Management
Rumsey Management
Management Plans
Rumsey Ecological Reserve
The Rumsey Ecological Reserve is managed by a 1998 Management Plan. Its implementation is overseen by a Management Committee. Dorothy Dickson represented AWA on this Committee until 2003. The committee has not met since Dickson resigned.
One of the purposes of a representative Ecological Reserve is to serve as a benchmark against which the health of other similar areas can be measured. This is mainly for the comparison of natural land versus land managed for human use. The Management Committee has instituted a monitoring program for grazing.
Rumsey Natural Area
Rumsey Natural Area is being managed using the 1993 Rumsey Parkland South Regionally Integrated Decision (RID). The planning exercise was initiated in 1990 to determine guidelines for managing oil and gas activity, cattle grazing and recreational use. After the designation of Rumsey South as a Natural Area in 1996, the RID became the de facto management plan. The overall management goal is "To preserve and protect the Rumsey Aspen Parkland ecosystem while allowing for responsible use of its resources." A Central Region Resource Management Committee (RRCM) was responsible for monitoring the implementation of the RID, but no longer exists.
- RID Proposal 1989
- RID 1993
- RID Assessment 2001
- An Analysis of RID Commitments
- Alberta Energy Information Letter IL2003-25
- Energy and Utilities Board Information Letter IL90-21: Oil and Gas Development - Rumsey Block
The Seven Betrayals
Rumsey has suffered seven major betrayals by government in its history:
- The first was the building of a permanent road (the Poco Road) in the late 1980s after guidelines prohibiting such a road were agreed upon by government, industry, and conservation groups.
- The second was the formulation of the final Regionally Integrated Decision (RID) in 1993, which allowed oil and gas development in perpetuity. This was in direct contrast to recommendations by the RID committee of government, industry, and conservation interests, which called for the phasing out of oil and gas. Alberta Energy overrode that committee.
- The third was the designation of Rumsey in 1996 as a Natural Area instead of a Heritage Rangeland, which was promised by government. Heritage Rangelands have much more stringent guidelines for surface disturbance.
- The fourth was the selling of oil and gas leases the year after its designation as a Natural Area, with the environment minister boasting that Rumsey would be the leading example of how industrial development could be accommodated in protected areas. The promise of no new access or well sites was broken with the advent of CBM. New access routes up to 200 m long are being developed to new well sites.
- The fifth was the advent of CBM without any public consultation. The RID never considered CBM, which is known to have a much greater footprint than conventional gas.
- The sixth is that although the government now claims it is following the RID, 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 (without public involvement) that determined there would be no major review. At the time it appeared petroleum-related activities were subsiding and CBM was not considered. Without studying and monitoring ecological integrity, we do not know if the management goal of preserving and protecting the ecosystem is being met. The government has also never ensured “ongoing and meaningful public involvement as the RID is implemented.” The government has not honoured this contract with the public. The implementation of conservation studies has only begun because of public outcry over CBM development in this protected area:
- A Technical Advisory Group was established in November 2005, including representatives from Alberta native Plant Council, industry and academia to guide research regarding reclamation and cumulative effects commitments in the RID. A 2006 survey showed a number of cases of non-compliance by industry, a serious problem with invasive species, and poor or non-existent reclamation.
- In 2006 range inventories with a rare plant species component were conducted in a part of the Rumsey block.
- A cumulative effects assessment is proposed as part of University of Alberta PhD student research in 2007 and 2008.
- Range inventories were completed in 1994 by Eastern Slopes Rangeland Seeds Ltd. Overall the range was evaluated in good condition; however, there were signs of heavy grazing on knoll tops, in wetlands, along trails and at dugouts.
- A grazing lease was sold and grazing regime changed in part of the area without a monitoring plan to assess the effects.
- The seventh is the hijacking, once again, of the agenda in Rumsey by Alberta Energy and their abuse of the public trust. Although the RID allows oil and gas development in perpetuity, Alberta Energy Information Letter 2003-25 says that new commitments in the 81 Special Places, which includes the Rumsey Natural Area, will not be allowed with surface access. Alberta Energy reneged on that promise and is allowing 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. Energy argued that the RID takes precedence over the IL, Community Development argued that the IL takes precedence because it is more recent. In the meantime, well licences are being approved.
Clearly, there were many times when the government could have made the decision to truly protect this area. Instead, continued development has been made the priority. The RID was developed prior to the designation of the area as a Natural Area and is considered out of date for the Natural Area. The RID and Information Letter are policy documents that do not have legal status.
Although the government is now planning a review of the RID, it currently insists the RID is the management plan. The RID says that sites of rare and sensitive flora will be avoided. Plains rough fescue grassland communities are now on the ANHIC Tracking List as elements of biodiversity considered “rare or special in some way.” Well sites, pipelines and access routes continue to destroy rough fescue grasslands in Rumsey.
The RID calls for ongoing and meaningful public involvement, but there has not been a mechanism or opportunity for public involvement in implementation of the RID. Public input has been ignored in allowing oil and gas development to continue in the Rumsey Natural Area. AWA’s offer to provide steward services in the Rumsey Natural Area (spring 2005) was declined. Parks has indicated that AWA must obtain a letter of permission from leaseholders in Rumsey to be the official volunteer stewards for Parks, another example of Parks not taking responsibility for protected areas.
Surface Access Argument
- As per the RID in 1993, some mineral rights in the Rumsey Natural Area were sold with a "no surface access" addendum, others were sold with a "subject to conditions" addendum (eg. plough in pipeline). There are two agreements between Alberta Energy and Community Development relating to each scenario.
- After Natural Area designation in 1996, Community Development tried but Alberta Energy refused, to put "no surface access" addenda on all mineral sales in Rumsey. Community Development attempted some creativity with conditions addenda (eg. helicopter access only).
- During Special Places a moratorium on new industrial developments was placed on candidate areas, although existing commitments were honoured. If an area was protected, no new surface access was allowed. This was later spelled out in Alberta Energy IL2003-25.
- The IL2003-25 specifically refers to "a total of 81 protected areas adding nearly two million hectares to the province's network of parks and protected areas." This necessarily includes the Rumsey Natural Area. The Parks Division asserted the IL confirms rights sold after 1996 are not considered "existing commitments" and therefore do not require surface access. Alberta Energy disagrees and reneges on the agreement in the IL. SRD maintains that the RID does allow CBM even though the RID committee only contemplated conventional gas (one well per section) and assumed that was being phased out (even as late as 2001).
- IL2003-25:
- Existing Subsurface and surface commitments will be honoured, which includes renewing dispositions for existing mineral activities.
- New surface dispositions for existing surface or subsurface commitments will be honoured as necessary 'extensions' to an existing commitment, subject to a review through the current application and approval process.
- Existing surface or subsurface commitments within a protected area cannot be used a a basis to access new subsurface rights within a protected area. By definition, any new subsurface disposition or subsurface right does not qualify as an existing commitment, as it came into effect after the protected area was established.
- In 1997, Alberta Energy was going to sell new leases in the Natural Area, a year after its designation. Environment Minister Ty Lund told the legislature there would be no new wells or new roads. Current CBM proposals call for both.
- In March 2006, Alberta Energy sent an interdepartmental directive to the ADM of Community Development directing that approval be given for surface access to mineral dispositions with the "subject to condition" addendum. Energy says it will continue to sell rights with the expectation access will be provided.
- Alberta Energy now considers an "existing commitment" to be any right that has been sold and remains undeveloped even if many years have passed and the right has been resold. AWA considers this to be an abuse of intent.


