  Canadian  development  expenses  and 
Canadian oil and gas property expenses with a first year deduction of one and a half times the deduction 
that is otherwise available. The federal government also announced in late 2018 that it will make $1.6 billion 
available  to  the  oil  and  natural  gas  industry  in  light  of  worsening  commodity  price  differentials.  The  aid 
package, however, is mostly in the form of loans and is earmarked for crude oil and natural gas projects 
related  to  economic  diversification  as  well  as  direct  funding  for  clean  growth  crude  oil  and  natural  gas 
projects. 

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Producers and working interest owners of crude oil and natural gas rights may also carve out additional 
royalties or royalty-like interests through non-public transactions, which include the creation of instruments 
such as overriding royalties, net profits interests and net carried interests. 

Alberta  

Producers of oil and natural gas from Crown lands in Alberta are required to pay annual rental payments, 
currently at a rate of $3.50 per hectare, and make monthly royalty payments in respect of oil and natural 
gas produced from Crown Lands.  Producers of oil and natural gas from Crown lands in Alberta are also 
required to pay a royalty on substances produced from Crown lands. 

On May 27, 2010, the Government of Alberta announced changes to the existing royalty framework under 
the  Petroleum  Royalty  Regulation,  2009  and  the  Natural  Gas  Royalty  Regulation,  2009  which  became 
effective January 1, 2011 (the “Alberta Royalty Framework”).  Changes include making the Natural Gas 
Deep  Drilling  Program,  which  adjusts  the  royalties  for  deep  gas  wells,  a  permanent  initiative  under  the 
Alberta Royalty Framework.  Qualifying wells under the Natural Gas Deep Drilling Program include natural 
gas wells with gas-oil ratios of greater than 1,800:1 which have been spud or deepened on or after May 1, 
2010 and have a true vertical depth greater than 2,000 metres.  An Emerging Resources and Technologies 
Initiative has also been created to encourage new exploration and development from higher cost and more 
technically  challenging  resources,  such  as  shale  gas,  coal  seams  and  horizontal  oil  and  gas  wells.  In 
particular, pursuant to the Emerging Resource and Technologies Initiative: (a) coalbed methane wells will 
receive a maximum royalty rate of 5 percent for 36 producing months on up to 750 MMcf of production, 
retroactive to wells that began producing on or after May 1, 2010; (b) shale gas wells will receive a maximum 
royalty rate of 5 percent for 36  producing months with no limitation on production  volume, retroactive to 
wells that began producing on or after May 1, 2010; (c) horizontal gas wells will receive a maximum royalty 
rate  of  5  percent  for  18  producing  months  on  up  to  500  MMcf  of  production,  retroactive  to  wells  that 
commenced drilling on or after May 1, 2010; and (d) horizontal oil wells and horizontal non-project oil sands 
wells will receive a maximum royalty rate of 5 percent with volume and production month limits set according 
to the depth (including the horizontal distance) of the well, retroactive to wells that commenced drilling on 
or after May 1, 2010.  

On  January  29,  2016,  the  Alberta  government  announced  changes  to  the  Alberta  Royalty  Framework.  
Under the new modern royalty framework (the “MRF”), the sliding scale royalty concept will be maintained, 
but will be achieved with a greater degree of simplicity. The new royalty percentage will be applied to the 
gross revenue generated from all hydrocarbons, with no differentiation between produced substances, and 
wells will be charged a flat 5 percent royalty rate until revenues exceed a normalized well cost allowance, 
which  will be based on vertical well depth and  lateral length. The calculation of this cost allowance, and 
other details regarding the various parameters within the new formula under the MRF was announced in 
2016  and  was  fully  implemented  as  of  January  1,  2017.    Prior  to  January  1,  2017,  the  former  royalty 
framework continued to apply to any wells drilled prior to that date, and thereafter for a period of 10 years 
following which, such wells will be transitioned into the MRF.  

In addition to any negotiated royalty amount payable to the freehold mineral owner, producers of oil and 
natural gas from freehold lands in Alberta are required to pay annual freehold mineral taxes. The freehold 
mineral tax is a tax levied by the Government of Alberta on the value of oil and natural gas production from 
non-Crown lands and is derived from the Freehold Mineral Rights Tax Act (Alberta). The freehold mineral 
tax  is  levied  on  an  annual  basis  on  calendar  year  production  using  a  tax  formula  that  takes  into 
consideration, among other things, the amount of production, the hours of production, the value of each 
unit of production, the tax rate and the percentages that the owners hold in the title. The basic formula for 
the  assessment  of  freehold  mineral  tax  is:  revenue  less  allocable  costs  equals  net  revenue  divided  by 
wellhead production equals the value based upon unit of production. If payors do not wish to file individual 
unit values, a default price is supplied by the Crown. On average, the tax levied is 4 percent of revenues 
reported from fee simple mineral title properties. 

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On July 18, 2019, the Government of Alberta enacted the Royalty Guarantee Act to provide certainty that 
no major changes will be made to the current oil and gas royalty structure for a period of at least 10 years. 
The  Royalty  Guarantee  Act  also  confirms  that  the  transition  to  the  MRF  for  wells  drilled  on  or  before 
December 31, 2016 will occur as planned in 2026. 

Any changes to the royalty regime in  Alberta  may  have  a  material  effect  on  Surge.  See  “Risk Factors -  
Royalty Regimes.” 

Saskatchewan  

In  Saskatchewan,  the  amount  payable  as  a  Crown  royalty  or  a  freehold  production  tax  in  respect  of  oil 
depends on the type and vintage of oil, the quantity of oil produced in a month, the value of the oil produced 
and specified adjustment factors determined monthly by the provincial government.  

For  Crown  royalty  and  freehold  production  tax  purposes,  conventional  oil  is  divided  into  “types”,  being 
“heavy  oil”,  “southwest  designated  oil”  or  “non-heavy  oil  other  than  southwest  designated  oil”.  The 
conventional royalty and production tax classifications (“fourth tier oil”, “third tier oil”, “new oil” and “old oil”) 
depend on the finished drilling date of a well and are applied to each of the three crude oil types slightly 
differently.  

Heavy oil is classified as third tier oil (produced from a vertical well having a finished drilling date on or after 
January 1, 1994 and before October 1, 2002 or incremental oil from new or expanded water flood projects 
with a commencement date on or after January 1, 1994 and before October 1, 2002), fourth tier oil (having 
a finished  drilling  date on  or after October 1,  2002 or incremental oil from new or expanded water flood 
projects with  a commencement date on or after October 1, 2002) or new oil (conventional oil that is not 
classified  as  “third  tier  oil”  or  “fourth  tier  oil”).  Southwest  designated  oil  means  oil  produced  within  the 
southwest area that is produced from an oil or gas well with a finished drilling date on or after February 9, 
1998 or incremental waterflood oil that commenced operation after February 9, 1998. Southwest designated 
oil uses the same definition of fourth tier oil but third tier oil is defined as conventional oil produced from a 
vertical  well  having  a  finished  drilling  date  on  or  after  February  9,  1998  and  before  October  1,  2002  or 
incremental oil from new or expanded water flood projects with a commencement date on or after February 
9, 1998 and before October 1, 2002, and new oil is defined as conventional oil produced from a horizontal 
well having a finished drilling date on or after February 9, 1998 and before October 1, 2002.  For non-heavy 
oil other than southwest designated oil, the same classification as heavy oil is used but new oil is defined 
as conventional oil produced from a vertical well completed after 1973 and having a finished drilling date 
prior to 1994, conventional oil produced from a horizontal well having a finished drilling date on or after April 
1, 1991 and before October 1, 2002, or incremental oil from new or expanded water flood projects with a 
commencement date on or after January 1, 1974 and before 1994 whereas old oil is defined as conventional 
oil not classified as third or fourth tier oil or new oil.  

Production tax rates for freehold production are determined by first determining the Crown royalty rate and 
then subtracting the “Production Tax Factor” (“PTF”) applicable to  that classification of  oil.  Currently the 
PTF is 6.9 for “old oil”, 10.0 for freehold “new oil” and freehold “third tier oil” and 12.5 for freehold “fourth 
tier oil”.  The minimum rate for freehold production tax is zero. 

Base prices are used to establish lower limits in the price-sensitive royalty structure for conventional oil and 
apply at various reference well production rates (m3 per month) for old oil, new oil, third tier oil and fourth 
tier oil.  Where average wellhead prices are below the established base prices of $100 per m3 for third and 
fourth tier oil and $50 per m3 for new oil and old oil, base royalty rates are applied. Base royalty rates are 5 
percent for all fourth tier oil, 10 percent for heavy oil that is third tier oil or new oil, 12.5 percent for southwest 
designated oil that is third tier oil or new oil, 15 percent for non-heavy oil other than southwest designated 
oil that is third tier or new oil, and 20 percent for old oil.  Where average wellhead prices are above base 

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prices, marginal royalty rates are applied to the proportion of production that is above the base oil price.  
Marginal royalty rates are 30 percent for all fourth tier oil, 25 percent for heavy oil that is third tier oil or new 
oil, 35 percent for southwest designated oil that is third tier oil or new oil, 35 percent for non-heavy oil other 
than southwest designated oil that is third tier or new oil, and 45 percent for old oil. 

The amount payable as a Crown royalty or a freehold production tax in respect of natural gas production is 
determined  by  a  sliding  scale  based  on  the  monthly  provincial  average  gas  price  published  by  the 
Saskatchewan government (effective February 1, 2012), the quantity produced in a given month, the type 
of natural gas, and the classification of the natural gas. Like conventional oil, natural gas may be classified 
as “non-associated gas” (gas produced from gas wells) or “associated gas” (gas produced from oil wells) 
and  royalty  rates  are  determined  according  to  the  finished  drilling  date  of  the  respective  well.    Non-
associated gas is classified as new gas (having a finished drilling date before February 9, 1998 with a first 
production  date  on  or  after  October  1,  1976),  third  tier  gas  (having  a  finished  drilling  date  on  or  after 
February 9, 1998 and before October 1, 2002), fourth tier gas (having a finished drilling date on or after 
October  1,  2002)  and  old  gas  (not  classified  as  either  third  tier,  fourth  tier  or  new  gas).    A  similar 
classification is used for associated gas except that the classification of old gas is not used, the definition 
of fourth tier gas also includes production from oil wells with a finished drilling date prior to October 1, 2002, 
where the individual oil well has a gas-oil production ratio in any month of at least 3,500 m3 of gas for every 
m3 of oil, and new gas is defined as oil produced from a well with a finished drilling date before February 9, 
1998 that received special approval, prior to October 1, 2002, to produce oil and gas concurrently without 
gas-oil ratio penalties. 

On December 9, 2010, the Government of Saskatchewan enacted the Freehold Oil and Gas Production 
Tax Act, 2010 with the intention to facilitate the efficient payment of freehold production taxes by industry. 
Two  new  regulations  with  respect  to  this  legislation  are:  (i)  The  Freehold  Oil  and  Gas  Production  Tax 
Regulations, 2012 which sets out the terms and conditions under which the taxes are calculated and paid; 
and (ii) The Recovered Crude Oil Tax Regulations, 2012 which sets out the terms and conditions under 
which taxes on recovered crude oil that was delivered from a crude oil recovery facility on or after March 1, 
2012 are to be calculated and paid. 

Base royalty rates are 5 percent for all fourth tier gas, 15 percent for third tier or new gas, and 20 percent 
for old gas. Where average well-head prices are above base prices, marginal royalty rates are applied to 
the proportion of production that is above the base gas price. Marginal royalty rates are 30 percent for all 
fourth tier gas, 35 percent  for third tier and new gas, and 45 percent for old gas. The current regulatory 
scheme  provides  for  certain  differences  with  respect  to  the  administration  of  fourth  tier  gas  which  is 
associated gas. 

The  Government  of  Saskatchewan  currently  provides  a  number  of  targeted  incentive  programs.  These 
include both royalty reduction and incentive volume programs, including the following: 

  Royalty/Tax Incentive Volumes for Vertical Oil Wells Drilled on or after October 1, 2002 providing 
reduced Crown royalty (a Crown royalty rate of the lesser of “fourth tier oil” Crown royalty rate and 
2.5  percent)  and  freehold  tax  rates  (a  freehold  production  tax  rate  of  0  percent)  on  incentive 
volumes of 8,000 m3 for deep development  vertical oil wells,  4,000 m3 for non-deep exploratory 
vertical oil wells and 16,000 m3 for deep exploratory vertical oil wells (more than 1,700 metres or 
within  certain  formations)  and  after  the  incentive  volume  is  produced,  the  oil  produced  will  be 
subject to the “fourth tier” royalty tax rate; 

  Royalty/Tax  Incentive  Volumes  for  Exploratory  Gas  Wells  Drilled  on  or  after  October  1,  2002 
providing reduced Crown royalty (a Crown royalty rate of the lesser of “fourth tier oil” Crown royalty 
rate and 2.5 percent) and freehold tax rates (a freehold production tax rate of 0 percent) on incentive 
volumes of 25,000,000 m3 for qualifying exploratory gas wells; 

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  Royalty/Tax Incentive Volumes for Horizontal Oil Wells Drilled on or after October 1, 2002 providing 
reduced Crown royalty (a Crown royalty rate of the lesser of “fourth tier oil” Crown royalty rate and 
2.5  percent)  and  freehold  tax  rates  (a  freehold  production  tax  rate  of  0  percent)  on  incentive 
volumes of 6,000 m3 for non-deep horizontal oil wells and 16,000 m3 for deep horizontal oil wells 
(more than  1,700 metres total vertical depth  or within certain formations) and after the  incentive 
volume is produced, the oil produced will be subject to the “fourth tier” royalty tax rate; 

  Royalty/Tax Incentive Volumes for Horizontal Gas Wells drilled on or after June 1, 2010 and before 
April  1,  2013  providing  for  a  classification  of  the  well  as  a  qualifying  exploratory  gas  well  and 
resulting in a reduced Crown royalty (a Crown royalty rate of the lesser of “fourth tier oil” Crown 
royalty rate and 2.5 percent) and freehold tax rates (a freehold production tax rate of 0 percent) on 
incentive  volumes  of  25,000,000  m3  for  horizontal  gas  wells  and  after  the  incentive  volume  is 
produced, the gas produced will be subject to the “fourth tier” royalty tax rate;  

  Royalty/Tax  Regime  for  Incremental  Oil  Produced  from  New  or  Expanded  Waterflood  Projects 
Implemented  on  or  after  October  1,  2002  whereby  incremental  production  from approved  water 
flood  projects  is  treated  as  fourth  tier  oil  for  the  purposes  of  Crown  royalty  and  freehold  tax 
calculations;  

  Royalty/Tax  Regime  for  Enhanced  Oil  Recovery  Projects  (Excluding  Waterflood  Projects) 
Commencing prior to April 1, 2005 providing lower Crown royalty and freehold tax determinations 
based in part on the profitability of EOR projects during and subsequent to the payout of the EOR 
operations;  

  Royalty/Tax  Regime  for  Enhanced  Oil  Recovery  Projects  (Excluding  Waterflood  Projects) 
Commencing on or after April 1, 2005 providing a Crown royalty of 1 percent of gross revenues on 
EOR  projects  pre-payout  and  20  percent  of  EOR  operating  income  post-payout  and  a  freehold 
production tax of 0 percent pre-payout and 8 percent post-payout on operating income from EOR 
projects; and  

  Royalty/Tax  Regime  for  High  Water-Cut  Oil  Wells  designed  to  extend  the  producing  lives  and 
improve the recovery rates of high water-cut oil wells and granting “third tier oil” royalty/tax rates 
with a Saskatchewan Resource Credit of 2.5 percent for oil produced prior to April 2013 and 2.25 
percent  for  oil  produced  on  or  after  April  1,  2013  to  incremental  high  water-cut  oil  production 
resulting  from  qualifying  investments  made  to  rejuvenate  eligible  oil  wells  and/or  associated 
facilities.  

