History

• “The environmental assessment struggles to meet minimal requirements and guidelines. It fails many of the tests for acceptable practice, especially for a protected area.
• “Design of rare plant and wildlife surveys appears to have suffered from lack of standard pre-field work information gathering to identify environmentally significant components of the Rumsey Natural Area ecosystem.
• “The field surveys appear to have been cursory and lacking adherence to provincial guidelines.
• “The environmental assessment fails in most aspects as a credible framework to guide development in a sensitive way, in a sensitive area, with sensitive species. It is troubling that government managers accepted this EA as satisfying the condition for pipeline construction.”

• Vegetation has been sprayed on a Husky pipeline, on which crested wheat grass is sprouting. Crested wheat grass has spread up a nearby hillside and will continue to spread (along with smooth brome) unless prevention measures are taken.
• Survey stakes mark a pipeline route and well centre near two abandoned wells in 1-3-34-19-W4. On one of the wellsites, crested wheat grass persists and appears to be spreading.
• Willow thickets in SE24-33-19-W4 have been cleared with a bulldozer.
• A riparian woodland and shrubland in NW36-33-19-W4 have been cleared with a bulldozer.
• Extensive erosion where the main east-west access road (the Poco Road) descends a steep east-facing slope.
• Evidence of heavy grazing and trampling by livestock, some occurring this spring, resulting in a steep south-facing hillside north of the road being almost bare of vegetation.
• Livestock grazing in mid-May in north Rumsey NA. Studies have shown rough fescue grasslands are best grazed in the fall or winter and definitely should not be grazed in early spring.

• AWA is justifiably disappointed an angry that a CBM well was approved without public consultation or notification of key stakeholders including AWA, ANPC, and RDRN. "This is completely unacceptable and contravenes the requirement for public consultation contemplated in the RID. We have submitted objections to the EUB and we are assessing our legal options, including a judicial review to seek remedy for this situation. We do not feel we have been dealt with fairly or reasonably."
• AWA asks that Parks request that Alberta Energy not grant a section 8 continuation to Pioneer for the well, which they were unable to complete by the time their lease expired March 6. "Pioneer was well aware that they were in a protected area and should have been prepared for any extra work required to plan for such a non-conforming and damaging industrial activity."
• The letter points out failings of the application and well location and application of the requirements of the RID. Why is Parks not requiring basic environmental standards and an on-site full-time environmental monitor for oil and gas activities? Monitors are already being used for sensitive private lands.
• AWA asks again for a moratorium on oil and gas activities until a new management plan is developed with full public input, and that oil and gas be phased out of Rumsey as was originally conceived by the RID committee.

March 7: AWA and ANPC meet with Pioneer.

• Pioneer will not be proceeding with drilling this year due to ground conditions.
• Pioneer says they did not consult with conservation interests because they are not on the LSAS and Registry Record, nor do they have standing with the EUB. However, they are also partners with Trident (although not on this well) and obtained Trident's public consultation protocol. Trident met with conservation interests a number of times to explain their plans (once ENGO's found out about their CBM well after it was drilled in 2004).
• Pioneer commits to consultation with AWA and ANPC in any future proposed activities.

Pioneer is unable to drill a CBM well because of unfavorable ground conditions. The lease expires March 6; Pioneer applies for an extension. SRD tells Cheryl Bradley of ANPC that conservation interests were not notified and consulted by SRD about Pioneer’s application because there is no protocol for doing so.

The Technical Advisory Group meets 5 times between Nov 2005 and Mar 2007, including a field trip to view industrial sites in the Rumsey Natural Area. TAG has developed a terms of reference and begun to guide implementation of research projects by PhD and MSc students from the University of Alberta as well as by the Alberta Research Council. Consultants are undertaking range health assessment. Research is focusing on vegetation and soils on industrial disturbances in Rumsey, factors affecting restoration to native rough fescue communities and cumulative environmental effects of land uses in Rumsey.

• Cheryl Bradley (ANPC) learns at a Technical Advisory Group meeting Feb. 26 that approval was given for another CBM well in Rumsey Natural Area - at first she is told it is by Canadian Superior, but later finds out it is Pioneer.
• The application indicates the well is routine and that the surface owner is freehold, neither of which is true. Wells in protected areas are non-routine and the surface owner is the Crown.
• Although it is to be a minimal disturbance well (1m x 1.5m)Community Development and SRD approve the location of the well within 50 metres of wetland, violating provincial guidelines (100 metre limit). This was to achieve flat ground conditions and reduce visual impacts and impact on rough fescue grasslands, but it also violates basic environmental standards and the RID (disturbance of wetlands will be avoided, p. 21). The application indicates there is adequate water body setback.
• The well is in a new location and will require 120 metres of new access road which runs near or through the wetland.
• AWA and the Alberta Native Plant Council are weighing what legal options they have to prevent the well from being drilled, including appealing the issuance of the well licence in the courts.
• Both groups object to the EUB and Pioneer (AWA - March 1, ANPC, March 5; EUB is reminded of the July 2006 tour). Pioneer sends AWA a “Notification of Proposed Pioneer Gas Well Pursuant to Alberta Energy and Utilities Directive 56 Requirements.” AWA responds "It is late to be asking if we have any objections now that the well licence has apparently been issued. Nevertheless, the Alberta Wilderness Association (AWA) registers its strong objection to the proposed wellsite inside an internationally significant protected area and by way of this email, we have copied the AEUB.” 
• The groups are calling for a halt to further oil and gas development in Rumsey. AWA has had a more than 3 decade history in Rumsey and ANPC sits on the government's Technical Advisory Committee which is guiding research on rough fescue restoration and assessment of cumulative effects in Rumsey. The groups argue that the provision in the RID for "ongoing and meaningful public involvement" has never been fulfilled, yet the government insists the RID is the management plan for the area.
• The EUB informs Bradley that IL90-21 is still in efect: "The ERCB will advise the RID committee and the AWA of receipt of any applications for well licences within the Rumsey proposed parkland boundary."

Feb. 23: AWA's FOIP request is delivered. Of the more than 2000 documents said to be in the file, only 124 pages are delivered. (see March, May, August 2006)

Feb. 15: Goudreau responds to AWA's letter of Jan 19: "Regarding your request for an end to mineral sales within the natural area, or that such sales would include no rights for surface access within the natural area, my ministry and Alberta Energy are currently reviewing this situation. When we have completed this review, I will be in a better position to respond. Similarly, we will also be in a position to review the Regional Integrated Decision for the Rumsey Block, and to develop a process for completing a management plan for Rumsey natural Area. Once the management plan process has been initiated, I assure you that the Alberta Wilderness Association will be included as a key stakeholder."

Jan. 23: EnCana ends potential takeover talks with Trident Exploration Corp. Trident has struggled with heavy debt and a lack of interest in its plans for an initial public offering. (Globe and Mail)

• IL2003-25 "applies to all legislated protected areas in Alberta including the Rumsey natural Are and all other sites mentioned in your letter."
• Energy considers mineral agreements as existing commitments in legislated protected areas if:
  • "the agreement was in place qt the time the protected area was established by Order-in-Council; or,
  • "the agreement was publicly posted for sale before the date the protected are was established by Order-in-Council."
  • "An existing mineral agreement may be transferred from one company to another and retain the original access restriction. All petroleum and natural gas leases, including those located in Rumsey natural Area, must be proven productive at the end of their primary five-year term in order to continue production. If an agreement is not productive at the end of the4 term, the DOE discontinues the agreement. The land is then returned to the land-bank and becomes available for resale as a new agreement that carries the current access restriction."
  • "All agreements posted or sold in Rumsey Natural Area after being established by Order-in-Council are considered new and carry access restrictions agreed to within the" RID.
  • Regarding rationale for continuing to sell leases without knowledge of ecological conditions: "Allocations of petroleum and natural gas agreements are issued with the access restrictions specified in the RID." Community Development and SRD are the land management agencies which "address surface management considerations as part of their surface dispositions approval process if and when the agreements are developed."

• official documentation saying Rumsey natural Area is excluded from IL2003-25.
• the list of the 9 other sites excluded from IL2003-25.
• if any leases sold in the Rumsey NA after 1996 are considered new.
• the rationale for continuing to sell leases in the NA and insisting on surface access prior to any conservation studies (as required by the RID) being done to show whether ecological integrity is being maintained or not.

Sept. 15: The Office of the Information and Privacy Commissioner confirms that Community Development has agreed to waive all fees on AWA's FOIP request (see March, May, August) "on the grounds that the records pertain to a matter of public interest."

July 11: Response from Community Development re FOIP request fee waiver (see May): "While we are prepared to accept that there may be a public interest in some of the records you have requested, specifically those that pertain to the 'involvement of different government departments in efforts to protect or develop Rumsey,' we do not believe that this would extend to all of the records requested." The fee is reduced to $656.50. (see August)

June 27: Response from SRD to AWA's May 11 letter: SRD "continues to work with other government agencies, industry and stakeholders to minimize the footprints and maintain the Rumsey area's ecological integrity according to the goals of the" RID.

May 11: AWA sends letters to Ministers Ducharme (Parks) and Coutts (SRD) asking for:

• no further industrial activity take place in the Natural Area.
• the opportunity to develop a management plan that befits a nationally significant protected area.
• a moratorium on all CBM activity in the natural Area until the studies laid out in the RID, including a cumulative effects assessment, are completed and it can be proven that the goal of the RID is being met.
• EUB hearings on any new proposed industrial activity in protected areas.
• a province-wide review of protected areas, policy and legislation, and what the public wants done with them.
• a meeting [although a meeting was promised, Ducharme was moved out of the portfolio with the change in premiers in December].

May 11: AWA also responds to Alberta Energy with similar requests, and to Premier Klein. [see archive]

May 17: EUB responds to ANPC regarding Trident's co-mingling application in Rumsey NA (see Dec. 2005): The EUB decides to continue processing the application without a hearing because it meets all the regulatory requirements. EUB maintains co-mingling will have surface impacts and approval does not mean wells or other activities will be approved. "While IL 2003-25 addresses Existing Mineral Commitments in Legislated Provincial Protected Areas, the lands applied for in the above referenced application are not in a protected area and therefore are not subject to the provisions of IL 2300-25."  When queried why EUB maintains Rumsey is not a protected area, no response is received, although AWA and ANPC hear that EUB lawyers are not happy with the wording.

AWA submits a request under the Freedom of Information and Protection of Privacy Act (FOIP request) for information from 2005 to May 2006. The charge for the information is estimated at $1,097. (see June)

April 24: A memo from Fay Orr, DM Community Development to Dan McFayden, Energy essentially repeats message in the briefing note of Oct. 2005.

April 12: AWA attends the annual EUB-ENGO meeting in Calgary and makes a presentation on the situation in Rumsey. AWA offers the EUB a virtual tour and a field tour.

Community Development has given 18 approvals for surface dispositions for access to mineral rights sold prior to 1996. Approvals for 10 other applications are pending.

April 3: Energy criticizes Community Development for not moving forward or "facilitating" approval of well applications that have been on hold pending a review of the Il2003-25 issue (see March 2006). Doug Bowes, Community Development, says CD is not stalling and reviewing applications is time-consuming. "Energy better be prepared to allow the standard process to unfold. We should not feel pressured to approve an initial application without the standard review and approval process being followed through to the end. Energy won't be the ones at the end of the day taking the flack for a rushed and forseeably botched approval in Rumsey. What point is there in us participating if Energy is intent on forcing us to accept any old application and damn the consequences of not reviewing it first to determine the best location and construction conditions?"

AWA letter to Premier Ralph Klein: (see reply May 2006)

• AWA objects to the unethical and dishonourable behaviour of Alberta Energy bullying their way into opening up more development in Rumsey.
• AWA asks for:
  • Alberta Energy's decision to be reversed and no new drilling be allowed in the Rumsey Natural Area.
  • EUB hearings on any new proposed industrial activity in protected areas (as a short term measure to deal with these situations until they are all resolved.)
  • A province-wide review of protected areas, policy and legislation and what the public wants done with them. This would be separate from the proposed Land Use Strategy.
• We need to focus on restoring past industrial disturbances, not making new ones.
• The Rumsey block is a tiny island in a sea of development in the Parkland and Grassland. Talking about balancing development and protection in Rumsey is ridiculous. The government has not met conservation goals in either of these natural regions.