On  June  22,  2011,  the  Government  of  Saskatchewan  released  the  Upstream  Petroleum  Industry 
Associated Gas Conservation Standards, which are designed to reduce emissions resulting from the flaring 
and venting of associated gas (the “Associated Natural Gas Standards”). The Associated Natural Gas 
Standards were jointly developed with industry and the implementation of such standards commenced on 
July  1,  2012  for  new  wells  and  facilities  licensed  on  or  after  such  date.  The  new  standards  apply  to  all 
existing licensed wells and facilities as of July 1, 2015. 

Effective April 1, 2014, the Saskatchewan Ministry of the Economy streamlined fees related to licenses and 
applications  in  the  oil  and  gas  sector  by  eliminating  10  different  licensing  fees,  which  resulted  in  an 
aggregate of 20,000 fee transactions per year, and replacing them with a single annual levy based on a 
company’s production and number of wells.  While the fees have been streamlined, approvals to conduct 
the relevant activities are still required.  These changes to the fee structure are part of ongoing work by the 
Government of Saskatchewan to streamline the licensing, regulation and monitoring processes in the oil 
and gas sector. 

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Climate Change Regulation 

Federal  

Canada is a signatory to the United Nations Framework Convention on Climate Change (the “UNFCCC”), 
which  was entered into in  order work towards stabilizing atmospheric concentrations of greenhouse  gas 
(“GHG”) emissions at a level to prevent “dangerous anthropogenic interference with the climate system”. 
The UNFCCC came into force on March 21, 1994. On December 12, 2015, the UNFCCC adopted the Paris 
Agreement,  which  Canada  ratified  on  October  5,  2016.  Under  the  Paris  Agreement,  countries  have 
committed to an ambitious goal of holding the increase in global average temperature to well below 2°C 
above pre-industrial levels, while they pursue efforts to limit the temperature increase to 1.5°C above pre-
industrial levels. To date, 189 of the 197 parties to  the convention have ratified the Paris Agreement. In 
December 2018, the United Nations annual Conference of the Parties took place in Katowice, Poland. The 
Conference concluded with the attendees reiterating their commitment to the targets set out in the Paris 
Agreement  and  establishing  a  transparency  framework  related  to,  among  other  matters,  emissions  and 
climate finance reporting. 

In May 2015, Canada submitted its Intended Nationally Determined Contribution (“INDC”) to the UNFCCC 
Secretariat, pledging a 30 percent reduction from 2005 levels—approximately 523 Mt—by 2030. In addition, 
provincial/territorial and federal leaders met and agreed that they would work together to build a national 
climate change plan.  At a follow-up meeting of the First Ministers and Prime Minister on March 3, 2016, 
the  parties  agreed  under  the  Vancouver Declaration  on Clean Growth  and Climate Change to launch a 
process  to  develop  the  Pan-Canadian  Framework  on  Clean  Growth  and  Climate  Change  (the 
“Framework”),  which was released on December 9, 2016 at  the First Ministers  meeting.  Saskatchewan 
was the only province that decided not to adopt the Framework.  

Prior to the release of the Framework, the federal government announced in October 2016 that it will set a 
minimum price on carbon starting at $10 per tonne of CO2e in 2018, which will increase by $10 per year 
until it reaches $50 per tonne of CO2e by 2022. On January 1, 2019, the federal government enacted the 
Greenhouse Gas  Pollution Pricing Act (the “GGPPA”). This regime  has two  parts: an emissions trading 
system  for  large  industry  and  a  regulatory  fuel  charge  imposing  an  initial  price  of  $20/tonne  of  GHG 
emissions. Under current federal plans, this price will escalate by $10 per year until it reaches a price of 
$50/tonne in 2022. Starting April 1, 2020, the minimum price permissible under the GGPPA is $30/tonne of 
GHG emissions. This approach will be reviewed in 2022 to confirm the path forward, including continued 
increases in stringency. Under the federal plan, each province and territory will be required to implement 
carbon pricing in its jurisdiction by 2018, whether in the form of a carbon tax or a cap-and-trade system. If 
the carbon price in a jurisdiction does not meet the federal minimum price, the federal government will step 
in and impose a carbon price that makes up the difference and return the revenue to the province or territory. 
In addition, provincial and territorial goals for reducing emissions must be at least as stringent as federal 
targets.  

The pricing systems in Quebec, Nova Scotia, the Northwest Territories and British Columbia continue to 
meet  the  federal  benchmark  requirements  on  stringency  and  the  provincial  systems  in  place  in  Prince 
Edward Island, Alberta and Saskatchewan meet the requirements for the emission sources they cover. The 
Federal  backstop  supplements  the  provincial  systems  by  applying  to  other  sources  that  the  provincial 
systems  do  not  cover.  New  Brunswick’s  carbon  price  system  took  effect  on  April  1,  2020.  The  federal 
backstop is in place currently in Ontario, Manitoba, Yukon and Nunavut.  

Alberta,  Saskatchewan,  and  Ontario  have  challenged  the  constitutionality  of  the  federal  government’s 
pricing regime. The Saskatchewan and Ontario references advanced in parallel where the appeal Courts 
ruled in favour of the constitutionality of the GGPPA. The reference put before the Alberta Court of Appeal 
was found in favour of Alberta and found the GGPPA as unconstitutional. Each of the Attorney Generals of 

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Saskatchewan, Ontario and Canada (in respect of the Alberta Court of Appeal decision) appealed these 
decisions to the Supreme Court of Canada (“SCC”). The SCC heard the three appeals together over two 
days in September of 2020. Following the two-day hearing, the SCC reserved their right to make a decision 
at that time. A decision is expected for early 2021. The Attorney General of Manitoba also appeared before 
the Federal Court in December of 2020 to challenge whether the federal government properly exercised its 
constitutional authority under the GGPPA to reject Manitoba’s climate change plan. A decision has not been 
rendered on that matter.    

In  October  2018,  the  federal  government  announced  an  alternative  pricing  scheme  for  large  electricity 
generators designed to incentivize a reduction in emissions intensity, rather than encouraging a reduction 
in generation rates. 

On April 26, 2018, the federal government passed the Regulations Respecting Reduction in the Release 
of  Methane  and  Certain  Volatile  Organic  Compounds  (Upstream  Oil  and  Gas  Sector)  (the  “Federal 
Methane Regulations”). The Federal Methane Regulations seek to reduce emissions of methane from the 
crude oil and natural gas sector, but will not come into force until January 1, 2020. By introducing a number 
of  new  control  measures,  the  Federal  Methane  Regulations  aim  to  reduce  unintentional  leaks  and 
intentional  venting  of  methane,  as  well  as  ensuring  that  crude  oil  and  natural  gas  operations  use  low-
emission equipment and processes. Among other things, the Federal Methane Regulations limit how much 
methane upstream oil and gas facilities are permitted to vent. These facilities would need to capture the 
gas and either re-use it, re-inject it, send it to a sales pipeline, or route it to a flare. In addition, in provinces 
other  than  Alberta  and  British  Columbia  (which  already  regulate  such  activities),  well  completions  by 
hydraulic  fracturing  would  be  required  to  conserve  or  destroy  gas  instead  of  venting.  The  federal 
government anticipates that these actions will reduce annual GHG emissions by about 20 Mt by 2030. 

In  March  2016,  a  Joint  Statement  on  Climate,  Energy,  and  Arctic  Leadership  was  issued.  This  joint 
statement  sets  out  specific  commitments  on  energy  development,  environmental  protection,  and  Arctic 
leadership. In particular, Canada and the US have made commitments to reduce methane emissions by 
40-45 percent below 2012 levels by 2025 from the oil and gas sector, finalize and implement the second 
phase of an aligned GHG emission standard for post-2018 model year on-road heavy duty vehicles, phase 
out fossil fuel subsidies, accelerate clean energy development and foster sustainable energy development. 

In  December  2017,  Environment  and  Climate  Change  Canada  (“ECCC”)  published  its  updated 
requirements  and  step-by-step  reporting  instructions  in  advance  of  the  2017  reporting  period  under  the 
federal  Greenhouse  Gas  Reporting  Program  (“GHGRP”).  The  Notice  with  respect  to  reporting  of 
greenhouse gases for 2017, which was published on December 30, 2017 in Part I of the Canada Gazette, 
outlines the 2017 reporting requirements for GHG-emitting facilities. In December 2017, ECCC published 
its updated requirements and step-by-step reporting instructions in advance of the 2017 reporting period 
under the GHGRP. Starting with the 2017 reporting year, the GHGRP will apply to a wider range of GHG 
emitting operations in Canada, as the reporting threshold was lowered from 50,000 tonnes to 10,000 tonnes 
of CO2e. All facilities that emitted the equivalent of 10,000 tonnes of CO2e in 2017 were required to submit 
a report by June 1, 2018. 

In  November  2016,  the  federal  government  announced  that  it  would  commence  development  of  a 
performance-based clean fuel standard (“CFS”) that would incent the use of a broad range of low carbon 
fuels, energy sources and technologies. The objective of the CFS is to achieve 30 Mt of annual reductions 
in GHG emissions by 2030, as part of efforts to achieve Canada’s commitments under the Paris Agreement. 
On December 13, 2017, ECCC published a regulatory framework on the CFS, which outlines the key design 
elements for the CFS regulation, including its scope, regulated parties, carbon intensity approach, timing, 
and potential compliance options such as credit trading. On December 18, 2020, the Federal Government 
published proposed CFS regulations, the final regulations of which are expected to be published in 2021 
with the CFS regulations scheduled to come into force in 2022.  

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The  proposed  CFS  regulations  take  a  performance-based  approach  to  reducing  greenhouse  gas 
emissions. The CFS regulations require suppliers of liquid fuels, such as gasoline, diesel and kerosene to 
gradually cut the amount of carbon in their product. It is the goal of the program to incentivize innovation 
and  adoption  of  clean  technologies  while  giving  fuel  suppliers  the  ability  meet  requirements  in  a  cost-
effective  way  that  works  for  their  business.  The  proposed  regulations  also  offer  compliance  credits  to 
incentive industries to innovate and adopt cleaner technologies to lower their compliance costs.   

On November 19, 2020, the Federal Government announced Bill C-12, An Act respecting transparency and 
accountability in Canada’s efforts to achieve net-zero greenhouse gas emissions by the year 2050. Canada 
joins over 120 countries in committing to net-zero emissions by 2050, including the UK, Germany, France 
and Japan. Once passed, Bill C-12 will legally bind the federal government to a process to achieve net-
zero emissions by 2050. The legislation will, among other things, set rolling five-year emissions-reduction 
targets (starting in 2030) and require plans to reach each target on a reporting basis and enshrine greater 
accountability  and  public  transparency  into  Canada’s  plan  for  meeting  net-zero  emission  by  2050  by 
providing  for  independent  third-party  review  by  the  Commissioner  of  the  Environment  and  Sustainable 
Development.  

Surge will continue to monitor the policies of the Government of Canada and any resulting legislation with 
respect to GHG emissions.  The US Environmental Protection Agency (“EPA”) is proceeding to regulate 
GHGs under the Clean Air Act. This EPA action is subject to legal and political challenges, the outcome of 
which cannot be predicted. The ultimate form of Canadian regulation is anticipated to be strongly influenced 
by the regulatory decisions made within the United States. Various states have enacted or are evaluating 
low carbon fuel standards, which may affect access to market for crude oils with higher emissions intensity. 

Alberta  

Alberta’s Climate Leadership Plan was introduced in November 2015 with the following policy objectives: 
(i)  putting  a  price  on  GHG  emissions;  (ii)  phasing  out  coal-generated  electricity  by  2030;  (iii)  having  30 
percent of electricity be generated from renewable sources by 2030; (iv) capping oil sands emissions to 
100 Mt per year; and (v) reducing methane emissions by 45 percent by 2025. 

On  January  1,  2018,  the  Carbon  Competitiveness  Incentive  Regulation  (“CCI  Regulation”)  replaced 
the Specified Gas Emitters Regulation. Under the CCI Regulation, facilities were allowed to emit a certain 
amount of GHG, free of charge from the carbon levy. The CCI Regulation applied to facilities that emitted 
100,000 tonnes or more of GHG in 2003, or a subsequent year. Under the CCI Regulations, a facility would 
receive performance credits if its GHG emissions are less than the amount freely permitted. If its emissions 
were above the amount freely permitted, they were required take one or more of the following actions to 
bring the facility into compliance: 

  make improvements at their facility to reduce emissions intensity; 

  use  emission  performance  credits  generated  at  facilities  that  achieve  more  than  the  required 

reductions; 

  purchase Alberta-based carbon offset credits; or 

 

contribute to Alberta’s Climate Change and Emissions Management Fund. 

Emissions  from  the  oil  sands  sector  (which  account  for  approximately  one-quarter  of  Alberta’s  annual 
emissions) have been capped at 100 Mt per year. This cap has been legislated in the Oil Sands Emissions 
Limit  Act  (Bill  25),  which  was  introduced  on  December  14,  2016.  The  legislation  contemplates  certain 

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exceptions  in  respect  of  cogeneration  emissions,  upgrading  emissions,  and  potential  discretionary 
exemptions by regulation (likely to accommodate new technological developments).  

In June 2019, the Government of Alberta pivoted in its implementation of the Climate Leadership Plan and 
repealed the Climate Leadership Plan. The Carbon Competitiveness Incentives Regime (“CCIR”) remained 
in place. As a result, the federally imposed fuel charge took effect in Alberta on January 1, 2020, at a rate 
of $20/tonne. In accordance with the GGPPA, this will increase to $30/tonne on April 1, 2020. However, on 
December  4,  2019,  the  federal  government  approved  Alberta’s  proposed  Technology  Innovation  and 
Emissions Reduction (“TIER”) regulation intended to replace the CCIR, so the regulation of emissions from 
heavy industry remains subject to provincial regulation, while the federal fuel charge still applies. The TIER 
regulation came into effect on January 1, 2020.  

The  TIER  regulation  operates  differently  than  the  former  facility-based  CCIR,  and  instead  applies  to 
industrywide to emitters that emit more than 100,000 tonnes of CO2e per year in 2016 or any subsequent 
year.  The  2020  target  for  most  TIER-regulated  facilities  is  to  reduce  emissions  intensity  by  10%  as 
measured against that facility’s individual benchmark (which is, generally, its average emissions intensity 
during the period from 2013 to 2015), with a further 1% reduction for each subsequent year. The facility-
specific benchmark does not apply to all facilities. Certain facilities, such as those in the electricity sector, 
are compared against the good-as-best gas standard, which measures against the emissions produced by 
the cleanest natural gas-fired generation system. Similarly, for facilities that have already made substantial 
headway in reducing their emissions, a different “high-performance” benchmark is available to ensure that 
the cost of ongoing compliance takes this into account. Similar to the CCIR, the TIER regulation targets 
emissions intensity rather than total emissions. Under the TIER regulation, facilities in high-emitting sectors 
can opt-in to the program despite the fact that they do not meet the 100,000 tonne threshold. A facility can 
opt-in to TIER regulation if it competes directly against another TIER-regulated facility or if it has annual 
CO2e  emissions  that  exceed  10,000  tonnes  per  year  and  belongs  to  an  emissions-intensive  or  trade 
exposed sector with international competition. In addition, the owner of two or more “conventional oil and 
gas  facilities”  may  apply  to  have  those  facilities  regulated  under  the  TIER  regulation.  To  encourage 
compliance  with  the  emissions  intensity  reduction  targets,  TIER-regulated  facilities  must  provide  annual 
compliance reports and facilities that are unable to achieve their targets may either purchase credits from 
other facilities, purchase carbon offsets, or pay a levy to the Government of Alberta. 

Beginning on May 30, 2019 as part of the Carbon Tax Repeal Act and ended the Alberta Climate Leadership 
Adjustment  Rebate.  The  carbon  levy  no  longer  applies  to  any  type  of  fuel;  however,  as  Alberta  has  no 
carbon levy equivalent for fuel consumption, the federal government announced that beginning on January 
1, 2020 a federal fuel charge  will apply in  Alberta. In  December 2019,  Alberta issued a  Court challenge 
against the federal carbon tax, which came into effect on January 1, 2020, arguing that each province has 
the right to set its own policies to fight climate change. The Alberta Court of Appeal ruled in February of 
2020 that the federal carbon tax in Alberta was unconstitutional. The Attorney General of Canada appealed 
the decision to the SCC which was heard in September of 2020, a decision of which is expected for early 
2021.  

Saskatchewan 

In October 2016, Saskatchewan released its Climate Change White Paper, which outlined the principles of 
the province’s approach to climate change, including a focus on both mitigation and adaptation responses 
to  climate  change. Following  the  release  of  the  White  Paper,  the  government  worked  on  developing  its 
comprehensive  climate  change  strategy,  which  was  released  in  December  2017:  Prairie  Resilience:  A 
Made-in-Saskatchewan Climate Change Strategy (the “Strategy”). The Strategy focuses on the principles 
of readiness and climate resilience, curbing GHG emissions, and preparing for changing conditions such 
as extreme weather, drought or wildfire. Saskatchewan has decided not to sign on to the Pan-Canadian 
Framework on Clean Growth and Climate Change or to adopt a carbon pricing mechanism, meaning that 
it will be out of compliance with federal requirements. The Strategy proposes actions in key areas, including 

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(i) natural systems; (ii) physical infrastructure; (iii) economic sustainability; (iv) community preparedness; 
and (v) measuring, monitoring and reporting. Although no specific emission reduction targets are set out in 
the  Strategy,  the  Saskatchewan  government  has  indicated  that  it  will  support  Canada’s  efforts  to  meet 
national commitments under the Paris Agreement. Prior to the release of the Strategy, Saskatchewan relied 
on the GoGreen Saskatchewan initiative to encourage the reduction of GHG emissions and to educate the 
public  about  climate  change.  Between  2008  and  2015,  the  Saskatchewan  government  estimates  that  it 
invested $60 million in GoGreen funding through public/private partnerships. 

Saskatchewan  has  also  identified  technology  as  a  key  driver  of  emission  reductions,  including  carbon 
capture use and storage as well as renewable energy.  

As part of the Strategy, Saskatchewan will develop annual GHG reporting regulations for facilities that emit 
more than 25,000 tonnes of CO2e annually (with a voluntary opt-in for emitters over 10,000 tonnes of CO2e 
annually). 

On  April  10,  2019,  Saskatchewan  produced  the  first  annual  report  on  climate  resilience.  The  report 
measures  the  Province’s  progress  on  goals  set  out  under  Prairie  Resilience:  A  Made-in-Saskatchewan 
Climate Change Strategy. Among these goals is the aim of increasing the role of renewable energy in the 
provincial energy mix to 50% by 2030. 

On October 1, 2019, Bill 147 – An Act to amend the Oil and Gas Conservation Act, was proclaimed into 
force  that,  in  part,  amends  the  Oil  and  Gas  Conservation  Act  to  the  extent  necessary  to  bring  it  into 
alignment  with  the  Saskatchewan  Oil  and  Gas  Emissions  Management  Regulations.  The  Oil  and  Gas 
Emissions  Management  Regulations  came  into  effect  January  1st,  2019.  The  Oil  and  Gas  Emissions 
Management Regulations were introduced as a made-in-Saskatchewan results-based regulation to reduce 
methane-based GHG emissions by 4.5 million tonnes of carbon dioxide equivalent (CO2e) from 2015 levels 
by 2025. 

Land Tenure 

Crude  oil  and  natural  gas  located  in  the  Western  Canadian  provinces  is  owned  both  by  the  respective 
provincial governments and by private individuals.  Provincial governments grant rights to explore for and 
produce oil and natural gas pursuant to leases, licenses and permits for varying periods and on conditions 
set forth in provincial legislation, including requirements to perform specific work or make payments. Where 
oil and natural gas is privately owned, rights to explore for and produce such oil and natural gas are granted 
by lease on such terms and conditions as may be negotiated. 

The respective provincial governments predominantly own the rights to crude oil and natural gas located in 
the western provinces, with the exception of Manitoba where private ownership accounts for approximately 
80 percent of the crude oil and natural gas rights in the southwestern portion of the province.  Provincial 
governments grant rights to explore for and produce oil and natural gas pursuant to leases, licences and 
permits  for  varying  terms  and  on  conditions  set  forth  in  provincial  legislation,  including  requirements  to 
perform  specific  work  or  make  payments.  Private  ownership  of  oil  and  natural  gas  also  exists  in  such 
provinces and rights to explore for and produce such oil and natural gas are granted by lease on such terms 
and conditions as may be negotiated. 

Each of the provinces of Alberta and Saskatchewan has implemented legislation providing for the reversion 
to the Crown of mineral rights to deep, non-productive geological formations at the conclusion of the primary 
term of a lease or license.   

Alberta  also  has  a  policy  of  “shallow  rights  reversion”  which  provides  for  the  reversion  to  the  Crown  of 
mineral rights to shallow, non-productive geological formations for all leases and licenses. For leases and 

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licenses issued subsequent to January 1, 2009, shallow rights reversion will be applied at the conclusion 
of  the  primary  term  of  the  lease  or  license.    Holders  of  leases  or  licences  that  have  been  continued 
indefinitely prior to January 1, 2009 will receive a notice regarding the reversion of the shallow rights, which 
will be implemented three years from the date of the notice. In 2013, Alberta Energy placed an indefinite 
hold on serving shallow rights reversion notices for leases and licences that were granted prior to January 
1, 2009. Alberta Energy stated that it will provide the industry with notice if, in the future, a decision is made 
to serve shallow rights reversion notices. 

Environmental Regulation 

The oil and natural gas industry is currently subject to environmental regulations pursuant to a variety of 
provincial and federal legislation, all of which is subject to governmental review and revision from time to 
time.    Such  legislation  provides  for  restrictions  and  prohibitions  on  the  release  or  emitting  of  various 
substances produced in association with certain oil and gas industry operations, such as sulphur dioxide 
and nitrous oxide.  In addition, such legislation sets out the requirements for the satisfactory abandonment 
and reclamation of well and facility sites and provides form among other things, restrictions and prohibitions 
on spills, releases, discharges, or emissions of various substances produced in association with oil and gas 
operations,  habitat  protection  and  minimum  setbacks  of  oil  and  gas  activities  from  fresh  water  bodies. 
Compliance with such legislation can require significant expenditures and a breach of such requirements 
may result in suspension or revocation of necessary licenses and authorizations, civil liability for pollution 
damage,  and the  imposition  of material fines and  penalties. Certain  environmental protection legislation 
may subject Surge to statutory strict liability in the event of an accidental spill or discharge from a licensed 
facility,  meaning  that  fault  need  not  be  established  by  claimants  affected  by  such  a  spill  or  discharge.  
Further,  as  Canadian  environmental  legislation  evolves,  the  use  of  administrative  penalties  by  the 
imposition of fines for the commission of environmental offences on an absolute liability basis has grown. 

Environmental legislation is evolving in a manner that has and is expected to continue to result in stricter 
standards  and  enforcement,  larger  fines,  liabilities  and  sanctions,  and  potentially  increased  capital 
expenditures  and  operating  costs.    To  mitigate  potential  environmental  liabilities,  Surge  in  addition  to 
implementing  policies  and  procedures  designed  to  prevent  an  accidental  spill  or  discharge,  maintains 
insurance at industry standards.  

Federal  

Canadian  environmental  regulation  is  the  responsibility  of  the  federal  government  and  provincial 
governments. Where there is a direct conflict between federal and provincial environmental legislation in 
relation to the same matter, the federal law will prevail, however, such conflicts are uncommon. The federal 
government  has  primary  jurisdiction  over  federal  works,  undertakings  and  federally  regulated  industries 
such as railways, aviation and interprovincial transport. The Canadian Environmental Protection Act and 
the Canadian Environmental Assessment Act, provide the foundation for the federal government to protect 
the environment and cooperate with provinces to do the same.  

On June 21, 2019 Bill C-48 (the Oil Tanker Moratorium Act), came into force. This legislation is aimed at 
providing coastal protection in northern British Columbia by prohibiting crude oil tankers carrying more than 
12,500 metric tonnes of crude oil or persistent crude oil products from stopping, loading, or unloading crude 
oil in that area. This legislation may prevent the building of pipelines to, and export terminals located on, 
the portion of the British Columbia coast subject to the moratorium and, as a result, negatively affect the 
ability of producers to access global markets. 

As previously discussed in Industry Conditions – Restrained Pipeline Capacity and Differential Volatility, 
the CERA and the IAA came into force and the NEB was replaced with the CER. In addition, the Impact 
Assessment  Agency  (“IA  Agency”)  replaced  the  Canadian  Environmental  Assessment  Agency  (“CEA 
Agency”).  

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Bill C-69 introduced a number of important changes to the regulatory regime for federally regulated major 
projects  and  associated  environmental  assessments.  Designated  projects  will  require  an  impact 
assessment as part of their regulatory review. The impact assessment, conducted by a review panel, jointly 
appointed by the CER and the IA Agency, includes expanded criteria the review panel may consider when 
reviewing  an  application.  The  impact  assessment  also  requires  consideration  of  the  project’s  potential 
adverse effects, the overall societal impact and the expanded public interest that a project may have. The 
IA  must  look  at  the  direct  result  of  the  project’s  construction  and  operation,  including  environmental, 
biophysical  and  socio-economic  factors,  including  consideration  of  a  gender-based  analysis,  climate 
change, and impacts to Indigenous rights. Designated projects include pipelines that require more than 75 
kilometers of new right of way and pipelines located in national parks. Large scale in situ oil sands projects 
not regulated by provincial greenhouse gas emissions and certain refining, processing and storage facilities 
will also require an impact assessment. 

As stated, the objective of the legislative changes was to improve decision certainty and turnaround times. 
Once  a  review  or  assessment  is  commenced  under  either  the  CERA  or  IAA,  there  are  time  limits  the 
relevant regulatory authority will have to issue its report and recommendation. Designated projects will go 
through a planning phase to determine the scope of the impact assessment, which the federal government 
has stated should provide more certainty as to the length of the full review process. Applications for non-
designated  projects  will  follow  a  similar  process  as  under  the  NEB  Act.  There  is  significant  uncertainty 
surrounding the impact of Bill C-69 on oil and natural gas projects. The Minister of Natural Resources has 
a mandate to implement the CER efficiently and effectively, but the CER’s ability to expedite the project 
approval process has yet to be substantially tested. 

On July 17, 2020, the Federal government published its Strategic Assessment of Climate Change (“SACC”) 
to assess the impacts of climate change in federal impact assessments conducted under the federal IAA. 
The SACC applies to designated projects under the IAA. Guidance for projects regulated by the CER will 
consider the principles and objectives of the SACC. The SACC may also apply to environmental reviews 
by  other  federal  lifecycle  regulators,  and  be  used  in  regional  assessments.  Environment  and  Climate 
Change Canada has indicated it plans to review and update the SACC every 5 years. Proponents will be 
required to provide information about the emissions intensity of their projects, and this information will be 
compared to national and international projects of a similar scope and nature. A description of mitigation 
measures and  the plan  for  the project to achieve net-zero emission by 2050  will also be  required, as is 
information on the project’s ability to scope with the physical impacts of climate change.  

Alberta 

Environmental  legislation  in  the  Province  of  Alberta  is,  for  the  most  part,  set  out  in  the  Environmental 
Protection  and  Enhancement  Act  (“EPEA”),  the  Water  Act  and  the  Oil  and  Gas  Conservation  Act 
(“ABOGCA”).  EPEA, the Water Act and the ABOGCA impose strict environmental standards with respect 
to releases of effluents and emissions, require stringent compliance, reporting and monitoring obligations, 
and impose significant penalties for non-compliance. 

The regulatory landscape in Alberta has undergone a transformation from multiple regulatory bodies to a 
single regulator for upstream oil and gas, oil sands and coal development activity.  On June 17, 2013, the 
Alberta  Energy  Regulator  (the  “AER”)  assumed  the  functions  and  responsibilities  of  the  former  Energy 
Resources Conservation Board, including those found under the ABOGCA.  On November 30, 2013, the 
AER assumed the energy related functions and responsibilities of Alberta Environment and Parks (“AEP”) 
in respect of the disposition and management of public lands under the Public Lands Act.  On March 29, 
2014,  the  AER  assumed  the  energy  related  functions  and  responsibilities  of  AEP  in  the  areas  of 
environment and water under EPEA and the Water Act, respectively.  The AER’s responsibilities exclude 
the functions of the Alberta Utilities Commission and the Surface Rights Board, as well as Alberta Energy’s 
responsibility for mineral tenure. The objective behind the transformation to a single regulator is the creation 
of  an  enhanced  regulatory  regime  that  is  efficient,  attractive  to  business  and  investors,  and  effective  in 

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supporting public safety, environmental management and resource conservation while respecting the rights 
of landowners. 

In December 2008, the Government of Alberta released a new land use policy for surface land in Alberta, 
the  Alberta Land  Use Framework (the  “ALUF”). The  ALUF sets out an  approach to manage  public and 
private  land  use  and  natural  resource  development  in  a  manner  that  is  consistent  with  the  long-term 
economic, environmental and  social goals  of  the  province.  It  calls  for the development  of  seven  region-
specific land use plans in order to manage the combined impacts of existing and future land use within a 
specific region and the incorporation of a cumulative effects management approach into such plans. 

The Alberta  Land Stewardship Act (the “ALSA”) provides the legislative authority for the Government of 
Alberta to implement the policies contained in the ALUF.  Regional plans established under the ALSA are 
deemed to be legislative instruments equivalent to regulations and will be binding on the Government of 
Alberta  and  provincial  regulators,  including  those  governing  the  oil  and  gas  industry.    In  the  event  of  a 
conflict or inconsistency between a regional plan and another regulation, regulatory instrument or statutory 
consent,  the  regional  plan  will  prevail.    Further,  the  ALSA  requires  local  governments,  provincial 
departments,  agencies  and administrative  bodies or tribunals to review their regulatory  instruments and 
make any appropriate changes to ensure that they comply with an adopted regional plan.  The ALSA also 
contemplates the amendment or extinguishment of previously issued statutory consents such as regulatory 
permits, licenses, registrations, approvals and authorizations for the purpose of achieving or maintaining 
an objective or policy resulting from the implementation of a regional plan.  Among the measures to support 
the goals of the regional plans contained in the ALSA are conservation easements, which can be granted 
for the protection, conservation and enhancement of land, and conservation directives, which are explicit 
declarations contained in a regional plan to set aside specified lands in order to protect, conserve, manage 
and enhance the environment. 

On August 22, 2012, the Government of Alberta approved the Lower Athabasca Regional Plan (“LARP”) 
which came into force on  September 1, 2012.  The LARP is the first of seven  regional plans developed 
under the ALUF.  LARP covers a region in the northeastern corner of Alberta that is approximately 93,212 
square kilometres in size. The region includes a substantial portion of the Athabasca oilsands area, which 
contains approximately 82 percent of the province’s oilsands resources and much of the Cold Lake oilsands 
area.    LARP  establishes  six  new  conservation  areas  and  nine  new  provincial  recreation  areas.  In 
conservation and provincial recreation areas, conventional oil and gas companies with pre-existing tenure 
may  continue  to  operate.    Any  new  petroleum  and  gas  tenure  issued  in  conservation  and  provincial 
recreation areas will include a restriction that prohibits surface access. 

The South Saskatchewan Regional Plan (“SSRP”) was approved by the Government of Alberta on July 23, 
2014 and became effective on September 1, 2014. The SSRP is the second regional plan developed under 
the ALUF and covers approximately 83,764 square kilometres and includes 44 percent of the province’s 
population.  

The  SSRP  creates  four  new  and  four  expanded  conservation  areas,  and  two  new  and  six  expanded 
provincial  parks  and  recreational  areas.  Similar  to  LARP,  the  SSRP  will  honour  existing  petroleum  and 
natural gas tenure in conservation and provincial recreational areas. However, oil and gas companies must 
nonetheless minimize impacts of activities on the natural landscape, historic resources, wildlife, fish and 
vegetation when exploring, developing and extracting the resources. Any new petroleum and natural gas 
tenures sold  in conservation areas, provincial parks, and recreational areas  will prohibit surface access. 
Freehold mineral rights will not be subject to this restriction. With the implementation of the new Alberta 
regulatory structure under the AER, AEP will remain responsible for development and implementation of 
regional plans. However, the AER will take on some responsibility for implementing regional plans in respect 
of energy related activities. 