A Calgary Herald editorial suggests that it is time to review the idea that protected areas should be out of bounds for energy development if the energy is in short supply.

Hansard, March 21:

• Dr. Kevin Taft, Alberta Liberals: This government's decision to allow petroleum drilling in Rumsey Natural Area is clearly a fundamental contradiction in government policy. Either special areas are protected or they aren't....Why does this government allow overruling of the Minister of Community Development in allowing the Minster of Energy to open the possibility of drilling the Rumsey natural area, an area your government supposedly designated as protected?
• Greg Melchin, Minster of Energy: I think one of the first things we need to clarify is that the Rumsey area is an area that has been valued...there is a current management plan that does accept petroleum and natural gas postings in the natural area. However, in the natural area, which is not the reserve, even those are issued under very strict restrictions and constraints....years ago when they went into the special places that were designated, there was a management plan put under for all of those areas. In these cases, in the reserves specifically, there is no drilling activity allowed. Under the other areas, the broader area, the natural area, it's under strict guidelines. That was that plan that is being followed, that was approved from day one.

AWA News release, March 20: "Alberta Energy's conniving and duplicity are a grand betrayal of the public trust,” says Cliff Wallis, AWA Past-President. “It’s outrageous that they have used  unethical and dishonourable behaviour to bully their way into opening up more development in this unique area. This is one of the worst abuses of public trust that I have seen in my 30 years of working to protect Alberta's wild places. We will oppose this every step of the way." 

Joe Miller, Executive Director, Alberta Energy and John Kristensen, ADM, Community Development sign an "Access Review of 'Subject to" Natural Area Parcels.

• The existing policies and practices are:

  • IL 2003-25 provides direction for existing mineral commitments in all protected areas.
  • Mineral rights in protected areas are sold with addenda that correspond to the levels of surface access as defined in management plans.
  • Changes to existing levels of access require consultation with affected departments and, as necessary, affected stakeholders.
• Proposal:
  • Energy and CD will review lands with a "subject to" access level to determine if they merit any change
  • the process will review and make recommendations on what happens with theses lands when they are returned to the land bank.
  • SRD will be involved.
  • The report is due June 30, 2006
  • During the review, Energy will reserve from disposition any parcels that have not been sold in the "subject to" Natural Areas (10 sites, includes Rumsey)
  • CD will facilitate access to mineral commitments sold as "surface access subject to specific restrictions" if the agreement holders have done their due diligence.
  • The process will objectively evaluate the natural resource values of each parcel and their contribution as a Natural Area to the3 protected areas system; and will evaluate the mineral resource values of each parcel with respect to tenure type and status, and the development activity within and adjacent to each Natural Area.

A Technical Advisory Committee is established in 2006, including representatives from ANPC (Cheryl Bradley), industry and academia to guide research regarding reclamation and cumulative effects commitments in the RID. Terms of Reference for the Rumsey Parkland Project are created: Review of the Reclamation/Restoration/Remediation Program in the Rumsey South (Rumsey Parkland).

Alberta Energy sends an interdepartmental directive to Community Development directing that approval be given for surface access to mineral dispositions with the "subject to conditions" addendum. Energy says it will continue to sell rights with the expectation access will be provided. To date, one well per section is being allowed.

Once again Alberta Energy hijacks the agenda in Rumsey by Alberta Energy while reneging on their promise for protected areas. Although the 1993 RID allows oil and gas development in perpetuity, Alberta Energy Information Letter 2003-25 says that new commitments in 81 Special Places, which includes the Rumsey Natural Area, will not be allowed surface access. Alberta Energy reneges on that promise and allows surface access for rights sold in Rumsey after its designation as a natural area in 1996. This means an open door to CBM development in the area, an activity never contemplated in the RID or the 2001 Assessment.

Trident has put its drilling plans on hold for this winter because they have not completed the application process.

AWA and ANPC meet with Trident to review map of proposed wellsites in Rumsey and the company’s compliance records.

December 16: SRD Minister David Coutts replies to AWA's November letter with an almost exact copy of a previous reply letter. AWA writes (Dec. 22)back listing the questions asked in the November letter again. SRD refuses to answer the questions (Jan. 13 reply).

Dec. 14: An application #1435383 is filed with the EUB by Trident Exploration Corp (with Fekete Associates) to obtain approval "to produce gas without segregation in the wellbore from the Edmonton sands and coals" in the Natural Area (Twp 33 Rge 19 W4). This lack of segregation is called "commingling" of production and approval is required as per EUB Directive 65 (section 3.1 and 1.6). Trident wants approval for this since the "coal seams are low pressure and have very low productivity" and "commingling reduces the number of wells required." AWA and ANPC write letters of objection to the EUB. Reasons are that commitments in the RID are not being met, concerns about the impacts of CBM development on the ecosystem and hence on the RID goal and that approval of this application will constitute approval of the drilling program. Is the public interest being met? [ANPC receives a response in May, AWA never receives a response.]

Nov. 14: Memo from Fay Orr, DM Community Development to Don Keech, Acting DM Alberta Energy, response to Oct. 20, 2005 memo regarding application of IL2003-25 in Rumsey: Community Development has not changed its interpretation of the IL. The disagreement between the two departments is on the application of the IL to 10 sites, including Rumsey, initially established as Special Places. "The IL clearly applies to Rumsey Natural Area, and therefore in those cases where conflicts exist between the IL and the 1993 Regionally Integrated Decision ..., the IL which was signed most recently would prevail.....This is an important and contentious public issue that must be addressed as quickly as possible." Suggests a meeting to discuss respective concerns and moving forward.

AWA asks Trident for a meeting to discuss their records of non-compliance, a copy of their environmental policy, and the locations of their proposed wellsites. [Feb. 2006]

Greg Melchin, Minister of Energy, writes in a Nov. 7 letter to AWA: "I assure you the Alberta government places high priority on the protection of our environment."

SRD Minister David Coutts writes in a Nov. 9 letter to AWA: “In regard to current reclamation and restoration activities in the Rumsey area Sustainable Resource Development has been working with representatives from the environmental community to develop a project that evaluates reclamation and restoration achievements. Specifically, the project will evaluate previous development and reclamation practices by looking at the level of restoration of the plant community and potential threats posed by invasive species and weeds. The groups will make recommendations to refine minimum disturbance practices for fescue parkland and make specific recommendations for management for the Rumsey Natural Area and Ecological Reserve.”

ANPC (C. Bradley) agrees to participate in a Technical Advisory Group (TAG) to guide the review of reclamation/restoration in Rumsey.  Participants include SRD, CD, Alberta Research Council, and Oil and Gas industry specialists and a professor with the Department of Renewable Resources, University of Alberta. Research is planned which will help evaluate if current management is achieving the goal of the RID and if management meets the expectations of a provincially designated protected area.

However, the budget for such projects by Public Lands was slashed this year. So AWA writes in reply to Coutts Nov. 9 letter that:

• We expect the study to include all the studies mentioned in the RID, including biophysical inventories, cumulative effects of oil and gas developments, past and current reclamation, and vegetation monitoring as well as "ongoing and meaningful public consultation."

• We expect funding to be available without "fundraising" by Public Lands. "We expect the government to invest in the protection of our natural resources at a level commensurate with their significance. The international significance of Rumsey and other protected areas in Alberta is well-known, yet we see a disproportionate allocation of government surpluses to questionable non-essential ventures like movies [Premier Klein gives $5.5 million to a war movie], and virtually no allocation of government surpluses or operating funds to the protection of Rumsey and other globally significant sites. Such actions ...clearly demonstrate the low value that Alberta places on safeguarding our natural heritage."

• "We look forward to a clear commitment from Alberta to protecting our protected areas, with adequate funding for their preservation as well as the complete removal of industrial activity being the most important indicators of that commitment."

• We propose no new industrial activity in Alberta's protected areas

• We propose one billion dollars be put in an environment (air, land, water, biodiversity) fund, to be jointly administered by Sustainable Resource Development, Alberta Environment, Community Development and the public.

• "we believe that a stakeholder is anyone who has expressed an interest in the areas where we operate"
• "Trident would be happy to sit down with a representative from AWA to view and further discuss any non-compliance issues we have either received or self-filed."
• "we are happy to share our environmental policy with interested stakeholders."

Trident holds another public meeting with government representatives and conservation groups.

• They scouted out well locations and are drilling 29 wells (28 on public, 1 on private land) instead of 31, 11 of which must be drilled before the end of the year. However, due to warm weather, they have obtained permission to delay drilling. They plan to drill wells this winter.
• The wells represent new wells and new access (can be within 100 meters of an approved access road).
• Site selection based on a number of factors including existing access routes, well-drained soil, vegetation types, existing disturbed or reclaimed areas, aesthetic concerns.
• In the process of finalizing Area Operating Agreements
• Will use as little infrastructure as possible.
• All compressors will be put outside the Natural Area, but this means larger diameter pipelines will be used (outside diameter of 5 inches). This is the largest pipeline proven to withstand plough-in installation.
• They are negotiating use of some existing pipelines.
• Will develop 2-3 staging areas where approved vehicles can be cleaned to mitigate weed contamination. Will have vehicles dedicated for use in the Natural Area.
• Wells on SCADA monitoring system to eliminate need for daily service visits.
• Fluids will be trucked out.
• Writing mitigation plans for each location, including mock corrals to maintain an agricultural look and paint colours that blend into the environment according to season. Vegetation monitoring 2/year for a few years, then 1/year, then review after 5 years.
• use of minimal disturbance, natural recovery, reseeding on large disturbances. Research on revegetation methods being conducted on the first well site on trenched in pipeline. Winter drilling part of minimal disturbance, minimizes compaction of soil.
• Trident has approached some other companies with mineral rights in Rumsey and suggested working together to ensure consistent operating practices. Not all companies wish to do so.
• Public Lands says they are telling other companies they will need to raise the bar in terms of environmental performance in the Natural Area and that Public Lands is under no obligation to meet reduced spacing if companies apply for it, ie Public Lands doesn't have to approve more than 1 well per section

Oct. 20, 2005: Memo from Bill Richards, Community Development to Don Bradshaw, AB Energy re mineral postings for December sale which includes 22.75 sections. (see Sept. 2005) "Community Development expects that all future requests for sales affecting any lands within Rumsey Natural Area will either be postponed until our ongoing discussions related to IL2003-25 are concluded or, if sold, will be sold with the requisite No-Surface-Access addendum in accordance with IL2003-25. Community Development definitely will not give consent to surface access for any sales that occur after the date (September 14, 2005)."

October 18, 2005: Memo from Don Keech, Acting DM, Energy to Fay Orr, DM, Community Development regarding IL2003-25: CD has changed their interpretation of the intent of IL2003-25. "The current interpretation is significantly different from the joint agreement reached between our departments when the IL was developed. The issue has been discussed between staff of our departments for several months without resolution....IL2003-25 addresses how government deals with existing surface and subsurface commitments following the conclusion of the Special Places 2000 Program. The IL does not, nor was it intended to, address the level of access and development permitted within individual protected areas ro classes of protected areas. It does not change the Special Places 2000 Policy, which is clear that levels of access and development will be addressed through site specific management plans. Of immediate concern are issues in the Rumsey Natural Area, where your staff has communicated to us in writing that they will deny surface access as of mid September 2005 to all future mineral rights sold. Rumsey is managed under a Regionally Integrated Decision (RID) approved in 1993 by Sustainable Resource Development, Community Development, Alberta Energy and other provincial government agencies. The RID allows for surface access for oil and gas activity in portions of the natural area, and specifically refers to the posting and sale of new mineral rights within the natural area. To my knowledge there has been no government decision to re-open or modify the RID. In light of thi8s, Alberta Energy will continue to sell mineral rights in Rumsey and other protected areas consistent with the level of access restrictions identified in the respective government approved management plans. When mineral rights are sold the Crown is obligated to provide access in accordance with the level of access indicated at the time of sale." (see Nov. 14, 2005)

Oct 7, 2005: Email from Doug Bowes to others in Community Development re mineral sales posting by AB Energy (see Sept. 22, 2005): Don Bradshaw of AB Energy advises that Energy has completed the majority of the requested site review and that the Rumsey mineral postings will go forward in the December sale, which is usually the biggest revenue sale of the year. Energy will be contacting CD at the DM level to discuss the IL2003-25 issue. "We have twice now on recent posting requests responded to advise that until this issue is resolved we believe such sales should be postponed or at least sold with the NAS [no-surface-access] addenda consistent with IL2003-25. In both responses we also advised them that we would not give consent in the future for surface access to any future leases that are sold without the NSA addenda in any of the 10 sites (including Rumsey)."

Community Development prepares a briefing note on IL2003-25" Honouring Existing Commitments in ten natural Areas Including Rumsey Natural Area.

• The Issue: Ten of the first twenty-six protected areas designated under the Special Places Program are not covered by a no-surface-access addendum for ongoing mineral sales. CD requested that Energy amend the addendum on all lands included in these sites, contending that it was an oversight that resulted in a failure to update the addendum at an earlier date. Energy contends that Cabinet's commitment (under Special Places) that there would be "no new development" in parks and protected areas does not apply to these 10 sites, despite signing off on Information Letter (IL) 2003-25 which acknowledges this commitment and refers to all "81 protected areas" established under the program.
• The ten sites were included on a list of 26 new natural areas established as part of the kick-off of the Special Places Program in 1995.
• On Jan. 6, 1997, the government began to apply "Interim Protection Measures" for candidate sites under Special Places to prevent the introduction of new conflicts/commitments prior to final decisions on designation, resulting in the sites only being impacted by the development of "existing commitments."
• March 2, 2005: Energy agrees to examine their files and review the status of subsurface commitments and sales activities in each of the 10 sites not covered by IL2003-25 and to assess potential options for resolving the issue. Community Development requests that any further mineral postings affecting these sites be postponed until the issue is resolved or, if sold, that they be sold with a no-surface-access addendum consistent with Cabinet's commitment, Special places Policy, and IL2003-25. CD receives information on mineral interests in Rumsey, but not the other 9 sites.
• On two recent requests for mineral postings in Rumsey Natural Area, CD indicates Energy should postpone both sales until the issue is resolved or, sell them with a no-surface-access addendum. CD also indicates it would not provide Ministerial consent for surface access on any further interests sold after September 14, 20905. Energy indicated that it intends to proceed with postings for an additional 21.5 sections with the Natural Area in its December sale and that these lands will be posted with the addenda currently in place, pursuant to the Rumsey RID. These addenda do not preclude "new development" within the natural area.
• "It may be impossible to protect the integrity of Rumsey over the long-term from the impact of honouring the 35 "existing commitments." Providing additional access for any of the 56 interests purchased since site designation will make this task more difficult."
• Cultural Facilities and Historic Resources Division has identified the entire Rumsey Natural Area as a significant historic resource pursuant to the Historic Resources Act.

Sept 22: Email from Doug Bowes, Community Development to Don Bradshaw, AB Energy: Another mineral sale requests even more lands be posted than in the previous posting request for one section (see Sept 7, 2005). The same lands discussed then, which AB Energy agreed to hold of on until discussions regarding IL2003-25 were concluded are included again in the current posing request which is for 21.5 sections in the Rumsey Natural Area. Bradshaw promises to look into the matter (see Oct 7, 2005 and Oct. 20, 2005).

Sept 14: Email from David Wren, Community Development to Don Bradshaw, AB Energy regarding a mineral sale in 4-19-033:24 NW. There is also an attached memo. "This sale indicates correctly that the NW quarter is subject to a level 1 addendum (no-surface-access). However, it also indicates that the other three quarters (SE, SW &NE) are subject to a level 3 addendum (access subject to restrictions). Community Development expects that all future requests for sales affecting any lands within Rumsey natural Area will either be postponed until our ongoing discussions related to IL2003-25 are concluded or, if sold, will be sold with the requisite No-Surface-Access addendum in accordance with Il2003-25. Community Development will not consent to access within the natural area for new interests sold after today's date."

Sept 7: Email from Doug Bowes, Community Development to Don Bradshaw, AB Energy regarding a proposed mineral sale in the Rumsey Natural Area. "All of us are still awaiting the final outcome of our discussions on the issue of existing commitments within Rumsey Natural Area in particular, and the nine other sites previously identified as well. Community Development continues to expect that all requests for sales (affecting any of the ten identified sites) will be postponed to ensure this government does not further complicate the situation if it is determined that such sales should not be posted as per our interpretation of IL2003-25."

• Two abandoned, unreclaimed well sites with mixtures of native and non-native species colonizing largely unvegetated areas of gravel and sand.
• Trident's first CBM well with a 5 metre wide row of cleared native vegetation planted to annual rye. The vegetation adjacent to the well site and road has been invaded by non-native species.
• Over-grazing resulting in changing plant community from rough fescue to mixed-grass.
• Deep tracks eroding a hillside.
• Invasive, non-native species along the Poco Road.

AWA sends letters with photos to the Ministers of SRD, Community Development and Energy.

• The goal is to share their tentative plans and encourage feedback.
• Their first well is not producing yet because of high line pressure, but expect this will decline as more wells are brought onstream.
• They say they want to "raise the bar within the petroleum industry: by minimizing their environmental impact.
• Trident has 100 percent mineral ownership in five sections and contractual agreements with other companies to develop 26 other sections, 18 of which must be drilled before the end of the year, otherwise they revert to CNRL, the original owner.
• They plan to drill one well per section to gather data to see how many ore wells per section are needed. They don't believe it is economically viable to drill more than 4 wells per section.
• They have decided to drill only in the upper Horseshoe formation and not in the lower Mannville.
• Their plan is for minimal impact, use of existing leases and access roads, and micromanagment. They will not do a cumulative effects assessment as they feel that they are only one of many users of the land.
• They offer to reclaim some of the other sites and fund a PhD student to study longer-term reclamation.
• ENGOs concerned about rushing into CBM in Rumsey without appropriate background studies to show what is feasible and what will protect the integrity of the area. Note that we still don't know how to reclaim rough fescue.
• Trident will ensure that all identified stakeholders are apprised of any news developments in their plans for drilling in Rumsey, including when they file the formal applications to the EUB.
• ENGOs push for a volunteer stewardship opportunity in the area. Community Development says they don't usually give stewardship in areas where there are leaseholders.

Public Lands planning an evaluation of industrial impacts in Rumsey that can be applied to a cumulative effects analysis. They say "reclamation practices have evolved over the past three decades at Rumsey suing available techniques and approaches but firmly adopting a philosophy of minimum disturbance by reducing surface impacts (footprint) and promoting natural recovery of the Fescue Parkland plant communities....Oil and gas activity continues to potentially influence the incremental effects on the basic integrity of the Rumsey Aspen parkland, additional studies are required to assess past and present reclamation. The proposal to introduce and allow coalbed methane extraction may further impose concerns relative to maintaining the natural qualities associated with the Parkland. In the effort to adhere to the objectives of the RID, a review is required to conduct a study on the ecological integrity of the Parkland."

• They will develop a Terms of Reference with input from project partners, who include Cheryl Bradley and Kirsty Venner (Trident).
• They will catalogue well sites, do a literature review, a develop a monitoring protocol in fall 2005 that will provide the scope of work for assessment of industrial sites in 2006.
• "The detailed scope of work will permit the development of a budget and provide a target for fundraising from government, industrial and conservation community stakeholders."
• Once the initial background work is completed, they suggest engaging a local group of stakeholders, as a steering committee, to share in the review of the results and make further recommendations about management of the area.
• Cheryl Bradley suggests that restoration, not just reclamation, be the goal, that the work encompass the entire Rumsey Block, including the Ecological Reserve, and that the current advisory committee for the Reserve be kept informed.

Greg Melchin, Minister of Energy, writes to AWA: "Management direction provided by the RID ensures the protection of the environment and the complete reclamation of oil and gas disturbances."

Gary Mar, Minister of Community Development, writes to AWA: "We are working closely with Alberta Sustainable Resource Development  to manage industrial access to Rumsey Natural Area in strict accordance with the provisions set out in the Rumsey Regionally Integrated Decision."

In response to AWA's request for volunteer steward status for Rumsey Community Development says volunteer stewardship for the Rumsey Natural Area is "not available at this time." [In a subsequent Trident multistakeholder meeting, Parks says ENGOs must get a letter of permission for stewardship from the grazing leaseholders.]

SRD and Community Development plan to meet with all industry stakeholders in Rumsey to discuss their plans and expectations and tell them what the government expects.

April 24: Memo from Fay Orr, DM, Community Development to Dan McFayden, DM, Energy, follow up on meeting to discuss energy activities in certain [probably the ten excluded from IL2003-25] natural areas, including Rumsey. Notes that Rumsey Natural Area is particularly sensitive and high-profile because it was legislatively protected in 1996 under Special Places, extremely popular among natural historians and environmental organizations, represents one of the largest undisturbed natural grassland and parkland areas in Alberta, the largest area of rough fescue is found here; AWA has a keen interest; AWA and other ENGOs monitor the area very closely. "Many individuals and organizations are telling us that they would be much more accepting of energy activities on non-protected area Crown lands if our government minimized these activities within protected areas." Looking forward to resolution of energy activities within these particular natural areas so there is consistency of application of IL 2003-25.

April 20, 2005: email from John Kristensen, ADM Parks, regarding request for feedback for the government's multistakeholder advisory committee on coalbed methane: notes people are upset about the possibility of CBM within parks and protected areas. "we therefore need to minimize to the greatest extent possible CBM development inside PPA's, notwithstanding IL2003-25, in order to show Albertans that the GOA [Government of Alberta] is aware of the balance required in extracting natural resources and protecting PPA's." Notes many Albertans think of CBM as something brand new, especially because of the greatly increased well spacing unit requirements and the impact this will have on the land.

• No evidence that the RID goal is being met or that energy development is not negatively impacting the area
• guidelines for monitoring studies, cumulative effects assessment and public involvement not being met.
• RID has no legal status, no penalty if guidelines are not met.

March 16: A meeting between SRD, Community Development and Trident re CBM. Notes say: " EUB consideration for additional spacing requirements presents a surface concern to us; PPA [Parks and Protected Areas] is not generally supportive of it for Rumsey due to the sensitivity of this underrepresented ecotone and its resulting National and International significance. We prefer that a request to EUB for additional spacing requirements not precede the first CBM wells and after it is demonstrated what one well/Section produces."

March 2, 2005: Energy agrees to examine their files and review the status of subsurface commitments and sales activities in each of the 10 sites not covered by IL2003-25 and to assess potential options for resolving the issue. Community Development requests that any further mineral postings affecting these sites be postponed until the issue is resolved or, if sold, that they be sold with a no-surface-access addendum consistent with Cabinet's commitment, Special places Policy, and IL2003-25.

Jason Unger, AWA says: "AWA believes that CBM development is contrary to the purpose and intent of the Natural Area designation and that it will significantly under mine the conservation values of Rumsey. We are asking government to suspend CBM development in the area, to designate it as a Heritage Rangeland and to revise the management plan to reflect its status as a protected area." He says that mineral rights have been consistently posted following the designation of Rumsey as a Natural Area in 1996, including areas of land that had no legal obligations linked to them or had dispositions that subsequently expired, contrary to the purpose of Alberta Energy Information Letter 2003-25 (see below) (WLA Feb. 2005)

SRD responds: "management criteria and direction, as established in the Regionally Integrated Decision of 1993, recognized oil and gas activity as an acceptable land use in the Rumsey Natural Area, subject to stringent guidelines...The present designation will continue with the RID serving as the management directive as it contains provisions that ensure it is kept current and relevant."