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Pursuant to several ministerial orders passed pursuant to s. 52.1(2) of the Alberta Public Health Act which 
declared a state of public health emergency in Alberta due to the COVID-19 pandemic, certain industrial 
environmental reporting requirements including the extension of deadlines or the suspension of reporting 
requirements under EPEA and the Water Act. The ministerial orders expired on August 14, 2020 and all 
environmental reporting should resume in accordance with the prescribed deadlines and requirements.  

Saskatchewan 

Saskatchewan’s Ministry of the Economy and the Oil and Gas Conservation Board collectively regulate oil 
and gas activities in the province, which is primarily governed by the Natural Resources Act and The Oil 
and Gas Conservation Act (“SKOGCA”). 

The Environmental Management and Protection Act (“EMPA”) regulates the protection of the environment 
in Saskatchewan, including among others the designation of environmentally impacted sites, issuance of 
environmental protection orders, and obligations to report releases of substances.  Most importantly, the 
EMPA  prohibits  the  discharge  of  substances  causing  adverse  effects  to  the  environment,  and  assigns 
responsibility  for  such  adverse  effects  to  a  broad  category  of  “persons  responsible.”    This  includes  the 
person who caused or contributed to the discharge (i.e. fugitive release of sour gas or flaring in excess of 
the permitted levels), had possession or control of the substance, as well as every owner and occupier of 
the land, including subsequent owners and occupiers and any person transporting the substance. 

In  May  2011,  Saskatchewan passed  changes to  SKOGCA.  Although  the  associated  Bill  received  Royal 
Assent on May 18, 2011, it was not proclaimed into force until April 1, 2012, in conjunction with the release 
of The Oil and Gas Conservation Regulations, 2012 (“OGCR”) and The Petroleum Registry and Electronic 
Documents Regulations (“Registry Regulations”). The aim of the amendments to the SKOGCA, and the 
associated regulations, is to provide resource companies investing in Saskatchewan’s energy and resource 
industries  with  the  best  support  services  and  business  and  regulatory  systems  available.  With  the 
enactment  of  the  Registry  Regulations  and  the  OGCR,  Saskatchewan  has  implemented  a  number  of 
operational aspects, including the increased demand for record-keeping, increased testing requirements 
for injection wells and increased investigation and enforcement powers, and procedural aspects, including 
those related to Saskatchewan’s participation as partner in the Petroleum Registry of Alberta. 

On  June  22,  2011,  the  Government  of  Saskatchewan  released  the  Upstream  Petroleum  Industry 
Associated Gas Conservation Standards, which are designed to reduce emissions resulting from the flaring 
and venting of associated gas (the “Associated Natural Gas Standards”). The Associated Natural Gas 
Standards were jointly developed with industry and the implementation of such standards commenced on 
July  1, 2012 for new wells  and facilities licensed on or after such date. The new standards will apply to 
existing licensed wells and facilities on July 1, 2015. 

Liability Management Rating Programs 

Alberta 

On  June  20,  2016,  the  AER  issued  Bulletin  2016-16,  Licensee  Eligibility—Alberta  Energy  Regulator 
Measures to Limit Environmental Impacts Pending Regulatory Changes to Address the Redwater Decision 
(“Bulletin 16”) in an urgent response to a decision from the Alberta Court of Queen’s Bench, which was 
affirmed by a majority at the Alberta Court of Appeal.  In Redwater Energy Corporation (Re), 2016 ABQB 
278  (“Redwater”),  Chief  Justice  Wittman  found  that  there  was  an  operational  conflict  between  the 
abandonment and reclamation provisions of the Oil and Gas Conservation Act (Alberta) and the Bankruptcy 
and  Insolvency  Act  (“BIA”),  and  that  receivers  and  trustees  have  the  right  to  renounce  assets  within 
insolvency proceedings.  Such  a  conflict renders  the  AER’s  legislated authority  unenforceable  to  impose 
abandonment orders against licensees or to require a licensee to pay a security deposit before approving 

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a transfer when such a licensee is insolvent. Effectively, this means that abandonment costs will be borne 
by the industry-funded Orphan Well Fund or the province in these instances because any resources of the 
insolvent licensee will first be used to satisfy secured creditors under the BIA.  

On  January  31,  2019,  the  Supreme  Court  of  Canada  ruled  on  the  appeal  of  Redwater  in  Orphan  Well 
Association v. Grant Thornton  Limited,  2019 SCC 5  in favour of the AER and Orphan Well Association. 
Specifically, the SCC held that while trustees will not be personally liable for abandonment and reclamation 
obligations, the  estate  will  remain liable for such  obligations. As a result, reclamation and abandonment 
liabilities must be dealt with before there can be any distribution to the insolvent parties’ creditors, including 
its secured creditors.   

In  response  to  the  SCC’s  decision  in  Redwater,  the  AER  began  working  on  an  improved  liability 
management framework.  On July 30, 2020, the Government of Alberta announced that it will introduce a 
new Liability Management Framework (“LMF”) for the oil and gas industry. The changes seek to introduce 
a system to actively manage the reclamation of oil and gas sites through the entire life-cycle.  

Prior to the change,  the AER administered the Licensee Liability Rating Program (the “AB LLR Program”) 
as  part  of  the  Liability  Management  Rating  Assessment  Process.  The  AB  LLR  Program  was  a  liability 
management program governing most conventional upstream oil and gas wells, facilities and pipelines. In 
short, the AB LLR Program required a licensee whose deemed liabilities exceed its deemed assets (and 
therefore the licensee has a resulting LLR of less than 1.0) to provide the AER with a security deposit. In 
certain circumstances, for example during the transfer of AER licenses between parties, the AER required 
that the transferee must achieve an LLR of 2.0 or higher immediately following the proposed transfer of the 
applicable licenses. The ratio of deemed liabilities to deemed assets was assessed once each month and 
upon the submission of a license transfer application, and failure to post the required security deposit could 
result in the initiation of enforcement actions by the AER.  

The  new  LMF  is  expected  to  be  a  more  fulsome  assessment  to  assess  the  capabilities  of  oil  and  gas 
operators to meet their regulatory obligations with expanded powers to the AER. 

The  LMF  will  contain  a  Licensee  Capability  Assessment  system  which  will  look  at  companies’  records 
including quarterly financials and the AER will have the ability to exchange data to track payments with the 
Ministry  of  Environment  and  Parks  who  can  ensure  landowners  are  being  paid.  The  Orphan  Well 
Association (“OWA”) will also have a larger role in conducting  abandonment and reclamation  work. The 
Alberta  Government  will  set  the  policy  direction  while  the  AER  will  administer  the  program  though 
monitoring, enforcement and working with the industry.  

Since early 2020, the Government of Alberta has signalled their interest to actively reduce the inventories 
of orphan and inactive well sites in the province. The OWA is an industry-funded, non-profit organization 
that operates under authority given by the AER. Originally, the OWA’s role was restricted to overseeing the 
closure of oil and gas properties, however, in June 2020, the Liabilities Management Statutes Act expanded 
the  role  of  the  OWA  which  included  the  OWA  to  act  as  a  commercial  oil  and  gas  operator  in  certain 
scenarios and play a more active role in the life-cycle management of struggling or abandoned oil and gas 
assets.  

In April of 2020, the Federal Government also announced that up to $1 billion in funding would be available 
to Alberta’s oilfield service contractors to perform reclamation work as part of the Federal Government’s 
COVID-19 Economic Response Plan and $200 million would be offered to the OWA as a repayable loan. 
In  May  of  2020,  the  Government  of  Alberta  launched  SRP  which  was  funded  primarily  by  the  Federal 
Government’s  COVID-19  Economic  Response  Plan.  Pursuant  to  the  program,  contractors  are  provided 
with grants to perform well, pipeline and oil and gas site closure and reclamation work. The Government of 
Alberta also announced the extension of a $100 million repayable loan to the OWA.  

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On December 17, 2020 the AER announced the steps it had taken to introduce and implement the new 
framework  which  include  the  Alberta  Government  approving  changes  to  the  Oil  and  Gas  Conservation 
Rules (“OGCR”) and Pipeline Rules which allow the AER to develop new liability management programs. 
The following is a summary of the changes that are expected to be implemented by the LMF: 

  The Licensee Capability Assessment system will replace the AB LLR Program and will take into 
account a wider variety of assessment parameters to enable a more comprehensive and accurate 
corporate health assessment.  

  An inventory reduction program will also be established to help reduce inactive well inventory and 
will include an  area-based closure program for companies to work together to share the cost of 
cleanup. 

  A  panel  will  be  created  to  determine  how  to  bring  sites  that  were  abandoned,  remediated  or 

reclaimed before the current standards into line with current environmental requirements.  

  To promote the timely reclamation of wells, facilities and infrastructure, the AER may set closure 
targets (or quotas) for licensees. Licensees may now be required to complete a specific amount of 
work or spend a specific amount with respect to the closure of the licensee’s wells, facilities and 
pipelines.  

  Priority and timeline to complete the work with respect to closure of a licensee’s wells, facilities and 

pipelines may be directed by the AER.  

  An  “eligible  requestor” which  includes private  landowners and  the  Ministry  of  Energy  and  public 
lands  disposition  holders,  in  the  case  of  private  and  public  lands,  respectively,  may  nominate 
inactive or abandoned wells and facilities for closure.  

  A licensee may be required to provide closure plan on request from the AER and such plans are to 
be  approved  by  the  AER  and  subject  to  any  further  conditions  as  the  AER  deems  fit  in  the 
circumstance.  

  Financial and reserves information shall be provided by a licensee to the AER upon request for the 
purposes of assessing licensee eligibility, administering liability management programs or ensuring 
the safe, orderly and environmental responsible development and closure of energy resources.   

The implementation of the LMF is still ongoing and the AER has announced that several changes are still 
expected  to  improve  existing  liability  programs  and  implement  the  new  LMF.  No  timeline  has  been 
committed to for the implementation of the LMF, however, further developments are expected in early 2021.  

The Corporation cannot predict what the AER’s LMF may look like but the implementation of the LMF and 
the  new  regulatory  framework  will  have  an  impact  on  crude  oil  and  natural  gas  production  in  Alberta, 
including Surge’s business. 

Saskatchewan 

In Saskatchewan, the Ministry of Economy implements the Licensee Liability Rating Program (the “SK LLR 
Program”). The SK LLR Program is designed to assess and manage the financial risk that a licensee’s well 
and facility abandonment and reclamation liabilities pose to an orphan well fund (the “Oil and Gas Orphan 
Well Fund”).  The Oil and  Gas Orphan Well Fund is responsible for carrying out the abandonment and 
reclamation of wells and facilities contained within the SK LLR Program when a licensee or WIP is defunct 
or missing.  The SK LLR Program requires a licensee whose deemed liabilities exceed its deemed assets 
to post a security deposit. The ratio of deemed liabilities to deemed assets is assessed each month for all 
licensees of oil, gas and service wells and upstream oil and gas facilities.  

On  August  19,  2016,  the  Saskatchewan  Ministry  of  the  Economy  released  a  notice  to  all  operators 
introducing interim measures in response to Redwater. Among other things, the Saskatchewan Ministry of 
the Economy announced that it considers all license transfer applications non-routine as it does not strictly 
rely on the standard LLR calculation in evaluating deposit requirements. In addition to increased security 

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deposit requirements, the Saskatchewan Ministry of the Economy at that time announced in 2016 that it 
may incorporate additional conditions with license transfer approvals. 

RISK FACTORS  

The business of exploring for, developing and producing oil and natural gas reserves is inherently risky. 
The following information is a summary only of certain risk factors relating to the Corporation and should 
be read in conjunction with the detailed information appearing elsewhere in this Annual Information Form. 
Prospective  investors  should  carefully  consider  the  risk  factors  set  out  below  and  consider  all  other 
information contained in this Annual Information Form and in the Corporation’s other public filings before 
making an investment decision. The risks set out below are not an exhaustive list, nor should be taken as 
a complete summary or description of all the risks associated with the Corporation’s business and the oil 
and natural gas business generally.   

COVID-19 

Global or  national health concerns,  including the  outbreak of  pandemic or contagious diseases such  as 
COVID-19, have, and may continue to adversely affect the Corporation by: (i) reducing global economic 
activity thereby resulting in lower demand for crude oil and natural gas and reduced commodity prices; (ii) 
impairing  the  Corporation’s  supply  chain  (for  example,  by  limiting  the  manufacturing  of  materials  or  the 
supply of services used in the Corporation’s operations); and (iii) affecting the health of the Corporation’s 
workforce, rendering employees unable to work or travel.  

Going Concern 

As at December 31, 2020, the Corporation had $260.9 million drawn on a total commitment of $335.0 million 
available under its syndicated credit agreement with a syndicate of lenders led by National Bank of Canada. 
This  credit  facility  is  comprised  of  a  $155.0  million  revolving  term  commitment,  a  $167.5  million  non-
revolving term commitment, and a $12.5 million operating loan facility. The revolving term commitment will 
continue to revolve until the next scheduled borrowing base redetermination date of June 30, 2021. The 
further extension of this credit facility is dependent on the Corporation's ability to repay or extend the term 
of the $167.5 million non-revolving term commitment that matures and requires repayment on December 
31, 2021. Should the Corporation fail to secure an extension, it could result in a failure to meet the terms of 
the credit agreement and the lenders would have the right, but not the obligation, to demand repayment of 
amounts  drawn  under  the  credit  facility.  If  the  amount  drawn  is  demanded  and  not  repaid,  this  would 
constitute a default under the Credit Facilities. A default under the Credit Facilities would also constitute a 
default under the Indenture as a result of which the principal of and interest and premium, if any,  on all 
Debentures  then  outstanding,  together  with  any  other  monies  outstanding  under  the  Indenture,  would 
immediately become due and payable by the Corporation. 

The  Corporation's  ability  to  continue  as  a  going  concern  is  dependent  upon  the  Corporation's  ability  to 
maintain  the  Credit  Facilities  at  or  above  amounts  currently  drawn  and  its  ability  to  renew  the  Credit 
Facilities prior to their respective repayment or maturity date. There can be no assurances that the Credit 
Facilities  will  be  renewed  or  additional  sources  of  funding  will  be  available  for  the  Corporation.  These 
matters cause material uncertainty which may cast significant doubt on the Corporation’s ability to continue 
as a going concern. 

Credit Facilities Risks  

The Corporation currently has the Credit Facilities and the amounts authorized thereunder is dependent on 
the borrowing base determined by its lenders.  The Corporation is required to comply with covenants under 
the Credit Facilities which may affect the availability, or price, of additional funding and in the event that the 

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Corporation does not comply with these covenants, the Corporation’s access to capital could be restricted 
or repayment could be required.  Events beyond the Corporation’s control may contribute to the failure of 
the Corporation to comply with such covenants.  A failure to comply with covenants could result in default 
under the Credit Facilities, which could result in the Corporation being required to repay amounts owing 
thereunder.    Even  if  the  Corporation  is  able  to  obtain  new  financing,  it  may  not  be  on  commercially 
reasonable terms or terms that are acceptable to the Corporation.  If the Corporation is unable to repay 
amounts owing under the Credit Facilities, the lenders under the Credit Facilities could proceed to foreclose 
or otherwise realize upon the collateral granted to them to secure the indebtedness.  The acceleration of 
the Corporation’s indebtedness under one agreement may permit acceleration of indebtedness under other 
agreements  that contain cross default or cross-acceleration provisions.   In addition, the  Credit  Facilities 
may impose operating and financial restrictions on the Corporation that could  include restrictions on the 
payment  of  dividends,  repurchase  or  making  of  other  distributions  with  respect  to  the  Corporation’s 
securities,  incurring  of  additional  indebtedness,  the  provision  of  guarantees,  the  assumption  of  loans, 
making of capital expenditures, entering into of amalgamations, mergers, take-over bids or disposition of 
assets, among others.   

The impact of the Supreme Court of Canada’s decision in the Redwater case on lending practices in the 
crude oil and natural gas sector and actions taken by secured creditors and receivers/trustees of insolvent 
borrowers  has  the  effect  of  adjusting  lending  practices  to  account  for  end-of-life  obligations  that  were 
thought  to  be  subordinate  to  secured  debt  and  will  be  subject  to  prior  satisfaction  of  abandonment  and 
restoration claims which may not be capable of quantification at the time credit is advanced. See “Industry 
Conditions – Liability Management Rating Programs”. 