A Wild Lands Advocate article details the deficiencies of the implementation of the RID. The government says the RID remains the management directive but it is only following some of the recommendations governing continued use of mineral and agricultural (grazing) resources, not those governing conservation or public involvement. It has never done the monitoring, inventories, cumulative effects analyses, or annual or five-year reports. The exception is a 2001 assessment by regional managers that determined there would be no major review. At the time it appeared petroleum-related activities were subsiding and CBM was not considered. The government has also never ensured “ongoing and meaningful public involvement as the RID is implemented.”

Public Lands Barry Cole tells AWA that "remediation of any impacts [due to oil and gas] to an acceptable level is a primary objective." (WLA Feb. 2005) SRD's main strategy is to use minimum disturbance sites, reduced surface impacts, promotion of natural recovery, "no go" areas as an effective approach to cumulative effects.

Cheryl Bradley disagrees: "They've started doing some range health assessment, but they can't show me that the ecological health of Rumsey is not in jeopardy, because they haven't done the monitoring to show it we're maintaining ecological integrity." There has been no mapping of fescue grasslands or locations of weedy species. "Without this information we have no way of knowing if we are meeting the management goal of the RID." She points out that the invasion of non-native species is the most critical thing.  In a letter to Public Lands: "The potential for invasion is exacerbated by surface disturbance and access which introduces aggressive invaders....A cumulative effects analysis must be conducted before any further development goes ahead."

The standard for reclaiming prairie and parkland landscapes in Alberta is "to promote the re-establishment of sound ecological function and the eventual restoration of the original range of variability in biological structure and diversity."

Gary Mar, Minister of Community Development writes to AWA: "Oil and gas developments are generally not compatible with the purpose of Alberta's parks and protected areas, and thus, the Alberta government has committed to phasing out industrial activity within these sites. This means that these activities will be phased out as the oil and gas resources are depleted and, in the interim, we will be doing everything possible to manage and minimize the disturbance of oil and gas activities on these lands. Depending on environmental, economic and technical factors, the time over which these activities can be phased out will vary in different sites. Interdepartmental discussions between senior officials are currently occurring on the issue of coal bed methane development in Rumsey natural Area. My staff are working to ensure that natural gas activities, including coal bed methane, are eventually phased out of this internationally significant protected area....Regarding your suggestion to re-designate Rumsey as a heritage Rangeland, please understand that there are six other sites, presently identified as heritage Rangeland natural Area, that still require re-designating as Heritage Rangelands. As such, for the time being, our focus will be on these sites."

Jan. 27, 2005: email from parks to an unnamed company: "Community Development (Parks and Protected Areas) with Sustainable Resource Development (Public lands) will be inviting companies with subsurface mineral interest in the Rumsey natural Area to discuss their development plans....With some CBM development added to the conventional O&G extraction which is ongoing, greater integration and sharing of infrastructure (roads/pipelines) will need to occur to keep disturbance of the protected site to a minimum. Knowledge of the potential cumulative impact from the total anticipated development (before it continues in a piece-meal fashion) will be desirable to best manage the footprint that it is expected to have." SRD was in charge of organizing the meeting.

A meeting of NAFTA's Commission on Environmental Cooperation on grassland identifies important grassland areas throughout the Great Plains in North America.

Cheryl Bradley says: "Alberta has the largest area of rough fescue grassland in North America. We are guardians of an important global heritage. Rumsey is right up there as a very highly significant grassland internationally. And I just can't believe we still threaten it with the death of a thousand cuts. It's unconscionable to me."

Alberta Community Development says it is working with Trident to ensure there’s minimal disturbance of the landscape. John Koch, VP of Trident says his company hasn’t decided whether or not to proceed with commercial coal-bed methane development in the area. If it does, it will make sure to use existing roads and pipeline right of ways and will do everything it can to minimize surface disturbance. He speculates that CBM development in Rumsey could be worth potentially billions of dollars. (FFWD, Oct. 21-27, 2004)

Kyla Fisher, Trident PR official, says "the question is whether drilling is the responsible thing to do" and that Trident needs more information about the area's sensitivities before determining whether drilling can be done while preserving the grasslands ecology. However, she also says that Trident will do its utmost to minimize any effects and will work with stakeholders to minimize impacts. (Red Deer Advocate, Oct. 21, 2004) "If we're going to drill in the Natural Area, we're going to make sure that we do it right. Doing it right, as far as we're concerned, is doing it in collaboration with the other groups." She says that if the message that comes across loud and clear from everyone is not to drill in Rumsey, then Trident will need to evaluate that. (WLA Dec. 2004)

Jason Unger, AWA Conservation Specialist says: "It's good that Trident is taking a proactive approach. But even tough Trident proposes to minimize disturbance, best practices means staying out of a protected area." (WLA Dec. 2004)

Cheryl Robb of Alberta Community Development says that Special Places would never have gone ahead if there was no agreement to honour existing sub-surface mineral rights.  (Red Deer Advocate Oct. 21, 2004)

Cheryl Bradley points out that the the debate is not with Trident about how to proceed, but with the government on whether we should proceed. Government's job, she says, is to protect the public interest from the corporation. "I think it's really dumb that we don't have any commitment when we designate an area as a protected area." Jason Unger, AWA, says, "When the government presents the idea of protected areas to the public, they public should be able to rely on the claim of protection." (WLA Dec. 2004)

The EUB  refuses to provide notice to AWA for well applications saying there is no requirement in the RID for the EUB to provide specific notification to AWA and directs AWA to use its website. However, IL90-21 is still in effect: "The ERCB will advise the RID committee and the AWA of receipt of any applications for well licences within the Rumsey proposed parkland boundary."

In a November 17, 2004 letter to AWA, Hon. Mike Cardinal, Minister of ASRD writes: "Continued applicability of the Rumsey RID to potential CBM activity will be evaluated on an ongoing basis."

Government has followed recommendations in the RID governing continued use of mineral resources and agricultural resources (grazing), but has not followed through on key recommendations aimed at protecting the area's ecological integrity. Studying and monitoring ecological integrity is essential to know if the management goal is being met. 

Recommendations regarding ecological integrity in the RID which are not being implemented or for which there is not logical follow through include:

• Further studies to assess the success of past and current reclamation activities (RID, pages 23 & 25). A 1991 Integrated Environments Ltd. (IEL) study concluded restoration to native condition was not occurring on well sites and large pipelines and that non-native species were invading native grasslands. The Public Lands manager in a recent email states “…there has been little success in advancing the use of native seed and much of the work within the NA has promoted reduced surface impacts that will allow for natural recovery.”  Natural recovery has not been demonstrated.

• Biophysical inventories with emphasis on rare and sensitive ecological resources and manage activities to avoid these (e.g. rare plant species survey, rare vegetation community survey) (RID, pages 10, 21, 25). No action.

• Review of the cumulative effects of existing and proposed oil and gas developments as it relates to the ecological integrity of the area (RID, page 25). No action.

• Monitor vegetation change and assess relative to factors of fire, climate, grazing (RID, page 25). A range inventory was conducted in 1994. Invasion of aggressive non-native species (e.g. awnless brome) has been identified as a problem in the Ecological Reserve and along access routes in the Natural Area, but currently there is no action to control it. Range health and riparian health assessments have not been undertaken.

• Initiate a program to control aspen and brush expansion to the 30% ratio (RID, page 10). No action.

• Review recreational activities that occur to ensure the environmental integrity of the resource base is maintained (RID, page 17). No action.

• Annual highlight summaries and a Plan Assessment report every five years which are available to the public (RID, page 36). An internal Plan Assessment was completed in 2001 and regional managers determined there would be no major review. At the time it appeared petroleum related activities were subsiding and CBM was not considered.

• To ensure ongoing and meaningful public involvement as the RID is implemented. (RID, page 34). No public involvement in the Rumsey Natural Area besides leaseholders. Volunteer stewards have not been allowed in areas where there are leaseholders.

Trident hold its first public meeting Oct. 18 to inform "identified stakeholders" of their intentions and to help increase their understanding of CBM.

• The Rumsey block, as the largest remaining representative site of
  aspen parkland and plains rough fescue grassland in Canada, has long
  been an area of conservation interest. The first Prairie Conservation
  Action Plan (released by the Government of Alberta and World Wildlife Fund Canada in 1989) called for provincial protection of the Rumsey block. In 1990, the northern part of the block was designated an Ecological Reserve. In 1993, a Regionally Integrated Decision
  (management guidelines) was adopted for the southern part of the block. In 1996, the southern part of the block was designated a Natural Area under the provincial Special Places program. This was intended as a 'holding' designation, pending ability to designate as a Heritage Rangeland, which came with the Bill 34 amendments to the Wilderness Areas, Ecological Reserves and Natural Areas Act. Designation as a Heritage Rangeland has not yet occurred.
• A new management plan did not anticipate coalbed methane (CBM).
• CBM is considered an experimental activity as information from existing wells is being used to inform the Alberta government's current review of the regulations that govern natural gas in coal development.
• The CBM under development in Rumsey is shallow and CBM wells typically require an initial density spacing two to four times greater than that of conventional gas development, which has historically occurred in the area.
• Currently there is very limited evidence of successful restoration of rough fescue grassland following industrial disturbance.

Not surprisingly, members representing the National Energy Board, the Natural Resources Conservation Board and the AEUB were present and abstained from signing on to this letter. Reply from CD (Gene Zwozdesky) that Ministers are “working to ensure the long-term viability of this area and its contribution to the parks and protected areas network.”

August to October: AWA (Jason Unger), ANPC (Cheryl Bradley) and RDRN (Dorothy Dickson, Margaret Coutts) have telephone conversations and meetings with Trident. They provide input into Trident’s assessment of risk in proceeding with CBM development in Rumsey. Trident intends to develop an area operating plan. AWA and ANPC inform others in the conservation community of Trident’s plans.

Trident starts to research the significance of Rumsey, who was/is involved and starts meetings with people to find out what would be some of the best practices. Trident admits: "The company knew right from the beginning that it was an ecologically sensitive area."

Cheryl Bradley writes to Public Lands saying that CBM extraction is not consistent with the goal of the RID. "Alberta Energy maintains that CBM development is in an experimental phase in Alberta. A Natural Area...is not the appropriate place for such 'experiments.'"

Public Lands says: "Public Lands has emphasized to Trident the need for long term planning to equip us with the information to make a balanced land use decision and yet maintain the integrity of the Block....The true test of balance will be ensuring that the management goal for the Rumsey parkland South natural Area is met and the values associated with the Ecological Reserve are maintained." However, these values have never been properly inventoried, mapped or regularly monitored. Public Lands says this is because they have no time or money.

Trident fails to provide adequate documentation to a third party pipeline company in development of its well. Consequently, pipeline construction is in contravention of requirements set out by Public Lands. The pipeline is trenched in rather than ploughed in, leaving up to a 100m swath of disturbed topsoil, which is now highly vulnerable to aggressive invasion of non-native species. After hearing ecological concerns they opt to hold off drilling any new wells until it can examine all impacts.

Alberta Energy Information Letter 2003-25 Re: Honouring Existing Mineral Commitments in Legislated Provincial Protected Areas states that mineral commitments that existed prior to the establishment of a protected area will be honoured and that applications for new surface dispositions for existing surface or subsurface commitments will also be honoured. However, existing surface or subsurface commitments within a protected area cannot be used as a basis to access new subsurface rights within a protected area. The IL refers specifically to 81 protected areas designated under Special Places, which includes the Rumsey Natural Area.

The Management Committee for the Ecological Reserve has a February meeting. Instituting monitoring has been a major difficulty. The Stewarts have agreed to keep records of their grazing rotations. Felix Gebbink of Public Lands has started monitoring a large no-grazing area and is keeping track of the invasion of smooth brome, a non-native grass introduced for cultivated pasture and which used to be allowe4d in gas-well reclamation seed mixes. There is discussion on how to deal with the mass of Canada thistle in and around a quarter section is is supposed to be an ungrazed benchmark site. With the 2001 drought, the leaseholders have put in two new wells for a total of 4 on the Reserve. Ron Bjorge has been monitoring the numbers and trends of ungulates in the Reserve and their impact on vegetation. Wayne Pedrini, the Parks and Protected areas rep, only has money in his budget for new boundary signs.

Dorothy Dickson resigns from the Management Committee and Dylan Biggs takes over as AWA's representative. Dorothy had been instrumental in getting the Committee to put monitoring programs in place.

Rough fescue is designated as Alberta's provincial grass emblem.

An inventory of rough fescue grassland sites in the Central parkland and Northern Fescue Grassland natural subregions shows the high ecological significance of remaining native plains rough fescue grasslands. Only 12% of grassland remnants in the Central Aspen Parkland support plains rough fescue community types and about half of these have invasive non-native species, including the highly aggressive awnless brome (Bromus inermis). Most areas of plains rough rescue grassland remaining are severely compromised by invasion of non-native plant species. The potential for invasion is exacerbated by surface disturbance and access which introduces aggressive invaders. Researchers failed to find examples of successful restoration of rough fescue grassland following disturbance except along small pipelines which are ploughed in. Report prepared by A.C. Holcroft Weerstra and Biota Consultants for SRD. (pdf 43KB)

The Alberta Orienteering Association's International Orienteering Meet is held in Rumsey Ecological Reserve. There are an estimated 300 participants. The Meet is supported by Public Lands staff, but others feel strongly that this is not an appropriate use of an Ecological Reserve. The Meet does not fit with the intent of allowing "nature-oriented activities such as bird-watching, photography, etc." and it is thought that it will set a bad precedent. It is suggested that the Meet be held in the Natural Area on a on-time-only basis, but Public Lands (Felix Gebbink) and the Stewarts (leaseholders) strongly oppose any compromise with their position that the Meet be held in the Reserve. Opponents are told that there is a grey area in the legislation and regulations about what was allowed in an Ecological Reserve unless an activity is actually prohibited. As the Meet entails foot access only and is non-consumptive, they are told that they probably have no solid legal grounds on which to deny AOA access. A Fish and Wildlife person who is substituting for Ron Bjorge (who opposes the meet) on the Committee says that as long as the Meet is held in late June when the young animals are mobile, he has no problem with using the Reserve.

• Regarding reclamation: "Programs agreed to with the individual companies responsible have been implemented and are ongoing, requiring several years to fully meet the desired vegetation requirements. With the continual buying and selling of oil and gas interests by petroleum companies it is difficult to maintain consistency in insuring these programs are fulfilled."
• A brome control study is in the early stages of development fo the Rumsey Ecological Reserve "and based on continued monitoring of the Parkland [Natural Area] a similar program could be implemented if a problem is determined."
• Signs are erected at entry points saying "Please help us preserve this sensitive area by keeping all vehicles on existing roads." Funding was provided by Buck for Wildlife program and petroleum companies active in the area. These were the alternative to gates.
• Mineral disposition holders suggested erecting locked gates on certain roads, but local management staff "determined it would be too restrictive and did not promote the Public Lands philosophy of multiple use. Public perception of such a proposal would likely have been negative."
• "In an attempt to ensure restrictive access development, the County of Stettler and the M.D. of Starland were approached informally with the request to prohibit road allowance development within the Parkland."
• "It is anticipated that mineral agreements prior to 1993 have the greatest potential for surface impact to the Parkland. These original agreements did not restrict the drilling location and may still result in companies locating in areas that require long access trails to the well site."
• "as the interest to drill within the Parkland appears to be subsiding, access reclamation will have to consider the agricultural and recreational user and the level of access required for their needs."
• "The RID itself continues to be an effective mechanism of management support ensuring this unique area is not compromised."
• "further integrated resource planning is not recommended or considered necessary at this time."
• "With the RID effectiveness it is also recommended that review, summaries and progress reports be deferred and if required be submitted within the monthly regional reports of Public Lands Central Region.

AWA and RDRN express concerns to Public Lands about grazing management in Rumsey. Cheryl Bradley provides Public Lands with scientific papers regarding grazing management on rough fescue grasslands. A meeting is held in Big Valley in April with Cheryl Bradley, Dorothy Dickson, Margaret Coutts, the Management Committee and the new leaseholders. The leaseholders are open to better management practices.

In June an onsite workshop is held with specialists on fescue grasslands and grazing management with the goal of trying to devise a grazing regime and monitoring system in order to meet the management goals in the Management Plan. These goals are "to sustain the remaining ecological and genetic diversity of the ecosystem" and to maintain all its components "in excellent condition capable of providing habitat to the full range of the remaining species."

Dr. Walter Willms notes that in order to meet the Ecological Reserve's mandate of maintaining and protecting the healthy fescue ecosystem, it is always best to use methods closets to the way in which a natural component of an ecosystem has evolved and was adapted to. Rough fescue evolved primarily under winter grazing by bison.

Because the idea of a Heritage Rangelands category is popular, it is added as an amendment to the WAERNA Act on May 30, 2000.

"We were assured that Rumsey Natural Area was near the top of the list for inclusion in the new category," says Dorothy Dickson. "Every time we have inquired since, we have been told it was still on the list and they were working on it but that it was "more complicated" than some of the others that have already been designated. We assume the "complication" has been the applications for CBM drilling and whether that could be counted as an "existing disposition" because it is where there are old dispositions for natural gas. They have now apparently decided that CBM is legally natural gas - hence they are starting to call it NGC (Natural Gas from Coal)."

The Regionally Integrated Decision states that the Central Region Resource Management Committee (RRMC) will produce an annual report to update regional plans. It also says the RRMC will put out an assessment of the RID every 5 years and evaluate whether it needs a major review, which would entail public involvement. Cheryl Bradley and Dorothy Dickson have each enquired about such a review but no one seems to have time, or else they don't think it necessary - no clear answer is forthcoming. "It did not seem worthwhile pressing the point when designation as a Heritage Rangeland appeared to be imminent," says Dickson.

In spite of Environment Minister Ty Lund’s assurances (see 1997, 1998) that no new well sites would be created, one person observes that at least 4 new wells have been drilled or applied for on new pads. Each are up to half a kilometer from existing roads. The well sites conform to the RID, but not to the Ministers assertions. Alberta Environment responds that new wells have been approved. Based on the RID areas within the natural area have been identified as “no surface access” or “surface access permitted with restrictions”. One well has been approved in the “no surface access” area, commitment approved prior to the approval of the RID, resulted in a 25 m intrusion into the “no surface access” area. “this is the only exception and no others will be made.”

After much public discussion, the Government produces more reports and a workbook to be returned by November 1,1999. It also makes it very clear that, whatever the public, some oil companies and environmental groups thought, they are not going to budge from their explicit endorsement of the policy of honouring existing dispositions, whether or not they are in existing or new "protected" areas. They also are apparently willing to accept OHV use in some protected areas. They say that if a mine was approved for a protected area, they would remove the protected status of that part of the area. They say forestry activity was not compatible in protected areas - so no areas with a timber allocation would be protected.

In general, the responses they get in the workbook are not compatible with the proposed Act. With an election coming, they do not pass the Natural Heritage Act and it has never been re-introduced.

The grazing lease in the Ecological Reserve, which has been held by the Usher family for about 90 years, changes hands, due to the illness of Tom Usher. Neither the Management Committee nor Public Lands is informed until the transfer is complete. The concern is that the new leaseholders, the Stewarts, are changing the grazing management from winter to summer grazing. This particular area had been chosen as the representative Ecological Reserve for the Central Aspen Parkland Region because it is in better ecological health than those further south. It is believed that this is due to the management practices of the Ushers. They practiced winter rather than summer grazing and grazed fewer cattle per hectare than other ranchers. However, there is no data to determine what specific practices or other factors contributed to the better conditions in this area. Winter grazing was not stipulated in the Management Plan and, therefore, was not a required management practice of the new leaseholders. There is concern that if winter grazing is important in maintaining ecological integrity, summer grazing may jeopardize it.

Public Lands staff say that summer grazing is not prohibited in the Plan; the Plan gives them the authority to approve "significant changes" to leaseholder practices and do not oblige them to discuss them with the Committee; the new leaseholders would not have anyone living on the lease, unlike the Ushers, so winter grazing was less feasible; it was their job to plan a grazing regime for summer-only grazing that would not harm the ecology of the Reserve and they believe it can be done using rotational grazing.

Dorothy Dickson tells the Public Lands Division staff that "I did not consider an Ecological Reserve an appropriate place to experiment with different grazing regimes and a plan should be in place, on a sound scientific basis, before they started to implement changes, which should then be introduced gradually with careful monitoring.

AWA and RDRN object to proposed Amoco pipeline through Rumsey. Amoco Canada plans an alternate route for an ethane pipeline which was initially proposed to run 14 km across the Rumsey Natural Area. The new route lies south of the Natural Area.

In January the Government introduces the Proposed Policy Foundation for a "Natural Heritage Act", followed by Management Guidelines for Protected and Recreation Areas, and Comparison of Management Guidelines under Current and Proposed Legislation.

Conservation organisations welcome the intent of having all types of protected areas under one, clear piece of legislation and many industry groups also support that idea. There is some confusion about the categories under which land would be protected. Natural Areas would apparently no longer exist - some would be upgraded but what would happen to the rest is suspiciously unclear.

However, as far as Rumsey is concerned, there is a hopeful-looking new category, "Heritage Rangelands."

"We felt that putting the Rumsey Natural Area (as included on the list of possible candidates) into this category was definitely a good thing as it would prohibit mechanized recreation and would have stricter regulation of energy extraction than in the RID, apparently with the aim of eventually phasing it out," says Dorothy Dickson. "Although the wording was rather vague and, as we had learnt in Rumsey, "honouring existing dispositions" could go on a long time as the "existing dispositions" changed hands or were used for deeper wells, new types of natural gas (CBM), etc. We had also learnt that "no new access" did not always mean what it appeared to mean!We did not agree with swallowing the Rumsey and some other Ecological Reserves into the Heritage Rangelands category as it would substantially reduce the protection they now have. From later conversations, it was verbally agreed that they would not do this."

From Hansard Feb. 5, 1998:

• Ty Lund: Because of the configuration of the well sites, there is no area within the Rumsey site that will require a new well site. Every one of them can be built on existing sites, and with directional drilling all of the minerals can be accessed.
• Grant Mitchell: How can the Premier say that his minister is honouring the spirit of the special places program when he is allowing oil and gas and other commercial development… [in] Rumsey and when he extended the lease on Rumsey after he had created it as a special place? It’s a question of hypocrisy.
• Ralph Klein: It’s not a question of hypocrisy. It’s a question of the minister doing the right thing in the spirit of sustainable development…and in the spirit of complying with the parameters for the Special Places 2000 Program.”

Hansard May 1, 1997, Environment Minister Ty Lund: "I don’t know if you’re familiar with Rumsey. That’s a designated area. There are oil and gas wells in there. The way the area is going to be managed in the future, they cannot go and build any more pads. If there’s to be any more drilling in the area, they have to directional drill from existing pads, and the area will be preserved."

May: Cheryl Bradley and other conservation participants in the Special Places Program express concern to the Special Places Provincial Coordinating Committee about use of the RID as the management plan for the Rumsey Natural Area.

Hansard June 9, 1997, Environment Minister Ty Lund: "the Rumsey natural area has a management plan in place. It has been passed. A lot of public consultation went into it. There will be no new roads, no new well sites in that area. There are currently a number of well sites in the area. They were there at the time that it was established.....I said that there would be no new roads, no new well sites in either one of those areas. In fact, the advertising for the sale clearly indicates that there would be no new access.