The Corporation’s lenders use the Corporation’s reserves, commodity prices, applicable discount rate and 
other factors, to periodically determine the Corporation’s borrowing base.  A material decline in commodity 
prices  could  reduce  the  Corporation’s  borrowing  base,  reducing  the  funds  available  to  the  Corporation 
under the Credit Facilities.  This could result in the requirement to repay a portion, or all, of the Corporation’s 
bank indebtedness.   

Operational Risks 

Oil and natural gas exploration operations are subject to all the risks and hazards typically associated with 
such operations, including hazards such as fire, explosion, blowouts, cratering and oil spills, each of which 
could result in substantial damage to oil and natural gas wells, producing facilities, other property and the 
environment or in personal injury. In accordance with industry practice, Surge is not fully insured against 
all of these risks, nor are all such risks insurable. Although Surge maintains liability insurance in an amount 
which it considers adequate, the nature of these risks is such that liabilities could exceed policy limits, in 
which event Surge could incur significant costs that could have a materially adverse effect upon its financial 
condition. Oil and natural gas production operations are also subject to all the risks typically associated with 
such  operations,  including  premature  decline  of  reservoirs  and  the  invasion  of  water  into  producing 
formations. 

Oil and natural gas exploration and development activities are dependent on the availability of drilling and 
related equipment in the particular areas where such activities will be conducted. Demand for such limited 
equipment  or  access  restrictions  may  affect  the  availability  of  such  equipment  to  Surge  and  may  delay 
exploration and development activities. 

Oil  and  natural  gas  exploration  and  development  activities  are  dependent  on  access  to  areas  where 
operations  are  to  be  conducted.    Seasonal  weather  variations,  including  freeze-up  and  break-up,  affect 
access in certain circumstances. Unexpected adverse weather conditions, such as flooding or prolonged 
break-up, can have a significant negative impact on capital expenditures, operations and costs. 

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To the extent Surge is not the operator of its oil and natural gas properties, it is dependent on such operators 
for the timing of activities related to such properties and is largely unable to direct or control the activities 
of the operators.  Payments from production generally flow through the operator and there is a risk of delay 
and  additional  expense  in  receiving  such  revenues  if  the  operator  becomes  insolvent.  Although  Surge 
intends to operate the majority of its properties, there is no guarantee that it will remain operator of such 
properties or that Surge will operate other properties it may acquire in the future. 

In addition, the success of Surge will be largely dependent upon the performance of its management and 
key employees. Surge does not have any key man insurance policies and, therefore, there is a risk that the 
death or departure of any member of management or any key employee could have a material adverse 
effect on Surge. 

Surge’s  ability  to  market  oil  and  natural  gas  from  its  wells  also  depends  upon  numerous  other  factors 
beyond  its  control,  including,  among  other  things,  the  availability  of  natural  gas  processing  and  storage 
capacity,  the  availability  of  pipeline  capacity,  the  price  of  oilfield  services  and  the  effects  of  inclement 
weather. Because of these factors, Surge may be unable to market some or all of the oil and natural gas it 
produces or to obtain favourable prices for the oil and natural gas it produces. 

Volatility of Oil and Natural Gas Prices and Markets 

Surge’s financial performance and condition are substantially dependent on the prevailing prices of oil and 
natural gas which are unstable and subject to fluctuation.  Fluctuations in oil or natural gas prices could 
have  an  adverse  effect  on  Surge’s  operations  and  financial  condition  and  the  value  and  amount  of  its 
reserves.  Prices for crude oil fluctuate in response to global and North American supply of and demand for 
oil, market performance and uncertainty and a variety of other factors which are outside the control of Surge 
including, but not limited, to the world economy and the OPEC’s ability to adjust supply to world demand, 
government  regulation,  political  stability  and  the  availability  of  alternative  fuel  sources.    In  addition,  the 
prices  received  by  Surge  for  its  oil  are  subject  to  differentials  against  such  benchmarks  as  WTI  and 
Edmonton Par which can fluctuate substantially and result in Surge realizing prices substantially below such 
benchmarks.  Oil and natural gas producers in Western Canada may receive significantly discounted prices 
for some of their production due to regional constraints on their ability to transport and sell such production, 
including  to  international  markets.  Natural  gas  prices  are  influenced  primarily  by  factors  within  North 
America, including North American supply and demand, economic performance, weather conditions and 
availability and pricing of alternative fuel sources.   

Decreases in oil and natural gas prices realized by Surge will result in reduced net production revenue and 
may change the economics of producing from some wells, which could result in a reduction in the volume 
of Surge’s reserves. Any further substantial  declines  in  the prices of crude oil  or  natural  gas could also 
result  in  delay  or cancellation  of  existing  or future  drilling, development  or  construction programs or the 
curtailment of production.  All of these factors could result in a material decrease in Surge’s net production 
revenue,  cash  flows  and  profitability  causing  a  reduction  in  its  oil  and  gas  acquisition  and  development 
activities. In addition, bank borrowings available to Surge will in part be determined by Surge’s borrowing 
base.  A  sustained  material  decline  in  prices  from  historical  average  prices  could  further  reduce  such 
borrowing base, therefore reducing the bank credit available, including under the Credit Facilities, and could 
require that a portion of its bank debt be repaid. 

Surge may enter into agreements to receive fixed prices on its oil and natural gas production to offset the 
risk of revenue losses if commodity prices decline; however, if commodity prices increase beyond the levels 
set in such agreements, Surge will not benefit from such increases. 

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Weakness in the Oil and Gas Industry 

Recent market events and conditions, including global excess oil and natural gas supply, actions taken by 
OPEC, slowing  growth  in  emerging  economies, market  volatility  and disruptions in  Asia, sovereign debt 
levels  and  political  upheavals  in  various  countries  have  caused  significant  weakness  and  volatility  in 
commodity prices. These events and conditions have caused a significant decrease in the valuation of oil 
and gas companies and a decrease in confidence in the oil and gas industry.  These difficulties have been 
exacerbated in Canada by certain changes in government at a federal level and, in the case of Alberta, at 
the  provincial  level,  and  the  resultant  uncertainty  surrounding  regulatory,  tax,  royalty  changes  and 
environmental regulation that have been announced or may be implemented by the new governments. In 
addition, the inability to get the necessary approvals to build pipelines and other facilities to provide better 
access to markets for the oil and gas industry  in Western Canada has led to additional downward price 
pressure on oil and gas produced in Western Canada and uncertainty and reduced confidence in the oil 
and gas industry in Western Canada. Lower commodity prices may also affect the volume and value of the 
Corporation’s reserves, rendering certain reserves uneconomic. In addition, lower commodity prices have 
restricted,  and  may  continue  to  restrict,  the  Corporation’s  cash  flow  resulting  in  a  reduced  capital 
expenditure budget. Consequently, the Corporation may not be able to replace its production with additional 
reserves and both the Corporation’s production and reserves could be reduced on a year over year basis. 

Political Uncertainty 

In the last several years, the United States and certain European countries have experienced significant 
political events that have cast uncertainty on global financial and economic markets. Since the 2016 U.S. 
presidential election, the U.S. administration has begun taking steps to implement a certain of its promises 
made during the campaign.  The administration has withdrawn the U.S. from the TPP and Congress has 
passed  sweeping  tax  reform,  which,  among  other  things,  significantly  reduces  U.S.  corporate  tax  rates. 
This  may  affect  competitiveness  of  other  jurisdictions,  including  Canada.    In  addition,  NAFTA  has  been 
renegotiated and on December 10, 2019, and Canada, the U.S. and Mexico signed the USMCA which will 
replace  NAFTA  once  ratified  by  the  three  signatory  countries.  See  “Industry  Conditions  –  The  North 
American Free Trade Agreement”.  The U.S. administration has also taken action with respect to reduction 
of regulation, which may also affect relative competitiveness of other jurisdictions. It is unclear exactly what 
other actions the U.S.  administration will implement, and if implemented, how these actions may impact 
Canada and in particular the oil and natural gas industry.  Any actions taken by the new U.S. administration 
may have a negative impact on the Canadian economy and on the businesses, financial conditions, results 
of operations and the valuation of Canadian oil and gas companies, including Surge. 

In addition to the political disruption in the United States, on January 31, 2020 the United Kingdom officially 
withdrew  from  the  European  Union.  Since  the  United  Kingdom’s  departure,  it  remains  unclear  what  the 
effects of this will be as a final deal was reached between the European Union and the United Kingdom 
which came into effect on December 31, 2020. Some European countries have also experienced the rise 
of anti-establishment political parties and public protests held against open-door immigration policies, trade 
and globalization. To the extent that certain political actions taken in North America, Europe and elsewhere 
in the world result in a marked decrease in free trade, access to personnel and freedom of movement it 
could have an adverse effect on Surge’s ability to market products internationally, increase costs for goods 
and  services  required  for  operations,  reduce  access  to  skilled  labour  and  negatively  impact  business, 
operations, financial conditions and the market value of the Common Shares. 

A change in federal, provincial or municipal governments in Canada may have an impact on the directions 
taken  by  such  governments  on  matters  that  may  impact  the  oil  and  natural  gas  industry  including  the 
balance between economic development and environmental policy. 

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Climate Change 

Public support for climate change  action and receptivity to new technologies has grown in recent  years. 
Governments  in  Canada  and  around  the  world  have  responded  to  these  shifting  societal  attitudes  by 
adopting ambitious emissions reduction targets and supporting legislation, including measures relating to 
carbon pricing, clean energy and fuel standards, and alternative energy incentives and mandates. There 
has also been increased activism, including threats of culpability, legal action against oil and gas producers, 
and  public  opposition  to  fossil  fuels  and  the  oil  and  gas  industry  in  which  the  Corporation  operates.  In 
November 2018, ENvironment JEUnesse, a Quebec advocacy group, applied to the Quebec Superior Court 
to certify a class action against the Government of Canada for climate related matters. In January 2019, 
the City of Victoria became the first municipality in Canada to endorse a class action lawsuit against oil and 
natural gas producers for climate-related harms.          

Public and government hostility toward the oil and gas industry could reduce demand for oil and gas and, 
therefore,  adversely  affect  market  prices  for  the  Corporation’s  production.  Existing  and  future  laws  and 
regulations may impose additional costs on companies operating in the oil and gas industry or significant 
liabilities  for  failure  to  comply  with  their  requirements.  Concerns  over  climate  change  and  fossil  fuel 
extraction could lead governments to enact additional or more stringent laws and regulations applicable to 
the Corporation and other companies in the energy industry in general.   

Surge’s  exploration  and  production  facilities  and  other  operations  and  activities  emit  GHGs  which  may 
require us to comply with GHG emissions legislation at the provincial or federal level. Climate change policy 
is evolving at regional, national and international levels, and political and economic events may significantly 
affect the scope and timing of climate change measures that are ultimately put in place. As a signatory to 
the UNFCCC and a signatory to the Paris Agreement, which was ratified in Canada on October 3, 2016, 
the Government of Canada pledged to cut its GHG emissions by 30 per cent from 2005 levels by 2030. 
One of the pertinent policies announced to date by the Government of Canada to reduce GHG emission is 
the planned implementation of a nation-wide price on carbon emissions. The federal carbon levy came into 
effect on April 1, 2019 and affects provinces which have not implemented their own carbon taxes, cap-and-
trade  systems  or  other  plans  for  carbon  pricing,  namely  Ontario,  Manitoba,  Saskatchewan  and  New 
Brunswick. The federal carbon levy will be at an initial rate of $20 per tonne. Beginning on May 30, 2019 
as part of the Carbon Tax Repeal Act and ended the Alberta Climate Leadership Adjustment Rebate. The 
carbon levy no longer applies to any type of fuel; however, as Alberta has no carbon levy equivalent for fuel 
consumption, the federal government announced that beginning on January 1, 2020 a federal fuel charge 
will apply in Alberta. In December 2019, Alberta issued a Court challenge against the federal carbon tax, 
which came into effect on January 1, 2020, arguing that each province has the right to set its own policies 
to fight climate change. In February of 2020 the Alberta Court of Appeal determined the carbon tax and the 
GGPPA  was  unconstitutional.  Each  of  the  Attorney  Generals  of  Saskatchewan,  Ontario  and  Canada 
appealed the Court of Appeal decisions from Saskatchewan, Ontario and Alberta to the SCC which were 
heard in September of 2020. A decision is expected from the SCC on the three matters in early 2021, the 
outcome of which may affect the Corporation’s business. The direct or indirect costs of compliance with 
GHG-related regulations may have a material adverse effect on our business, financial condition, results of 
operations and prospects.  Some of our significant facilities may ultimately be subject to future regional, 
provincial and/or federal climate change regulations to manage GHG emissions.  

Given the evolving nature of the debate related to climate change and the control of GHG and resulting 
requirements,  it  is  expected  that  current  and  future  climate  change  regulations  will  have  the  effect  of 
increasing  our  operating  expenses  and  in  the  long-term  reducing  the  demand  for  oil  and  natural  gas 
production, resulting in a decrease in our profitability and a reduction in the value of our assets or asset 
write-offs.  

See “Industry Conditions – Climate Change Regulation”. 

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Environmental Concerns 

Many aspects of the oil and natural gas business present environmental risks and hazards, including the 
risk that Surge may be in noncompliance with an environmental law, regulation, permit, licence, or other 
regulatory approval, possibly unintentionally or without knowledge.  Such risks may expose Surge to fines 
or penalties, third party liabilities or to the requirement to remediate, which could be material.   

The operational hazards associated with possible blowouts, accidents, oil spills, natural gas leaks, fires, or 
other damage to a well or a pipeline may require Surge to incur costs and delays to undertake corrective 
actions, could result in environmental damage or contamination or could result in serious injury or death to 
employees, consultants, contractors or members of the public, creating the potential for significant liability 
to Surge.  Also, the occurrence of any such incident could damage Surge’s reputation in the surrounding 
communities and make it more difficult for Surge to pursue its operations in those areas.   

Compliance with environmental laws and regulations could materially increase Surge’s costs.  Surge may 
incur  substantial  capital  and  operating  costs  to  comply  with  increasingly  complex  laws  and  regulations 
covering  the  protection  of  the  environment  and  human  health  and  safety.  In  particular,  Surge  may  be 
required  to  incur  significant  costs  to  comply  with  future  federal  or  provincial  greenhouse  gas  emissions 
reduction  requirements  or  other  regulations,  if  enacted.  See  “Industry  Conditions  –  Environmental 
Regulation”. 

The oil and natural gas industry elicits concerns about climate change, as well as general public opposition 
to the industry.  As a result, industry participants may be subject to increased public activism, which could 
result in increased costs due to delays or damage. 

Although Surge maintains insurance consistent with prudent industry practice, it is not fully insured against 
certain environmental risks, either  because such insurance is not available  or because of high premium 
costs. In particular, insurance against risks from environmental pollution occurring over time (as opposed 
to  sudden  and  catastrophic  damages)  is  not  available  on  economically  reasonable  terms.    Accordingly, 
Surge’s properties may be subject to liability due to hazards that cannot be insured against, or that have 
not  been  insured  against  due  to  prohibitive  premium  costs  or  for  other  reasons.  It  is  also  possible  that 
changing regulatory requirements or emerging jurisprudence could render such insurance of less benefit 
to Surge. 

Dividends 

The  Credit  Facilities  contain  restrictions  on  Surge’s  ability  to  pay  dividends.  In  addition,  the  payment  of 
dividends  by  a  corporation  is  governed  by  the  liquidity  and  insolvency  tests  described  in  the  ABCA.  
Pursuant to the ABCA, after the payment of a dividend, a corporation must be able to pay its liabilities as 
they become due and the realizable value of the assets of the corporation must be greater than the liabilities 
and the legal stated capital of its outstanding securities. 