Hansard June 9, 1997, Minister of Energy Steve West: "I was the minister that stood at the opening of the Rumsey Ecological Reserve, and at the time that we dedicated this beautiful piece of aspen parkland, we had a direction taken of an integrated approach where we could serve both the protection of this area as well as remove the resources from this part of the land. It wasn't our intention ever to sterilize that large a piece of the province from our natural resources. We are mature enough as a society today and as an industry to be able to go in to an area such as this, remove the resources, and leave it protected. I think it’s irresponsible to start to cast that doubt on it at this stage of the game.”

Chris Hantiuk, executive assistant to Ty Lund (Globe and Mail, June 7, 1997): ":We know there are certain economic benefits to be derived from oil and gas development, and as long as we can control the manner in which the resource is extracted, with reclamation…we can minimize those impacts. At the end of the day, when the reserves are depleted, we will have a nice, large, undisturbed parkland."

The auction of oil and gas rights is on June 25. Environmental groups issue a joint media release and letters are sent to editors and the government. There is a lot of press and public derision about the Government not respecting the "protected Special Places" the Minister had himself nominated. About 80% of the quarter sections in the Natural Area are available for new wellsites and road development. Current wellsites and roads will likely not be reclaimed because of the potential for future exploration and development. There is a ban on new road access into the Ecological Reserve but directional drilling into the southern part of the Reserve can occur, but has to be from the Natural Area.

However, replies from the Premier and Ministers all assure everyone that the rights being sold would have to comply with the RID, which had been written after extensive public consultation and that the majority of the leases would have "no surface access" and must use only "existing routes" as set out in the RID.

Letter to Premier Klein from Dawn Mitchell, Regional Director, Alberta, Endangered Spaces Campaign, World Wildlife Fund Canada:
“...over the past few years, WWF has worked with other organizations and leading scientists to develop rigorous criteria by which to evaluate progress towards the Endangered Spaces goal. One of these criteria is that there must be no industrial activity inside the boundaries of a protected area especially logging, mining, hydroelectric, and oil and gas. This principle used by WWF, is consistent with the World Conservation Union (IUCN) and is broadly supported by Canadians.
      "It is important to note, that in areas of ecological significance that have some industrial development, particularly oil and gas development prior to its designation, WWF has considered them protected. Specific examples are the Plateau Mountain Ecological Reserve where Husky Oil has been operating two wells since the late 1950s and the Rumsey natural Area where the oil and gas companies agreed to severe restrictions on their current activities and future phase out to maintain the area’s ecological integrity. This flexibility on our part is based on the recognition that to find a representative sample in areas where human activities have already have a severe impact, we have to find the best sties that can contribute to representation in a small way right now, with the potential of greater contribution as the industrial activity is phased out. The important point is that the phase out be certain. Unfortunately, this is no longer the case at the Rumsey Block.
      "At the Provincial Coordinating Committee, we were led to believe that the oil and gas activities would be phased out and that no new dispositions would be sold. This is why new felt quite comfortable including it as a site that could be counted as a protected area. We have since learned that while all the participants in the development of the Regionally Integrated decision (RID) agreed to phase out the oil and gas activities, the Department of energy changed the consensus decision after the fact to allow for oil and gas activity in perpetuity.
      "More troubling for us, is Environment Minister Ty Lund’s recent assertion to the PCC on May 27, 1997 that carefully managed development is acceptable in protected areas and that Rumsey would be the model for Special Places not the exception. The posting of new industrial dispositions in the Rumsey Block is clearly problematic. If the land sales go ahead as posted and new industrial development is initiated, WWF will have no choice but to de-list it as a protected area….it is important that the RID be amended to acknowledge Rumsey’s contribution to the Special Places program and ensure that it is protected from future development….The RID itself recognizes that oil and gas development has had a significant impact on some portions of the area through the opening of new access routes into the area and the introduction of non-native plant species prior to and as part of the reclamation process. The RID also states that the extent to which these impacts will affect the overall integrity and uniqueness of the Parkland has not been fully determined."

Excerpt from Premier Klein’s response: “The resource management plan for the Rumsey area is the cornerstone of our decision to designate the site for protection while providing for use of the oil and gas reserves below the surface….I am not prepared to cancel the Rumsey Ecological Reserve and Natural Area mineral postings as I believe that we have achieved balanced decisions regarding these sites that provide for existing commitments on the land and for the long term ecological preservation of their natural heritage values. Alberta remains committed to contributing our part to the Endangered Spaces Campaign. We will contribute, however, according to the Special Places Policy and Implementation Plan approach that was designed to meet the needs of our province.”

612 acres of land adjacent to the Reserve is bought by a coalition of Ducks Unlimited , the Nature Conservancy and Alberta Fish and Game and will act as a buffer zone.

The Protective Notation Reservation (PNT 840668) held by Parks is cancelled and the Natural Area is numbered NAA97003.

July: AWA comments on draft Rumsey Ecological Reserve Management Plan.

September 19: A memorandum from Alberta Agriculture, Food and Rural Development to Public Lands: "For Rumsey, the Regionally Integrated Decision will essentially become the management plan for the area, with few minor adjustments."

Ty Lund, the Environment Minister nominates Rumsey South as a Natural Area - the lowest possible protective category and one which would ensure that oil and gas extraction could continue.

The SP 2000 Provincial Coordinating Committee supports the designation, having been assured it had a RID as its Management Plan.

However, one of the PCC members [Wendy Francis of CPAWS] later said "we had not seen the RID nor understood its implications. We never would have endorsed Rumsey as a Special Place if we had known that new industrial development is allowed there".

It is clear that the hedging over granting any real protection for the Rumsey Block is because some companies are now successfully drilling into deeper reservoirs, mainly, if not entirely, for gas.

March: A new version of Natural Heritage Policy - Special Places 2000 is released and economic development had been added to its goals.  Rumsey South is on the list of proposed Special Places. CPAWS and FAN withdraw from the SP Coordinating Committee in protest.

A 1995 study of vegetation on 25 wellsites, 3 pipelines and 5 controls found much lower cover of native grasses on wellsites (19%) and pipelines (28%) compared to controls (77%) and higher cover of introduced grasses and forbs. (Eastern Slopes Rangeland Seeds Ltd. 1995)

Range inventories are completed by Eastern Slopes Rangeland Seeds Ltd.

The results of a 1991 study on reclamation of disturbed industrial sites in the area are finally made public. About 80 exploratory wells have been drilled. Even after 15 years, native vegetation, particularly fescue grassland, has not re-established on re-contoured roads and wellsites. Weeds introduced in non-native seed mixtures are invading the native prairie. Since reliable native seed mixes are not available, Public Lands Division is experimenting with alternative methods for reclaiming fescue grassland, including sod transplanting and sprigging.

In an October 1993 Wild Lands Advocate article (Vol. 1, No. 3), Cheryl Bradley writes: "Since phasing out oil and gas activity was put forward and considered reasonable by most planning team members, including some oil and gas industry representatives. However, the Energy Department is opposing this option at senior civil service levels."

An inventory and mapping of soils is being undertaken by the Resource Inventory Branch of Alberta Environmental Protection.

Volunteers Thayre Angliss and Cheryl Bradley work on a display on the Rumsey Wildland for the Calgary Zoo's Discovery Centre as part of the Aspen parkland exhibit of the Zoo's Canadian Wilds Project.

With no further public consultation nor the promised review, the new RID finally comes out. The RID says Rumsey contains about 0.01% of Alberta’s reserves of oil and less than 0.00001% of its gas reserves.

Dorothy Dickson says: When I received the new RID I said it was cynical and misleading and I wrote: "Theoretically it is improved in that it has pages of new environmentally correct statements about the Block's "unique natural qualities", its international significance and the need to ensure that "ecological integrity is the underlying principle upon which management decisions will be based." But, in practice, there is nothing new or improved in the regulations and guidelines that would accomplish this principle. The problems caused by increased vehicle access are noted but not addressed. There are many pious references to "reclamation" but no acknowledgement that, in spite of years of trying, we do not know how to reclaim fescue grassland. They agree that extraction activities "can have a cumulative effect" and that we don't understand how those impacts will affect the ecology - but they don't intend to wait and find out by doing baseline studies and monitoring."

The RID promises to ensure that its provisions "remain relevant and can be modified according to changing conditions" and that there will be "adjustments" to ensure compliance with a new regulation, Act or Cabinet approved policy.

However, according to Dorothy Dickson, if there is to be a protected Special Place in the Parkland Region, Rumsey is the only possible candidate and, equally obviously, it would make a sham of the Special Places 2000 Program to designate it as a "protected representative sample" and then allow the continued degradation of it by the energy department and industry under the RID. "Some of us nominated it for the Special Places 2000 Program, probably to be put under the designation of 'wildland'."

After the Provincial election, Ty Lund, who had been the government's strongest critic of SP 2000, is made Environment Minister there are many assurances that SP 2000 would not "interfere with" oil and gas development.
Dorothy Dickson and others withdraw their nomination of Rumsey for SP 2000, fearing that any designation might prove more of a threat even than the RID.

April: Cheryl Bradley is invited to a meeting with Board Members of the ERCB to discuss implications of the RID on energy activity in South Rumsey. Morris Sieferling and Barry Cole of Public Lands also are invited.

Spring: AWA is NOT invited to a negotiation among RID government participants regarding phase out. Minerals Division, the only opponent to a sunset clause, prevails. AWA requests reasons for the Mineral Division’s rejection of the phase-out option (letter 31 May 1993) but there is no response. According to Cheryl Bradley’s assessment of the RID, only 41 of 232 quarter sections in Rumsey will be subject to no surface access addendum.

Gulf Canada proposes a coalbed methane project in the Fenn-Big Valley field. Six wells are drilled. Reasons for the project include drilling wells to evaluate the areal extent of CBM productivity and determine the long-term productivity of wells in this area and the resultant potential for commercial development.

The first Special Places 2000 draft recognizes that the Parkland is one of  the regions lacking adequate representation and that "the largest remaining contiguous" area should be identified for protection. The report recommends that selection criteria "weigh protected area values versus other uses", that "major disturbances associated with energy development will not be allowed in Special Places" and that current activities in an area will be evaluated to ensure long-term environmental impacts do not occur; where such current activities appear as anomalies they will, where practical, be phased out.

The Steering Committee for Ecological Reserves requests that a small planning team be formed, consisting of a representative from AWA, the leaseholder (Usher family) and the government (Fish and Wildlife, Public Lands and Provincial Parks). Dorothy Dickson agrees to represent AWA.

Three energy companies state their intention of concluding their activities in the Block.  They are Poco Petroleums, North Canadian Oils and Renaissance Energy. The ERCB apparently says they are willing to initiate a coordinated plan for companies operating in the area to conclude production of proven resources while minimizing environmental impacts. Reasons industry gives for concluding activity in the block partly are marginal economics. 85% of the 60 wells drilling in the block since 1951 are capped, suspended or abandoned. There are also 25 test holes. None of the sites, not the cleared access trails to them, have been successfully reclaimed to native prairie according to a recent study by the lands Division on reclamation in the Rumsey Block.

Sept 15, letter from AWA (Cheryl Bradley) informs ERCB (Nelson Lord) and Alberta Energy (Michael Day) that three companies (Renaissance, North Canadian Oils, Poco Petroleums) have stated they will be doing no further activity in Rumsey. She asks that the Minerals Division define an end to mineral activity in Rumsey either by discontinuing sale of rights or placing a “no surface access” addendum on rights that are sold. A compelling reason for doing this is that we do not know how to reclaim fescue grassland.

The biggest decision facing the RID committee is whether or not to adopt measures which will officially define an end to oil and gas activity. Eight conservation groups and grazing lessees want an end to oil and gas activity. Over a third of petroleum companies operating in the block, including the two major players, are ready and willing to phase out their activity, provided current commitments are met.

Cheryl Bradley communicates with Renaissance Energy Ltd. (Sheldon Steeves) regarding minimal disturbance techniques and reclamation for a proposed well at 8-20-33-19 W4. She suggests Renaissance support research on reclaiming rough fescue prairie.