On March 9, 2020, the Corporation announced it was reducing monthly dividend by 90%, from $0.10 per 
Common  Share  per  year to $0.01  per Common Share per  year,  effective with the March  2020  dividend 
payable in April 2020.  On April 14, 2020, the Corporation suspended the Corporation’s dividend program 
in  its  entirely.  The  final    cash  dividend  payment  prior  to  suspension  was  made  on  April  15,  2020  for 
Shareholders of record as at March 31, 2020, as declared on March 16, 2020. 

The amount of future cash dividends, if any, will be subject to the discretion of the  Board of Directors and 
will otherwise depend on a variety of factors, including the removal of the restrictions on the payment of 
dividends contained in the Credit Facilities, prevailing economic and competitive  environment, results of 
operations, fluctuations in  working capital,  the price of oil  and  gas, the taxability  of  the Corporation, the 

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Corporation’s ability to raise capital, the amount of capital expenditures, the satisfaction of solvency tests 
imposed by the ABCA for the declaration and payment of dividends, applicable law and other factors. See 
“Dividend Policy.”  

Royalty Regimes  

There can be no assurance that the federal government and the provincial governments in the jurisdictions 
in which the Corporation operates will not adopt new royalty regimes or modify the existing royalty regimes 
which may have an impact on the economics of the Corporation’s projects. The royalty regime in Alberta, 
Saskatchewan and any other jurisdictions in which the Corporation’s oil and natural gas assets are located 
may  be  subject  to  further  review  and  changes  which  could  adversely  impact  the  Corporation’s  financial 
condition and operations. An increase in royalties would reduce the Corporation’s earnings and could make 
future  capital  investments,  or  the  Corporation’s  operations,  less  economic.  See  “Industry  Conditions  - 
Provincial Royalties and Incentives”. 

Gathering and Processing Facilities, Pipeline Systems and Rail 

Surge  delivers  its  products  through  gathering  and  processing  facilities,  pipeline  systems  and,  in  certain 
circumstances, by rail. The amount of oil and natural gas that Surge can produce and sell is subject to the 
accessibility,  availability,  proximity  and  capacity  of  these  gathering  and  processing  facilities,  pipeline 
systems and railway lines. Notwithstanding the Government of Alberta’s plans to purchase or lease 4,400 
rail  cars  and  the  implementation  of  production  curtailment  in  Alberta,  the  ongoing  lack  of  availability  of 
capacity in any of the gathering and processing facilities, pipeline systems and railway lines could result in 
the inability to realize the full economic potential of Surge’s production or in a reduction of the price offered 
for its production. The lack of firm pipeline capacity continues to affect the oil and natural gas industry and 
limit the ability to transport produced oil and gas to market. In addition, the pro-rationing of capacity on inter-
provincial pipeline systems continues to affect the ability to  export oil and natural gas. Unexpected shut 
downs or curtailment of capacity of pipelines for maintenance or integrity work or because of actions taken 
by regulators could also affect Surge’s production, operations and financial results. As a result, producers 
are  increasingly  turning to  rail  as  an  alternative  means of transportation. In recent  years,  the  volume of 
crude  oil  shipped  by  rail  in  North  America has increased  dramatically.  Any  significant  change in market 
factors  or other conditions  affecting these  infrastructure systems  and  facilities, as well  as any  delays  or 
uncertainty in constructing new infrastructure systems and facilities could harm Surge’s business and, in 
turn, its financial condition, operations and cash flows.  Announcements and actions taken by the federal 
government and the Government of Alberta relating to approval of infrastructure projects may continue to 
intensify, leading to increased challenges to interprovincial and international infrastructure projects moving 
forward.  In  addition,  while  the  federal  government  has  introduced  Bill  C-69  to  overhaul  the  existing 
environmental assessment process and replace the NEB with a new regulatory agency, the impact of the 
new proposed regulatory scheme on proponents and the timing of receipt of approvals of major projects 
remains unclear. 

Following major accidents in Lac-Megantic, Quebec and North Dakota, the Transportation Safety Board of 
Canada and the U.S. National Transportation Board have recommended additional regulations for railway 
cars carrying crude oil. In June 2015, as a result of these recommendations, the Government of Canada 
passed the Safe and Accountable Rail Act which increased insurance obligations on the shipment of crude 
oil by rail and imposed a per tonne levy of $1.65 on crude oil shipped by rail to compensate victims and for 
environmental  cleanup  in  the  event  of  a  railway  accident.  In  addition  to  this  legislation,  new  regulations 
have implemented the TC-117 standard for all rail tank cars carrying flammable liquids which formalized 
the commitment to retrofit, and eventually phase out DOT-111 tank cars carrying crude oil. The increased 
regulation of rail transportation may reduce the ability of railway lines to alleviate pipeline capacity issues 
and adds additional costs to the transportation of crude oil by rail. On July 13, 2016, the Minister of Transport 
(Canada) issued Protective Direction No. 38, which directed that the shipping of crude oil on DOT-111 tank 

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cars end by  November 1, 2016. Tank cars entering  Canada from the United States will be monitored  to 
ensure they are compliant with Protective Direction No. 38. 

A  portion  of  Surge’s  production  may,  from  time  to  time,  be  processed  through  facilities  owned  by  third 
parties  and  over  which  it  does  not  have  control.  From  time  to  time,  these  facilities  may  discontinue  or 
decrease operations either as a result of normal servicing requirements or as a result of unexpected events. 
A  discontinuation or decrease  of  operations  could  have  a  materially  adverse  effect on Surge’s ability  to 
process its production and deliver the same for sale. Midstream and pipeline companies may take actions 
to  maximize  their  return  on  investment  which  may  in  turn  adversely  affect  producers  and  shippers, 
especially  when  combined  with  a  regulatory  framework  that  may  not  always  align  with  the  interests  of 
particular shippers. 

Fixed Price Hedging  

From time to time, the Corporation may enter into agreements to receive fixed prices on its oil and natural 
gas production to offset the risk of revenue losses if commodity prices decline.  However, to the extent that 
the Corporation engages in price risk management activities to protect itself from commodity price declines, 
it may also be prevented from realizing the full benefits of price increases above the levels of the derivative 
instruments used to manage price risk.  In addition, the Corporation’s hedging arrangements may expose 
it to the risk of financial loss in certain circumstances, including instances in which:  production falls short 
of the hedged volumes; there is a widening of price-basis differentials between delivery points for production 
and the delivery point assumed in the hedge arrangement; the counterparties to the hedging arrangements 
or  other  price  risk  management  contracts  fail  to  perform  under  those  arrangements;  or  a  sudden 
unexpected event materially impacts oil and natural gas prices.   

Similarly, from time to time the Corporation may enter into agreements to fix the exchange rate of Canadian 
to United States dollars in order to offset the risk of revenue losses if the Canadian dollar increases in value 
compared to the United States dollar. However, if the Canadian dollar declines in value compared to the 
United States dollar, the Corporation will not benefit from the fluctuating exchange rate. 

Industry Regulation and Competition 

There  is strong competition  relating to  all aspects of  the oil and  natural  gas  industry.  Surge  will  actively 
compete  for  capital,  skilled  personnel,  undeveloped  land,  reserve  acquisitions,  access  to  drilling  rigs, 
service rigs and other equipment, access to processing facilities and pipeline and refining capacity, and in 
all other  aspects  of  its operations  with  a  substantial  number of other  organizations, many  of  which may 
have greater technical and financial resources than Surge. Some of those organizations not only explore 
for, develop and produce oil and natural gas but also carry on refining operations and market petroleum 
and other products on a world-wide basis and as such have greater and more diverse resources on which 
to draw.  Surge’s ability to increase reserves and production in the future will depend not only on its ability 
to develop its present properties, but also on its ability to select and acquire suitable producing properties 
or prospects for exploratory drilling. 

The marketability of oil and natural gas acquired or discovered will be affected by numerous factors beyond 
the control of Surge. These factors include reservoir characteristics, market fluctuations, the proximity and 
capacity  of  oil  and  natural  gas  pipelines  and  processing  equipment  and  government  regulation.  Oil  and 
natural  gas  operations  (exploration,  production,  pricing,  marketing,  transportation  and  royalty  rates)  are 
subject  to  extensive  controls  and  regulations  imposed  by  various  levels  of  government,  including  those 
described  above  under  the  heading  “Industry  Conditions”,  which  may  be  amended  from  time  to  time. 
Surge’s oil and natural gas operations may also be subject to compliance with federal, provincial and local 
laws and regulations controlling the discharge of materials into the environment or otherwise relating to the 
protection of the environment.  Changes to the regulation of the oil and gas industry in jurisdictions in which 

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Surge operates may adversely impact Surge’s ability to economically develop existing reserves and add 
new reserves. 

Variations in Foreign Exchange Rates and Interest Rates 

Surge’s  expenses  will  be  denominated  in  Canadian  dollars,  while  the  price  of  oil  and  natural  gas  will 
generally be denominated in U.S. dollars or impacted by the Canadian dollar to U.S. dollar exchange rate.  
As the exchange rate for the Canadian dollar versus the U.S. dollar increases, Surge will generally receive 
fewer  Canadian  dollars  for  its  production.  If  the  value  of  the  Canadian  dollar  against  the  U.S.  dollar 
increases,  the  financial  results  of  Surge  may  be  negatively  affected.    Future  fluctuations  in  the 
Canadian/United  States  foreign  exchange  rate  may  impact  the  future  value  of  Surge’s  reserves  as 
determined by independent evaluators.  In addition, variations in interest rates could result in a significant 
change  in  the  amount  Surge  will  pay  to  service  debt,  potentially  adversely  affecting  the  value  of  the 
Common Shares. Surge’s management may hedge interest rates to mitigate these risks. 

Price Volatility of Publicly Traded Securities 

In recent years, the securities markets in Canada and the United States have experienced a high level of 
price  and  volume  volatility,  and  the  market  price  of  securities  of  many  companies,  particularly  those 
considered to be development stage companies, has experienced wide fluctuations in price which have not 
necessarily  been  related  to  the  operating  performance,  underlying  asset  values  or  prospects  of  such 
companies. There can be no assurance that continual fluctuations in price will not occur. It is likely that the 
market  price  for  the  Common  Shares  will  be  subject  to  market  trends  generally,  notwithstanding  the 
financial and operational performance of Surge. 

Abandonment and Reclamation Costs 

As a general rule, the current oil and gas asset abandonment, reclamation and remediation (“A&R”) liability 
regime in Alberta limits each party’s liability to its proportionate ownership of an asset. In the case where 
one joint owner of an oil and gas asset becomes insolvent and is unable to fund the required A&R activities 
associated with such asset, the solvent working interest counterparties can recover the insolvent party’s 
share of the remediation costs from the Orphan Well Fund. See “Industry Conditions – Liability Management 
Ratings Programs”. 

As a result of the Supreme Court of Canada’s January 2019 decision in the Redwater case, a trustee in 
bankruptcy  is  not  permitted  to  renounce  uneconomic  oil  and  gas  assets  and  leave  these  assets  to  be 
remediated  by  the  Orphan  Well  Fund,  thereby  avoiding  the  environmental  liabilities  of  the  estate  it  is 
administering. Accordingly, the AER may now use Alberta’s provincial legislative scheme to prevent the 
repudiation or renunciation of an insolvent company’s assets by a trustee and require the trustee to satisfy 
certain environmental obligations in priority to the claims of secured and unsecured creditors.  In response 
to the Supreme Court’s decision, the AER and the Government of Alberta began revising Alberta’s current 
liability framework with the introduction of the LMF in July 2020. Surge cannot predict how the Government 
of Alberta or the AER will seek to implement the LMF in the coming months, however, the LMF framework 
will have an impact on crude oil and natural gas production in Alberta, including Surge’s business.   

The AER’s new LMF may impact the Corporation’s ability to transfer its licences, approvals or permits in 
the  course  of  a  divestment,  and  may  result  in  increased  costs  and  delays  or  require  changes  to  or 
abandonment of projects and transactions. As a result of the decision in Redwater, lenders may reduce the 
availability of credit to oil and gas issuers that utilize secured loans, thereby negatively affecting the financial 
capacity of such issuers, including potential partners and counterparties of the Corporation. Lenders also 
may generally increase their scrutiny of oil and gas assets held by producers, including the Corporation, 

- 67 - 

 
and the associated A&R liabilities in determining whether to provide credit, may require borrowers to adhere 
to more stringent A&R-related operational covenants, and may increase the cost of providing credit. 

While  the  impact  on  the  Corporation  of  any  legislative,  regulatory  or  policy  decisions  as  a  result  of  the 
Redwater decision cannot be reliably or accurately estimated, any cost recovery or other measures taken 
by applicable regulatory  bodies may impact the Corporation and materially and  adversely affect, among 
other things, the Corporation’s business, financial condition, results of operations and cash flow. 

There remains a great deal of uncertainty as to what new regulatory measures will be developed by the 
provinces or jointly with the federal government, as the new LMF is implemented in the province.  

Substantial Capital Requirements; Liquidity 

Surge may have to make substantial capital expenditures for the acquisition, exploration, development and 
production of oil and natural gas reserves in the future. If revenues or reserves decline, Surge may have 
limited ability to expend the capital necessary to undertake or complete future drilling programs. There can 
be no assurance that debt or equity financing or cash generated by operations will be available or sufficient 
to meet these requirements or for other corporate purposes or, if debt or equity financing is available, that 
it will be on terms acceptable to the Corporation. Moreover, future activities may require Surge to alter its 
capitalization significantly. The inability of the Corporation to access sufficient capital for its operations could 
have a material adverse effect on its financial condition, results of operations or prospects. 

Reserve Estimates 

There are numerous uncertainties inherent in evaluating quantities of reserves and the net present value 
of future net revenue  to  be derived  therefrom, including many factors  beyond the  control  of  Surge.  The 
reserves information contained in the Reserves Report and set forth herein, including information respecting 
the net present value of future net revenue from reserves, represents an estimate only.  This estimate is 
based on a number of assumptions relating to factors such as initial production rates, production decline 
rates, ultimate recovery of reserves, timing and amount of capital expenditures, marketability of production, 
future prices of oil and natural gas, operating costs and royalties and other government levies that may be 
imposed over the producing life of the reserves. These assumptions were based on price forecasts in use 
at the date the Reserves Report were prepared and many of these assumptions are subject to change and 
are beyond the control of Surge.  Ultimately, the actual reserves attributable to Surge’s properties will vary 
from the estimates contained in the Reserves Report and those variations may be material and affect the 
market price of the Common Shares. 

Reserve Replacement 

Surge’s future oil and natural gas reserves and production and the cash flows to be derived therefrom are 
highly dependent on successfully acquiring or discovering new reserves. Without the continual addition of 
new reserves, any existing reserves Surge may have at any particular time and the production therefrom 
will decline over time as such existing reserves are exploited. A future increase in reserves will depend not 
only on Surge’s ability to develop any properties it may  have from time to time, but also  on its ability to 
select  and  acquire  suitable  producing  properties  or  prospects.  There  can  be  no  assurance  that  Surge’s 
future  exploration  and  development  efforts  will  result  in  the  discovery  and  development  of  additional 
commercial accumulations of oil and natural gas.   

Sour Natural Gas 

Some  of  the  Corporation’s  current  or  future  properties  include  wells  that  produce  sour  natural  gas  and 
facilities that process sour natural gas.  An accidental discharge or leak of sour natural gas can be fatal or 

- 68 - 

 
cause serious injury.  The dangers associated with drilling for, producing, processing and transporting sour 
natural  gas  necessitate  increased  environmental,  health  and  safety  compliance  costs  to  Surge  and  any 
accidental  discharge  or leak of sour natural  gas could  lead to  significant  liabilities  to  Surge.    Surge has 
implemented policies and protocols to address this risk, but it is not possible for any issuer to eliminate all 
of the risks associated with producing, processing and transporting sour natural gas.   

Delay in Cash Receipts and Credit Worthiness of Counterparties 

In addition to the usual delays in payment by purchasers of oil and natural gas to the operators of Surge’s 
properties, and by the operator to Surge, payments between any of such parties may also be delayed by 
restrictions imposed by lenders, delays in the sale or delivery of products, delays in the connection of wells 
to a gathering system, blowouts or other accidents, recovery by the operator of expenses incurred in the 
operation  of  Surge’s  properties or  the establishment  by  the  operator of  reserves  for such  expenses.   In 
addition,  the  insolvency  or  financial  impairment  of  any  counterparty  owing  money  to  Surge,  including 
industry partners and marketing agents, could prevent Surge from collecting such debts. 

Geopolitical Risks  

Political  events  throughout  the  world  that  cause  disruptions  in  the  supply  of  oil  continuously  affect  the 
marketability  and  price  of  oil  and  natural  gas  acquired  or  discovered  by  the  Corporation.    Conflicts,  or 
conversely peaceful developments, arising outside of Canada have a significant impact on the price of oil 
and natural gas.  Any particular event could result in a material decline in prices and result in a reduction 
of the Corporation’s net production revenue.  

In addition, the Corporation’s oil and natural gas properties, wells and facilities could be the subject of a 
terrorist attack.  If any of the Corporation’s properties, wells or facilities are the subject of terrorist attack it 
may have a material adverse effect on the Corporation’s business, financial condition, results of operations 
and prospects.  The Corporation does not have insurance to protect against the risk from terrorism. 

Issuance of Debt 

From  time  to  time  Surge  may  enter  into  transactions  to  acquire  assets  or  shares  of  other  corporations. 
These transactions may be financed partially or wholly through debt, which may increase debt levels above 
industry standards.  Surge’s articles and by-laws do not limit the amount of indebtedness it may incur.  The 
level of Surge’s indebtedness from time to time could impair its ability to obtain additional financing in the 
future on a timely basis to take advantage of business opportunities that may arise. 

Possible Failure to Realize Anticipated Benefits of Acquisitions and Dispositions 

The Corporation has recently completed a number of acquisitions and dispositions and may complete future 
acquisitions and dispositions to strengthen its position in the oil and natural gas industry and to create the 
opportunity to realize certain benefits including, among other things, potential cost savings.  Achieving the 
benefits  of  recent  and  any  future  acquisitions  the  Corporation  may  complete  will  depend  in  part  on 
successfully  consolidating  functions  and  integrating  operations  and  procedures  in  a  timely  and  efficient 
manner, as well as the Corporation’s ability to realize the anticipated growth opportunities and synergies 
from  combining  the  acquired  assets  and  operations  with  those  of  the  Corporation.    The  integration  of 
acquired assets requires the dedication of substantial management effort, time and resources which may 
divert management’s focus and resources from other strategic opportunities and from operational matters 
during this process. The integration process may result in the loss of key employees and the disruption of 
ongoing business, customer and employee relationships that may adversely affect the Corporation’s ability 
to achieve the anticipated benefits of recent and any future acquisitions. Management continually assesses 
the value and contribution of services provided by third parties and assets required to provide such services. 

- 69 - 

 
In this regard, non-core assets may be periodically disposed of so that the Corporation can focus its efforts 
and resources more efficiently. Depending on the state of the market for such non-core assets, certain of 
Surge’s  non-core  assets  may  realize  less  on  disposition  than  their  carrying  value  on  the  consolidated 
financial statements of the Corporation. 

Cost of New Technologies 

The  petroleum  industry  is  characterized  by  rapid  and  significant  technological  advancements  and 
introductions of new products and services utilizing new technologies. Other companies may have greater 
financial, technical and personnel resources that allow them to enjoy technological advantages and may in 
the future allow them to implement new technologies before the Corporation. There can be no assurance 
that Surge will be able to respond to such competitive pressures and implement such technologies on a 
timely basis or at an acceptable cost. If Surge implements such technologies, there is no assurance that it 
will do so successfully. One or more of the technologies currently utilized by Surge or implemented in the 
future may become obsolete. In such case, Surge’s business, financial condition and results of operations 
could be affected adversely and materially. If Surge is unable to utilize the most advanced commercially 
available technology, or is unsuccessful in implementing certain technologies, Surge’s business, financial 
condition and results of operations could also be adversely affected in a material way. 

Information Technology Systems and Cyber-Security 

Surge  has  become  increasingly  dependent  upon  the  availability,  capacity,  reliability  and  security  of  its 
information technology infrastructure and its ability to expand and continually update this infrastructure, to 
conduct daily operations. Surge depends on various information technology systems to estimate reserve 
quantities,  process  and  record  financial  data,  manage  the  land  base,  analyze  seismic  information, 
administer contracts with operators and lessees and communicate with employees and third-party partners.  

Further, Surge is  subject to  a  variety  of  information technology  and system risks  as a part of its  normal 
course  operations,  including  potential  breakdown,  invasion,  virus,  cyber-attack,  cyber-fraud,  security 
breach,  and destruction or  interruption of its  information technology systems by third parties or insiders. 
Unauthorized access to these systems by employees or third parties could lead to corruption or exposure 
of  confidential,  fiduciary  or  proprietary  information,  interruption  to  communications  or  operations  or 
disruption to Surge’s business activities or competitive position. Further, disruption of critical information 
technology  services,  or  breaches  of  information  security,  could  have  a  negative  effect  on  Surge’s 
performance and earnings, as well as on Surge’s reputation. Surge has technical and process controls in 
line with industry-accepted standards to protect its information assets and systems; however, these controls 
may  not  adequately  prevent  cyber-security  breaches.  The  significance  of  any  such  event  is  difficult  to 
quantify, but may in certain circumstances be material and could have a material adverse effect on Surge’s 
business, financial condition and results of operations. 

Hydraulic Fracturing 

The proliferation of the use of hydraulic fracturing as a recovery technique employed in oil and natural gas 
drilling has given rise to increased public scrutiny of its environmental aspects, particularly with respect to 
its potential impact on local aquifers.  Surge utilizes hydraulic fracturing in a significant portion of the light 
oil wells it drills and completes.  Negative public perception of hydraulic fracturing may place pressure on 
governments in the jurisdictions where Surge operates to implement additional regulatory requirements or 
limitations  on  the  utilization  of  hydraulic  fracturing,  which  in  turn  could  restrict  Surge’s  operations  and 
increase its costs.   

Any  new  laws,  regulations  or  permitting  requirements  regarding  hydraulic  fracturing  could  lead  to 
operational delays, increased operating costs, third party or governmental claims, and could increase costs 

- 70 - 

 
of compliance and doing business as well as delay the development of oil and natural gas resources from 
shale formations, which are not commercial without the use of hydraulic fracturing. Restrictions on hydraulic 
fracturing could also reduce the amount of oil and natural gas that Surge is ultimately able to produce from 
its reserves. 

Dilution 

Common Shares, including rights, warrants, special warrants, subscription receipts and other securities to 
purchase, to convert into or to exchange into Common Shares, may be created, issued, sold and delivered 
on such terms and conditions and at such times as the Board may determine. In addition, Surge may issue 
additional  Common Shares from time to  time  pursuant  to  Surge’s stock  option  plan  and stock incentive 
plan.  The issuance of these Common Shares would result in dilution to holders of Common Shares.   

Net Asset Value 

Surge’s  net  asset  value  will  vary  depending  upon  a  number  of  factors  beyond  the  control  of  Surge’s 
management,  including  oil  and  natural  gas  prices.  The  trading  price  of  the  Common  Shares  is  also 
determined by a number of factors which are beyond the control of management and such trading price 
may be greater than or less than the net asset value of Surge. 

Reliance on Management 

Shareholders  will  be  dependent  on  the  management  of  Surge  in  respect  of  the  administration  and 
management of all matters relating to Surge and its properties and operations. Investors who are not willing 
to rely on the management of Surge should not invest in Common Shares. 

Permits and Licenses 

The operations of Surge may require licenses and permits from various governmental authorities. There 
can  be  no  assurance  that  Surge  will  be  able  to  obtain  all  necessary  licenses  and  permits  that  may  be 
required to carry out exploration and development at its projects. 

Title to Properties 

Although title reviews  will be done according to industry standards prior to the purchase of most oil and 
natural  gas  producing  properties  or  the  commencement  of  drilling  wells  as  determined  appropriate  by 
management, such reviews do not guarantee or certify that an unforeseen defect in the chain of title will 
not arise to defeat a claim of Surge which could result in a reduction of Surge’s interest in a property or well 
and the revenue received by Surge therefrom. 

Litigation 

In the normal course of the Corporation’s operations, it may become involved in, named as a party to, or 
be the subject of, various legal proceedings, including regulatory proceedings, tax proceedings and legal 
actions,  related  to  personal  injuries,  property  damage,  property  tax,  land  rights,  the  environment  and 
contract  disputes.  The  outcome  of  outstanding,  pending  or  future  proceedings  cannot  be  predicted  with 

- 71 - 

 
certainty  and  may  be  determined  adversely  to  the  Corporation  and  as  a  result,  could  have  a  material 
adverse effect on the Corporation’s assets, liabilities, business, financial condition and results of operations. 

Aboriginal Claims 

Aboriginal peoples have claimed aboriginal title and rights to resources and various properties in Western 
Canada. Such claims, in relation to any of Surge’s lands, if successful, could have an adverse effect on its 
operations. 

Income Taxes 

The  Corporation  files  all  required  income  tax  returns  and  believes  that  it  is  in  full  compliance  with  the 
provisions  of  the  Tax  Act  and  all  other  applicable  provincial  tax  legislation.  However,  such  returns  are 
subject to reassessment by the applicable taxation authority. In the event of a successful reassessment of 
the Corporation, whether by re-characterization of exploration and development expenditures or otherwise, 
such reassessment may have an impact on current and future taxes payable. 

Income tax laws relating to the oil and natural gas industry, such as the treatment of resource taxation or 
dividends, may in the future be changed or interpreted in a manner that adversely affects the Corporation. 
Furthermore, tax authorities having jurisdiction over the Corporation may disagree with how the Corporation 
calculates  its  income  for  tax  purposes  or  could  change  administrative  practices  to  the  Corporation’s 
detriment. 

Corporate Matters 

Certain of the directors and officers of Surge are also directors and officers of other oil and gas companies 
involved in natural resource exploration and development, and conflicts of interest may arise between their 
duties as officers and directors of Surge, as the case may be, and as officers and directors of such other 
companies.  

Failure to Maintain Listing of the Common Shares and the Debentures 

The Common Shares and the Debentures are currently listed for trading on the facilities of the TSX. The 
failure of Surge to meet the applicable listing or other requirements of the TSX in the future may result in 
the Common Shares and/or the Debentures ceasing to be listed for trading on the TSX, which would have 
a  material  adverse  effect  on  the  value  of  the  Common  Shares  and/or  Debentures.  There  can  be  no 
assurance that the Common Shares and Debentures will continue to be listed for trading on the TSX. 

Structure of Surge 

From time to time, Surge may take steps to organize its affairs in a manner that minimizes taxes and other 
expenses payable with respect to the operation of Surge and its subsidiaries. If the manner in which Surge 
structures its affairs is successfully challenged by a taxation or other authority, Surge and the holders of 
Common Shares may be adversely affected.  

Changes in Legislation 

It is possible that the Canadian federal and provincial government or regulatory authorities could choose to 
change the Canadian federal income tax laws, royalty regimes, liability management, environmental and 
climate change laws or other laws applicable to oil and gas companies and that any such changes could 
materially adversely affect Surge, its shareholders and the market value of the Common Shares. 

- 72 - 

 
Additional  information  on  the  risks,  assumptions  and  uncertainties  are  found  in  this  Annual  Information 
Form under the heading “Special Note Regarding Forward Looking Statements”. 

Alternatives to and Changing Demand for Petroleum Products 

Full conservation measures, alternative fuel requirements, increasing consumer demand for alternatives to 
oil and natural gas and technological advances in fuel economy and renewable energy generation devices 
could reduce the demand for oil, natural gas and liquid hydrocarbons. Recently, certain jurisdictions have 
implemented policies or incentives to decrease the use of fossil fuels and encourage the use of renewable 
fuel  alternatives,  which  may  lessen  the  demand  for  petroleum  products  and  put  downward  pressure  on 
commodity  prices.  In  addition,  advancements  in  energy  efficient  products  have  a  similar  effect  on  the 
demand for oil and gas products. Surge cannot predict the impact of changing demand for oil and natural 
gas  products,  and  any  major  changes  may  have  a  material  adverse  effect  on  its  business,  financial 
condition, results of operations and cash flows by decreasing profitability, increasing costs, limiting access 
to capital and decreasing the value of Surge’s assets. 

Global  Events  Outside  of  the  Corporation’s  Control,  such  as  Natural  Disasters,  Wars  or  Health 
Epidemics 

The Corporation may be impacted by  business interruptions resulting from pandemics and public health 
emergencies,  including  those  related  to  COVID-19  coronavirus,  geopolitical  actions,  including  war  and 
terrorism or natural disasters including earthquakes, typhoons, floods and fires. An outbreak of infectious 
disease, a pandemic or a similar public health threat, such as the recent outbreak of the novel coronavirus 
known as COVID-19, or a fear of any of the foregoing, could adversely impact us by causing operating, 
manufacturing supply chain, clinical trial and project development delays and disruptions, labour shortages, 
travel and shipping disruption and shutdowns (including as a result of government regulation and prevention 
measures). It is unknown whether and how the Corporation may affected if such an epidemic persists for 
an extended period of time. The Corporation may incur expenses or delays relating to such events outside 
of our control, which could have a material adverse impact on our business, operating results and financial 
condition. 

Forward-Looking Information 

Shareholders  and  prospective  investors  are  cautioned  not  to  place  undue  reliance  on  Surge’s  forward-
looking information. By its nature, forward-looking information involves numerous assumptions, known and 
unknown risks and uncertainties, of both a general and specific nature, that could cause actual results to 
differ materially from those suggested by the forward-looking information or contribute to the possibility that 
predictions, forecasts or projections will prove to be materially inaccurate. 

Additional  information  on  the  risks,  assumption  and  uncertainties  are  found  under  the  heading  “Special 
Note Regarding Forward Looking Statements” of this Annual Information Form. 

LEGAL PROCEEDINGS AND REGULATORY ACTIONS 

There are no outstanding legal proceedings material to the Corporation to which the Corporation is a party 
or in respect of which any of its properties are subject, nor are there any such proceedings known to the 
Corporation to be contemplated.   

During the year ended December 31, 2020, there were (i) no penalties or sanctions imposed against the 
Corporation by a court relating to securities legislation or by a securities regulatory authority; (ii) no other 
penalties or sanctions imposed by a court or regulatory body against the Corporation that it believes would 
likely  be  considered  important  to  a  reasonable  investor  in  making  an  investment  decision;  and  (iii)  no 

- 73 - 

 
settlement agreements entered into by the Corporation with a court relating to securities legislation or with 
a securities regulatory authority.  

INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS  

James  Pasieka,  a  director  of  the  Corporation,  and  Michael  Bennett,  the  Corporate  Secretary  of  the 
Corporation,  are,  respectively,  counsel  to  and  a  partner  of  the  national  law  firm McCarthy  Tétrault  LLP, 
which law firm renders legal services to the Corporation.   

Except as disclosed above or as may be disclosed elsewhere in this AIF, none of the directors, executive 
officers or principal shareholders of the Corporation, and no associate or affiliate of any of them, has or has 
had any material interest in any transaction or any proposed transaction which has materially affected or is 
reasonably expected to materially affect the Corporation or any of its affiliates.  

AUDITOR, TRANSFER AGENT AND REGISTRAR 

KPMG LLP are the auditors of the Corporation and have confirmed with respect to the Corporation, that 
they are independent within the meaning of the relevant rules and related interpretations prescribed by the 
relevant professional bodies in Canada and any applicable legislation or regulations. 

The transfer agent and registrar for the Common Shares is Odyssey Transfer Agent & Trust Company at 
its principal offices in Calgary, Alberta and Toronto, Ontario. 

INTEREST OF EXPERTS 

The Reserves Report and certain reserves estimates contained in filings made by the Corporation under 
National Instrument 51-102 – Continuous Disclosure Requirements during the year ended December 31, 
2020 were prepared  by Sproule.  As at the date of this Annual Information Form, the directors, officers, 
employees and consultants of Sproule who participated in the preparation of the Reserves Report or such 
reserves  estimates  or  who  were  in  a  position  to  directly  influence  the  preparation  or  outcome  of  the 
preparation of the Reserves Report or such reserves estimates, as a group, owned, directly or indirectly, 
less than 1% of the outstanding Common Shares.   