Cheryl Bradley is optimistic about the future of the wildland: "It's partly due to a growing information and public awareness about endangered spaces and the importance of protecting them. It's partly due to the proven lack of significant petroleum resources in the block. But is also due to a growing willingness on the part of individuals in different sectors...to consider each other's points of view and to work for decisions which will provide the greatest societal benefits." (Wild Lands Advocate)

 Because the draft RID is considered inadequate by so many respondents, a Round Table  meeting of participants in the RID in Big Valley (Nov. 21), followed by a public meeting is convened. It is chaired by Ian Dyson and the 30 participants included government departments, energy and grazing lease holders, municipalities, Cattle Commission and conservation organizations (AWA, CPAWS, RDRN). Follow-up submissions are accepted until Dec. 31st.It turns out to be a surprisingly helpful, productive, and even amicable, round table. The only disagreement to the concept of phasing out industry activity in Rumsey in the short term (5 -10 years) is from Mineral Resources. A proposed wording for a sunset clause to be included in the RID is developed.  Option for phase out is put forward for consideration at the ADM level by the planning team. 

• There is general agreement (except by the Energy Dept. which took virtually no part in the discussions) that the area must have better protection, that current oil and gas wells should be depleted as quickly as possible (10 to 12 years was accepted as reasonable) and all extraction activity be phased out.

• In the meantime there should be stricter regulation of sites, roads etc. and of reclamation. Conservation groups request more information be included regarding ecological values, the value of the energy resources, job creation values, etc.

• It is emphasized that more baseline ecological information is needed and more provision for monitoring the effects of grazing, recreational uses, etc.

• It is agreed that mechanized recreation should not be allowed at all.

• Suggestions by the Parks Dept. of putting in camping facilities were strongly opposed and withdrawn on the spot!

• The majority of those attending were quite pleased with the outcome and the Energy Dept said they would undertake to have a revised RID document ready for public review by early spring of 1992.

A draft Regionally Integrated Decision is released to the public on June 10. It notes that "this report was agreed to" by all of the participating departments. It does not say what the consulted groups and agencies thought of it.

The stated purpose of the RID is "To preserve and protect the Rumsey Aspen Parkland ecosystem while allowing for responsible use of its resources." However, the RID never defines "responsible use" nor establishes priorities for ensuring protection.

The RID covers the following subjects:

• Location, brief history etc.

• Agricultural, Cultural, Wildlife, Recreation and Mineral Resources

• Access

• Guidelines for development

• Implementation

• Monitoring and RID review

The Public is NOT impressed by the draft RID. Some typical comments:

• "Ecological conservation is apparently the goal in the RID, yet there is little evidence in the draft document to suggest that natural ecological interactions are even understood, let alone used as a benchmark for possible human impact assessment." ( CPAWS)

• "Agricultural resources can not be equated with vegetation inventory." (CPAWS)

• "The fact that the RID suggests a biophysical inventory should be done, clearly indicates that the information required to justify and assess the full range of activities that are proposed or occurring in the block does not exist." (Canadian Nature Federation.)

• "The management goal for the RID should state 'To preserve and protect the Rumsey Aspen parkland ecosystem while allowing for ecologically sustainable use of its resources.'" (CNF)

• CNF recommends discontinuing sale or renewal of oil and gas leases, expediting extraction of resources from existing wells and reclaiming well sties and roads, protection of sensitive natural and archaeological features from humans and cattle, non-mechanized and limited recreational use.

• "I was hoping that the RID would define an end to petroleum industry activity in the Rumsey Block, but as it stands, disturbance by this industry is authorized to continue in perpetuity." (AWA)

• "....... that a fair bit is known about populations of deer and grouse in the plan (based on Fish and Wildlife surveys) but that very little is known about the populations of the majority of wildlife species in the plan area." (AWA)

• "You have tinkered with the guidelines in the hope of alleviating some of the obvious symptoms of the current uses of this land but you have done nothing to cure the underlying causes of the damage which, unless halted, will eventually destroy the area's ecological value." (RDRN)

• "We would like clarification of the status of "guidelines." Are they only voluntary as the statement implies or does anyone have any authority to require compliance? If guidelines are not adhered to, what is done about it? Are there any legally enforceable requirements regarding use of the Rumsey Block?" (RDRN)

• "...further exploration for oil and gas, even with restrictions such as spelled out in the RID, will result in a continuation of damage to the ecology of the area. Every effort should be made to reduce this activity and contain the damage." (PCCC - Prairie Conservation Co-Coordinating Committee)

• "We question the advisability of allowing expanded oil and gas development in the Parkland. Would the limited, short-term economic gain be worth the resulting loss and degradation of natural habitat?...It seems to us that, "while allowing for responsible use of the resource" is being interpreted by some people as "business as usual with a little environmental lip service thrown in." No agricultural "improvements" or road development should be permitted unless the effect on the natural ecology can be shown to be negligible....the primary interest must be conservation of parkland habitat." (Sherwood Park Fish and Game Association)

Cheryl Bradley's Key Favourable Comments:

• The stated overall management goal is "to preserve and protect the Rumsey Aspen parkland ecosystem..."

• A project will be undertaken to assess revegetation by native species of disturbed sites.

• The mineral rights sold after Jan. 1, 1991 will have "no new surface access" addendum attached.

• Access points to the area will be gated.

Cheryl Bradley's Key Concerns:

• Mineral rights will continue to be sold throughout the block and exploration and development will continue in perpetuity where there currently are trails and roads, even though oil and gas resources are obviously not significant (i.e. only 8 of 58 wells drilled are in production).

• New access can occur to those rights sold prior to Jan. 1, 1991. This then becomes existing access. The plan does not indicate how extensive this new activity might be.

• The plan suggests a program to control expansion of aspen and shrubs without demonstrating an understanding of the trends and factors affecting this (i.e. climate may be the overriding factor). Theoretically control could include mechanical and chemical means which would not be consistent with conservation objectives.

• Alberta parks wants to continue to hold a reservation on the area but their intent for the area is unclear, i.e. preservation or recreation development.

• The RID does not suggest a legal designation for protection. A reservation gives Parks very little, if any, control over developments.

Excerpt from a letter from  Alberta Energy (signed by David Luff) to Cheryl Bradley, AWA:
"...the current moratorium on oil and gas postings in the area of the RRID was put into effect to relieve pressure for access while the planning process is underway. The moratorium has always been considered by the Alberta Dept. of Energy to be temporary, as it is the view of the Department that oil and gas exploration and development in the Rumsey area is in the public interest as long as the impact on the land can be mitigated and access minimized. It is also the view of the Department that oil and gas exploration and development can be conducted, under appropriate guidelines, in a manner that is sensitive to the aspen parkland ecology.. The Rumsey Aspen parkland area has already received considerable protection from disturbance. Access for oil and gas activity has been prohibited in a significant portion of the Rumsey Aspen Parkland area (approximately 20%) for some time and as a result of the recent establishment of the Rumsey Ecological Reserve, this provision will continue in perpetuity. The area to the south of the Rumsey Ecological Reserve, now the subject of the RRID, has also received considerable protection from disturbances related to oil and gas exploration and development activity through the application of restrictive operating guidelines. These guidelines have been in effect since 1982 and were reviewed and modified in 1989 [and] are being reviewed again with the development of the RIDD [sic]. Since it is anticipated the RRID will result in even stricter operating conditions for the Rumsey Aspen parkland are than currently exist, the Department is confident the issuance of new oil and gas agreements, and the continuation of carefully planned oil and gas exploration and development activities will not compromise the values that make the Rumsey area unique."

Dec. 1990 - Jan 1991: AWA works cooperatively with ERCB and North Canadian Oils Limited (office and field trip) in reviewing plans for a proposed well in 1-2-33-19-W4. Matters discussed include the need for the well, potential for directional drilling, infrastructure on the site, access during construction and operation, and reclamation. NCO agrees to special measures to reduce environmental impact.

Dec. 1990 - Feb. 1991: AWA works cooperatively with ERCB and Summit Resources Limited to define measures which will reduce the environmental impact of a proposed well in 1-33-32-18 W4M.

The Rumsey Ecological Reserve is established by  Order-in Council 511/90. The Reserve is on the Usher Ranching Ltd. grazing lease, covering 33.5 km² at the north end of the Block. In accordance with the Wilderness Areas, Ecological Reserves and Natural Areas Act, no new energy leases are allowed in the Ecological Reserve (ER) and the 3 already there are to be phased out as soon as possible (as of 2004 all are now depleted). An ER Management Planning Committee is set up on which Dorothy Dickson represents the Alberta Wilderness Association and the Red Deer River Naturalists.

The establishment of the Ecological Reserve is preceded by a major confrontation between conservationists and Parks Minister Steve West who at the last minute sought to scale down boundaries which had been agreed upon through public process. Official dedication of the Rumsey Ecological Reserve occurs on 9 Oct 1990. AWA is invited to attend the dedication by Recreation and Parks Minister Steve West and responds by sending a representative (Cheryl Bradley; Dorothy Dickson attends for Red Deer River Naturalists). 

Less than 20% of the original aspen parkland natural region in Canada remains in its natural state. Less than 1% of the Aspen parkland in Alberta remains in large enough blocks to provide adequate representation of ecosystems and to be considered a wildland. Only two blocks, other than Rumsey, are greater than 15 sections in area. Less than 0.1% of the Aspen parkland in Alberta is presently designated for protection in provincial parks, natural areas, ecological reserves, etc. The Brundtland Commission on Environment and Economy recommends that 12% of a natural region should be given protected status. The Prairie Conservation Action Plan (WWF Canada 1988) recommends conserving at least 10% of each habitat subregion.

The Public Lands Division initiates the development of a Regionally Integrated Decision which is agreed to by the Central Region Resource Management Committee (RRMC). The RID Committee is formed in January.

• It has representatives from:

  • Forestry, Lands and Wildlife  - Public Lands and Fish and Wildlife Divisions.

  • Alberta Energy - Minerals Division.

  • ERCB

  • Alberta Recreation and Parks.

  • Alberta Culture and Multiculturalism (there are native Indian and other archaeological sites in the Block.)

• Other groups and agencies are also consulted: 

  • Alberta Wilderness Association. (Cheryl Bradley. Alternate: Mike McNaughton of RDRN)

  • Independent Petroleum Association of Canada

  • Municipalities:  County of Stettler,  M.D. of Starland

  • Individual Leaseholder Representatives

  • Jake's Butte Grazing Association

  • Rowley Grazing Association

Among the issues to be addressed are existing and proposed oil and gas activity and uncontrolled motorized access, which has increased with the construction of all-weather roads by the oil and gas industry. The Decision is scheduled for completion in March 1991.

AWA's representative, Cheryl Bradley, argues "given the international significance of Rumsey's natural environment, a sound argument can be made that conservation values are higher than oil and gas potential and that Albertans are better served by taking action now to protect the area than to allow further deterioration to occur."

Of 56 wells drilled over the last decade, with resulting terrain and vegetation alteration, only 50% have been producers, many only marginally. Eight different companies are operating in the area with no coordination. Two are producing oil wells, sixteen are producing gas wells, 13 are capped gas wells and 25 are abandoned wells. All-weather roads and major trails now run through the area accessing producing wells and allowing easy vehicle access to the heart of the block by the public. Further deterioration of conservation values is foreseen when capped wells are brought into production. The Energy Resources Conservation Board (ERCB) has concluded that the Rumsey Block has only moderate future potential for exploration and development of oil and gas resources. According to Alberta Energy, bids for leases in the area have been generally low by provincial standards.

Reflecting on the road put in in 1987 (see below) Cheryl Bradley writes: "Any assumption that Alberta Recreation and Parks would look after the preservation interests was obviously naive....In hindsight, I think those of us who care about the Rumsey Wildland should have had a stronger vision for the area and worked for complete elimination of oil and gas activity when it began in earnest in the 80's....If anything has been gained by allowing oil and gas activity to proceed, it is that we can now say with certainty that oil and gas potential in the area is low compared to conservation potential, and oil and gas exploration and development activity should be phased out as quickly as possible. We now know for sure that it is of greater benefit for all of us to designate protection for the Rumsey Wildland than to allow its death by a thousand small cuts to continue." (Parks and Wilderness, Spring 1990).