KPMG LLP are independent of the Corporation pursuant to the rules of professional conduct of the Institute 
of Chartered Accountants of Alberta. 

ADDITIONAL INFORMATION 

Additional information concerning the Corporation may be found under the Corporation’s profile on SEDAR 
at  www.sedar.com.  Additional  information,  including  information  concerning  directors’  and  officers’ 
remuneration and indebtedness, principal holders of the Corporation’s securities and securities authorized 
for  issuance  under  equity  compensation  plans,  will  be  contained  in  the  information  circular  of  the 
Corporation for the annual general meeting of the holders of Common Shares scheduled to be held in 2021. 
Additional  financial  information  is  provided  in  the  Corporation’s  comparative  financial  statements  and 
management’s discussion and analysis for the year ended December 31, 2020. 

- 74 - 

 
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\

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Executed as to our report referred to above: 

Sproule Associates Limited 
Calgary, Alberta 

Sproule Associates Limited  

APEGA Permit Number 00417 

Original Signed by Gary R. Finnis, P.Eng. 
Gary R. Finnis, P.Eng. 
Senior Manager, Engineering 

Date: Mar. 02, 2021 

Membership: 62965 

Original Signed by Alec Kovaltchouk, P.Geo. 
Alec Kovaltchouk, P.Geo. 
VP, Geoscience 

Date: Mar. 02, 2021 

Membership: 72150 

2629.110581.Rev1 

Summary 

National Instruments 51-101 

       3  
Page 

 
SCHEDULE “B” 

FORM 51-101F3 
Report of Management and Directors on Reserves Data and Other Information 

Terms to which a meaning is ascribed in National Instrument 51-101 - Standards of Disclosure for Oil and Gas 
Activities have the same meaning herein. 

Management of Surge Energy Inc. (the “Corporation”) are responsible for the preparation and disclosure of 
information  with  respect  to  the  Corporation’s  oil  and  gas  activities  in  accordance  with  securities  regulatory 
requirements. This information includes reserves data, which are estimates of proved reserves and probable 
reserves and related future net revenue as at December 31, 2020, estimated using forecast prices and costs. 

Sproule  Associates  Limited,  an  independent  qualified  reserves  evaluator,  has  evaluated  and  reviewed  the 
Corporation’s  reserves  data.  The  report  of  the  independent  qualified  reserves  evaluator  is  presented  in 
Schedule ”A” to the Annual Information Form of the Corporation for the year ended December 31, 2020 (the 
“AIF”). 

The Reserves Committee of the Board of Directors of the Corporation has: 

(a) 

(b) 

reviewed the Corporation’s procedures for providing information to the independent qualified reserves 
evaluator; 

met with the independent qualified reserves evaluator to determine whether any restrictions affected 
the ability of the independent qualified reserves evaluator to report without reservation; and 

(c) 

reviewed the applicable reserves data with management and with Sproule Associates Limited. 

The Reserves Committee of the Board of Directors has reviewed the Corporation’s procedures for assembling 
and reporting other information associated with oil and gas activities and has reviewed that information with 
management. The Board of Directors has, on the recommendation of the Reserves Committee, approved: 

(a) 

(b) 

the  content and filing  with  securities  regulatory  authorities of Form  51-101F1, incorporated into  the 
AIF, containing reserves data and other oil and gas information; 

the filing of Form 51-101F2, which is the report of the independent qualified reserves evaluators on 
the reserves data; and 

(c) 

the content and filing of this report. 

[Balance of Page Intentionally Left Blank.] 

B - 2 

 
Because the reserves data are based on judgements regarding future events, actual results will vary and the 
variations  may  be  material.    However,  any  variations  should  be  consistent  with  the  fact  that  reserves  are 
categorized according to the probability of their recovery. 

(signed) “Paul Colborne” 
Paul Colborne, President & Chief Executive Officer  

(signed) “Jared Ducs” 
Jared Ducs, Chief Financial Officer 

(signed) “Daryl Gilbert” 
Daryl Gilbert, Director & Chair of the Reserves 
Committee 

(signed) “P. Daniel O’Neil” 
P. Daniel O’Neil, Director 

March 9, 2021 

B - 2 

 
 
 
 
 
SCHEDULE “C” 

Audit Committee Charter 

Role and Objective 

The Audit Committee is a committee of the Board of Directors of Surge Energy Inc. (the “Corporation”) to 
which the Board has delegated its responsibility for oversight of the nature and scope of the annual audit, 
management’s  reporting  on  internal  accounting  standards  and  practices,  financial  information  and 
accounting  systems  and  procedures,  financial  reporting  and  statements  and  recommending,  for  Board 
approval, the audited consolidated financial statements and other mandatory disclosure releases containing 
financial information of the Corporation.  The objectives of the Audit Committee are as follows: 

1. 

2. 

3. 

4. 

5. 

to assist directors in fulfilling their legal and fiduciary obligations (especially for accountability) in 
respect of the preparation and disclosure of the financial statements of the Corporation and related 
matters; 

to oversee the audit efforts of the external auditors of the Corporation; 

to maintain free and open means of communication among the directors, the external auditors, the 
financial and senior management of the Corporation; 

to satisfy itself that the external auditors are independent of the Corporation; and 

to strengthen the role of the outside directors by facilitating in depth discussions between directors 
on the Committee, management and external auditors. 

The function of the Committee is one of oversight of management and the external auditors in the execution 
of their responsibilities.  Management is responsible for the preparation, presentation and integrity of the 
financial  statements  of  the  Corporation,  maintaining  appropriate  accounting  and  financial  reporting 
principles  and  policies  and  implementing  appropriate  internal  controls  and  procedures.    The  external 
auditors are responsible for planning and carrying out a proper audit of the annual financial statements of 
the Corporation and reviewing the interim financial statements of the Corporation prior to their filing with 
securities regulatory authorities and other procedures.  

Composition of the Committee 

1. 

2. 

3. 

4. 

The Audit Committee shall consist of at least three directors. The Board shall appoint one member 
of the Audit Committee to be the Chair of the Audit Committee. 

Each director appointed to the Audit Committee by the Board must be independent. A director is 
independent if the director has no direct or indirect material relationship with the Corporation.  A 
material  relationship  means  a  relationship  which  could,  in  the  view  of  the  Board,  reasonably 
interfere with the exercise of the director’s independent judgment. In determining whether a director 
is independent of management, the Board shall make reference to National Instrument 52-110 – 
Audit  Committees  or  the  then  current  legislation,  rules,  policies  and  instruments  of  applicable 
regulatory authorities. 

Each member of the Audit Committee shall be “financially literate”. In order to be financially literate, 
a director must be, at a minimum, able to read and understand financial statements that present a 
breadth and complexity of accounting issues generally comparable to the breadth and complexity 
of issues expected to be raised by the Corporation’s financial statements. 

A director appointed by the Board to the Audit Committee shall be a member of the Audit Committee 
until replaced by the Board or until his or her resignation. 

 
 
Meetings of the Committee 

1. 

2. 

The Audit Committee shall convene a minimum of four times each year at such times and places 
as may be designated by the Chair of the Audit Committee and whenever a meeting is requested 
by the Board, a member of the Audit Committee, the auditors, or a senior officer of the Corporation. 
Meetings  of  the  Audit  Committee  shall  correspond  with  the  review  of  the  quarterly  financial 
statements and management discussion and analysis of the Corporation. 

Notice  of  each  meeting  of  the  Audit  Committee  shall  be  given  to  each  member  of  the  Audit 
Committee.  The auditors shall be given notice of each meeting of the Audit Committee at which 
financial  statements  of  the  Corporation  are  to  be  considered  and  such  other  meetings  as 
determined by the Chair and shall be entitled to attend each such meeting of the Audit Committee. 

3. 

Notice of a meeting of the Audit Committee shall: 

(a) 

(b) 

(c) 

(d) 

be in writing; 

state the nature of the business to be transacted at the meeting in reasonable detail; 

to the extent practicable, be accompanied by copies of documentation to be considered at 
the meeting; and 

be  given at least  two  business days  prior to  the time  stipulated  for the  meeting  or such 
shorter period as the members of the Audit Committee may permit. 

4. 

5. 

6. 

7. 

8. 

A quorum for the transaction of business at a meeting of the Audit Committee shall consist of a 
majority  of  the  members  of  the  Audit  Committee.  However,  it  shall  be  the  practice  of  the  Audit 
Committee  to  require  review,  and,  if  necessary,  approval  of  certain  important  matters  by  all 
members of the Audit Committee. 

A member or members of the Audit Committee may participate in a meeting of the Audit Committee 
by means of such telephonic, electronic or other communication facilities, as permits all persons 
participating in the meeting to communicate adequately with each other. A member participating in 
such a meeting by any such means is deemed to be present at the meeting. 

In  the absence  of  the  Chair of the  Audit  Committee, the members of the Audit  Committee  shall 
choose one of the members present to be Chair of the meeting. In addition, the members of the 
Audit Committee shall choose one of the persons present to be the Secretary of the meeting. 

The Chairman of the Board, senior management of the Corporation and other parties may attend 
meetings  of  the  Audit  Committee;  however  the  Audit  Committee  (i)  shall  meet  with  the  external 
auditors independent of management as necessary, in the sole discretion of the Committee, but in 
any event, not less than quarterly; and (ii) may meet separately with management. 

Minutes shall be kept of all meetings of the Audit Committee and shall be signed by the Chair and 
the Secretary of the meeting. 

Duties and Responsibilities of the Committee 

1. 

It is the responsibility of the Audit Committee to oversee the work of the external auditors, including 
resolution of  disagreements  between management and  the external  auditors regarding financial 
reporting. The external auditors shall report directly to the Audit Committee. 

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2. 

3. 

The Audit Committee shall, in the exercise of its powers, authorities and discretion so authorized, 
conform to any regulations or restrictions that may from time to time be made or imposed upon it 
by the Board or the legislation, policies or regulations governing the Corporation and its business. 

It  is  the  responsibility  of  the  Audit  Committee  to  satisfy  itself  on  behalf  of  the  Board  that  the 
Corporation’s  system  of  internal  controls  over  financial  reporting  and  disclosure  controls  and 
procedures are satisfactory for the purpose of: 

(a) 

(b) 

identifying, monitoring and mitigating the principal risks; 

ensuring compliance with legal, ethical and regulatory requirements; 

and  to  review  with  the  external  auditors  their  assessment  of  the  internal  controls  over  financial 
reporting  and  the  disclosure  controls  of  the  Corporation,  their  written  reports  containing 
recommendations  for  improvement,  and  management’s  response  and  any  follow-up  to  any 
identified weaknesses. 

4. 

It  is  the  responsibility  of  the  Audit  Committee  to  review  the  annual  financial  statements  of  the 
Corporation  and,  if  deemed  appropriate,  recommend  the  financial  statements  to  the  Board  for 
approval.  This process should include but be not to be limited to: 

(a) 

(b) 

(c) 

(d) 

reviewing and  accepting,  if appropriate, the annual audit  plan of the  external auditors of 
the Corporation, including the scope of audit activities, and monitor such plan’s progress 
and results during the year; 

reviewing  changes  in  accounting  principles,  or  in  their  application,  which  may  have  a 
material impact on the current or future years’ financial statements; 

reviewing  significant  accruals,  reserves  or  other  estimates  such  as  any  impairment 
calculation; 

reviewing  the  methods  used  to  account  for  significant  unusual  or  non-recurring 
transactions; 

(e) 

ascertaining compliance with covenants under loan agreements; 

(f) 

(g) 

reviewing disclosure requirements for commitments and contingencies; 

reviewing  adjustments  raised  by  the  external  auditors,  whether  or  not  included  in  the 
financial statements; 

(h) 

reviewing unresolved differences between management and the external auditors; 

(i) 

(j) 

obtain explanations of significant variances with comparative reporting periods; 

review of business systems changes and implications; 

(k) 

review of authority and approval limits; 

(l) 

review the adequacy and effectiveness of the accounting and internal control policies of 
the Corporation and procedures through inquiry and discussions with the external auditors 
and management; 

(m) 

confirm through private discussion with the external auditors and the management that no 
management restrictions are being placed on the scope of the external auditors’ work;  

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(n) 

(o) 

(p) 

review of tax policy issues; and 

review of emerging accounting issues that could have an impact on the Corporation; and 

understand bias in decision-making and areas where significant judgment is applied. 

5. 

It is the responsibility Audit Committee to review the interim financial statements of the Corporation 
and, if deemed appropriate, to recommend the financial statements to the Board for approval and 
to review all related management discussion and analysis.  The Audit Committee must be satisfied 
that adequate procedures  are in place for the review of the Corporation’s disclosure of all other 
financial information and shall periodically assess the accuracy of those procedures. 

6. 

The Audit Committee shall have the authority to: 

(a) 

(b) 

(c) 

inspect  any  and  all  of  the  books  and  records  of  the  Corporation,  its  subsidiaries  and 
affiliates; 

discuss  with  the  management  and  senior  staff  of  the  Corporation,  its  subsidiaries  and 
affiliates, any affected party and the external auditors, such accounts, records and other 
matters as any member of the Audit Committee considers necessary and appropriate; 

engage independent counsel and other advisors as it determines necessary to carry out 
its duties; and 

(d) 

to set and pay the compensation for any advisors employed by the Audit Committee. 

7. 

With respect to the appointment of external auditors by the Board, the Audit Committee shall: 

(a) 

(b) 

(c) 

(d) 

(e) 

recommend to the Board the appointment of the external auditors; 

review the performance of the external auditors and make recommendations to the Board 
regarding  the  replacement  or  termination  of  the  external  auditors  when  circumstances 
warrant; 

oversee the independence of the external auditors by, among other things, requiring the 
external auditors to  deliver to the Audit Committee, on a periodic basis, a formal written 
statement delineating all relationships between the external auditors and the Corporation 
and its subsidiaries; 

recommend to the Board the terms of engagement of the external auditor, including the 
compensation  of  the  auditors  and  a  confirmation  that  the  external  auditors  shall  report 
directly to the Committee; and 

when there is to be a change in auditors, review the issues related to the change and the 
information to be included in the required notice to securities regulators of such change. 

8. 

9. 

Audit Committee shall review annually with the external auditors their plan for their audit and, upon 
completion  of  the  audit,  their  reports  upon  the  financial  statements  of  the  Corporation  and  its 
subsidiaries. 

The Audit Committee must pre-approve all non-audit services to be provided to the Corporation or 
its subsidiaries by external auditors. The Audit Committee may delegate, to one or more members, 
the  authority  to  pre-approve  non-audit  services,  provided  that  the  member  report  to  the  Audit 
Committee  at  the  next  scheduled  meeting  and  such  pre-approval  and  the  member  comply  with 
such other procedures as may be established by the Audit Committee form time to time. 

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10. 

11. 

The Audit Committee shall review the Enterprise Risk Management framework and procedures of 
the  Corporation (i.e. hedging, litigation and  insurance), including the  annual review of  insurance 
coverage and make appropriate recommendations to the Board with respect thereto. 

The Audit Committee shall receive regular updates with respect to information technology matters, 
including  with  respect  to  the  Corporation’s  cyber  security  programs  to  address  potential  cyber-
related risks. 

12. 

The Audit Committee shall establish and maintain procedures for: 

(a) 

(b) 

the receipt, retention and treatment of complaints received by the Corporation regarding 
accounting controls, or auditing matters; and 

the confidential, anonymous submission by employees of the Corporation of concerns in 
accordance with the Corporation’s Whistleblower Policy. 

13. 

14. 

15. 

16. 

The  Audit  Committee  shall  review  and  approve  the  Corporation’s  hiring  policies  regarding 
employees and former employees of the present and former external auditors or auditing matters. 

The  Chairman  of  the  Audit  Committee  shall  review  and  approve  the  expenses  incurred  by  the 
President and Chief Executive Officer. 

The Audit Committee shall periodically report the results of reviews undertaken and any associated 
recommendations to the Board. 

The  Audit  Committee  shall  assess,  on  an  annual  basis,  the  adequacy  of  this  Mandate  and  the 
performance of the Audit Committee. 

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