Cheryl Bradley of AWA submits a Conservation Action Position for input to the Rumsey Parkland Planning Team. Proposed conservation actions include:

• Discontinue the sale of petroleum and natural gas leases in the block.

• Develop a coordinated plan to expedite extraction of already proven gas resources.

• Design guidelines for petroleum and natural gas development activities and reclamation which minimize impacts on the natural environment.

• Consider mechanisms for recognizing the contribution towards conservation of companies who voluntarily allow leases to lapse without drilling.

• Conduct studies to determine the type and location of significant natural and archaeological features and environmentally sensitive areas.

• Reassess stocking rates, distribution patterns of cattle and range health to ensure that grasslands are not suffering depletion and that environmentally significant sites are not being damaged.

• Develop a public access plan which protects wildland and wildlife values and recognizes industry (in the short term until activity ceases), grazing (perhaps management of cattle could be done on horseback), and wildland recreation (non-mechanized) interests.

• Consider regulatory mechanisms for ensuring long-term protection of the Rumsey block (eg. natural area, etc.)

RRMC Members endorse the draft RID, a mini-planning exercise, and agree to proceed with this initiative on a priority basis using existing resources. Regionally Integrated Decisions are "Action-oriented mini-planning exercises undertaken entirely within the region to address current resource management issues." All agencies present agree to appoint members to a team that will seek substantive involvement and input in this RID exercise by all stakeholders (including AWA, oil companies and grazing lessees). A letter to AWA from Alberta Forestry, Lands and Wildlife dated 5 Dec 1989 states: “It is the RRMC’s intention that the team seek substantive involvement and input in this exercise by all stakeholders (AWA, oil companies and grazing lessees).” ERCB and AWA encourage Poco to participate in the planning process on behalf of IPAC and they agree (letter 3 Jan 1990 from Poco to IPAC with cc to AWA).

The World Wildlife Fund describes Rumsey as "the largest remaining representative site of Aspen Parkland left in the world." The Prairie Conservation Action Plan (PCAP), published by WWF Canada, recommends that Rumsey be given protection as part of the WWF Endangered Spaces Campaign. It states: "Protect at least one large representative area in each of the four major prairie ecoregions." The PCAP is endorsed by all three prairie provincial governments.

AWA meets with Alberta Energy and the ERCB to discuss existing and potential reserves of oil and gas under the Rumsey Wildland and possible scenarios for managing future exploration and development activity. Information from the meeting includes:

• drilling activity peaked in 1985 when 12 wells were drilled and has fallen steadily since then to only 2 licences so far in 1989.
• pools in the area have been fairly well defined and the assessment of the government is that the area has only low to moderate potential for further finds.
• several existing gas wells (there are only 2 oil wells) have been very short-lived (4-5 years) and have not been big producers.
• with only a few exceptions, bides for leases in the area have been low by provincial standards.
• Alberta Energy and ERCB are willing to participate in the RID for the Rumsey Block in order to obtain consensus on how to handle sake of further leases and on what conditions to put on licences.

Site specific guidelines for oil and gas development are re-confirmed as adequate.

Public hearings are held regarding the formation of an Ecological Reserve in the northern portion of the area for 13.25 sections. There is no opposition.  

The Prairie Conservation Action Plan 1989 -1994 (World Wildlife Fund Canada, 1988) recommends protection of Rumsey as the “largest remaining representative site of aspen parkland left in the world”. AWA members Cliff Wallis and Cleve Wershler contribute to the PCAP.

One Parks employee states: "the road, designed as it is [i.e. to minimize surface disturbance while ensuring daily visitations and safety standards], is the least damaging solution to a long term problem over which we have very little control."

From a letter from Alberta Recreation and Parks, August 5: "Poco Petroleums put forward a proposal for an access which would serve both present and anticipated future needs. The argument was made that, although this created a greater single impact at the moment, the final result would be significantly less total impact. Knowing how easily areas can die "the death of a thousand cuts: where each individual impact is minimized but the cumulative effect is disastrous, Parks was sympathetic to the presentation....Due to anticipate frequency of use it was agreed that surfacing a defined, narrow road was less damaging than permitting a ramifying trail corridor on the same route....oil and gas development is a permitted use in the Rumsey South block and the objective of conditions and guidelines is the mitigation of impacts, Unfortunately, mitigation cannot be the same as prevention. The road is meant to be the least damaging solution to a long term problem. Only time can demonstrate whether this was a "good" decision or not."

Parks staff state the road as designed is the least damaging solution to a long term problem with industry and Energy over which Parks has very little control. AWA meets with Poco representatives (Scott Colebrook) to inform them about the area’s significance, obtain information on Poco’s future plans and to seek support for planning for the area’s protection.

Guidelines for oil and gas activity developed by AWA and representatives from the ERCB, industry and government in 1982-83 are implemented for the drilling of about 30 exploratory wells between 1984 and 1987. Guidelines include: no permanent roads, recontouring disturbed wellsites and revegetation with native species. AWA determines location of sites, contacts industry to discuss plans where there is concern about impacts, conducts periodic field checks to ensure guidelines are being followed and reports to members on the status of industrial activity.

AWA hosts a field trip with a local grazing lessee and representatives from Dome, Chevron and the ERCB. It is agreed that the area merits special consideration. Discussions focus on guidelines that might be applied to allow oil and gas development while protecting the unique wildland character. AWA incorporates ideas  from the trip and suggestions from a meeting with the Energy and Natural Resources (the government agency responsible for the area, January 1983, into a set of proposed guidelines that is forwarded to Fred McDougall, Deputy Minister of Energy and natural Resources for his comment and suggestions. Cheryl Bradley writes: "Traditional methods of dealing with oil and gas activity do not appear to be responsive to the special care which is required in managing this area, despite a reservation by parks on the lands which allows special conditions to be applied. The AWA hopes that government agencies, the oil and gas industry, grazing lessees, and conservation groups can work together in developing and implementing innovative approaches to the management of this very special wildland - the last of its kind in Alberta, perhaps in Canada." (Wild Lands Advocate Winter/Spring 1983).

The guidelines are established as government policy.

The Ecological Reserve area is reserved as a conservation area (RLC4) by Public Lands.

A 3445 ha area in the Rumsey area is nominated as an ecological reserve. It is one of 3 areas of 15 or more sections, and the most representative, of the parkland region that is also large enough to withstand recreational use.

According to the Alberta Ecological Survey, 1979, the Rumsey site is chosen because:

• It is the only large relatively undisturbed area of aspen parkland on hummocky disintegration moraine left in Canada.
• The moraine plateaux are not cultivated or overgrazed.
• The fescue grasslands are unsurpassed in Alberta.
• The saline, wet meadows in the glacial spillway are not overgrazed.
• An ecological benchmark is present in NW 14-34-19-W4.
• Rare and uncommon animal species inhabit the area.
• It is within one grazing lease.
• It includes some of the most spectacular hummocky disintegration moraine in the region.

An Alberta Recreation, Parks and Wildife report Aspen Groveland Resource Assessment: Rumsey Area is prepared by Lynn and Cheryl Bradley of the Resource Assessment and Management Section.

The Usher Ranching Ltd has its lease renewed for a ten year period. The Reserve is included in their year-long rotational grazing system. An assessed carrying capacity of 28 acres/head/year is maintained.

There are 4 grazing leases: Imperial Ranch ltd., Usher Ranching Ltd., Rowley Grazing Association, Jake’s Butte Grazing Association. There are two Ducks Unlimited easements (see 1960), two Wolf Hill Rural Electrification Association easements, two pipeline agreements, one with Dome petroleum and one with East Central Gas Coop Ltd, a licence of occupation by Alberta Gas Trunk Line, ten abandoned gas wells. Existing leases are up for renewal between 1977 and 1981. All rights to crown coal are reserved and no applications have been accepted since 1975. Present coal leases covering the entire Reserve are due to expire in 1994.

Cheryl Bradley (biologist) conducts field work in Rumsey for Alberta Parks. This is part of a program to identify, evaluate and preserve the remaining undisturbed tracts of Aspen Parkland in Alberta. Rumsey is the largest of three block identified. She co-authors a report that provides an overview of biophysical attributes and land use. The Alberta Parks Division recognizes the Wildland an area of high environmental significance and requests a "reservation for conservation purposes" on all public lands included within the Rumsey block (70 sections).

A reservation with no dispositions (RLC7), for conservation purposes, is granted on land that was set aside in 1967 as a Grassland Research Reserve for the Dept. of Lands and Forests and the University of Alberta as recommended by M. Forbes of the Lands Division. This is in the far northwest part of the area (northwest quarter of section 14-34-19-W4). This quarter section was check-sheeted by the Alberta Terrestrial Community Section of the International Biological Program in 1970 and was fenced to exclude domestic livestock. The purpose of this quarter was to establish a benchmark area for comparison and research purposes. It was removed from the Usher grazing lease, in what later became the Ecological Reserve, and has not been grazed since. It used to be, and sometimes still is, referred to as the natural area. This sometimes causes confusion with the later established Natural Area but this quarter is not under any separate legal designation and remains part of the Ecological Reserve.

S. Hatfield of the Lands Division suggests preserving an expanse of grassland in the area for future study and recreational needs. The prime deer habitat is popular with hunters and waterfowl is abundant.

Lease holders want to graze at 20 acres/head/year, but investigations by R. A. Wroe in for the Lands Division conclude that a carrying capacity of 24-25 acres/head/year would be the maximum density allowed for sustained forage production, and only if there were superior management in animal distribution.

The area is being grazed by the Ushers at stocking rates of 26 to 34 acres/head/year. A study of vegetation and grazing capacity is undertaken. One quarter section (NW14-34-19-W4) is designated a Natural Area and fenced from grazing as a benchmark against which to monitor grazing practices.

Part of the Usher lease is reassigned to the Rowley Grazing Association and Jake’s Butte Grazing Association.

Part of the Walters family grazing lease is deleted in favour of the Rowley Grazing Association. The remainder of the lease is assigned to the Imperial Ranch Ltd., a company formed by four local ranchers.

The Walters family obtains a twenty year ancillary agreement to their grazing lease in the area to erect ranch buildings and corrals on 80 acres of public land. By 1964, 160 acres of public land in the vicinity of the buildings had been broken without authorization for cultivation.

The carrying capacity for the Usher grazing lease in the reserve is lowered to 28 acres/head/year.

Much of the native vegetation has been altered by livestock grazing or destroyed through cultivation. Two Ducks Unlimited easements (1960 and 1964), part of the Big Valley Pot hole Development Project, become effective on 29 quarter sections in the area.

A land inspectors report stated: “the soil is arable but topography and climate preclude economic farming.”

Ducks Unlimited surveys the area and recommends “draining a number of potholes into each other to create permanent keewaters” which would serve as prime waterfowl breeding habitat. The Big Valley Pot Hole Development is carried out in the late 1950’s and early 1960’s with ditches cut between potholes in approximately 15 different locations.

The ranch, which has been jointly operated by Tom Usher and Jim Walters, is divided. The carrying capacity for the Usher grazing lease is set at 32 acres/head/year.

Tom Usher and Jim Walters acquire the grazing lease from Burns.

Burns ranching interests purchases the grazing rights from the Imperial Ranching Company which has been grazing in the area free of charge. They erect fencing.

The Dominion of Canada legal land survey is completed in the area. Livestock grazing through crown grazing leases begins in the Wildland.

Explorer Peter Fidler finds the area. He notes the rolling terrain occupied by thousands of bison, and several groups of Blackfoot who hunt and camp nearby. He identifies "Gopher Hill" on the east boundary of the block and the "Hand Hills" to the southeast.

Nomadic native Indians hunt abundant wildlife including bison, wapiti, pronghorn, mule deer, white-tailed deer, furbearers and some moose. They use fire to modify movements of bison and for communication. In the late 17^th and 18^th centuries fur traders and bounty hunters come to the area because of the abundant wildlife.