AWA Statement of Concern: Shell Application for Lake Water for Fracking in Little Smoky Duvernay Region

AWA’s Statement of Concern to the Alberta Energy Regulator on Shell’s application to use up to 5 million m³ per year of Iosegun Lake’s water for oil and gas fracking operations. AWA requests that this application be denied until concerns about significant water and land impacts in the Little Smoky River watershed, where the water use would occur, are resolved.

AWA is concerned that:

• Fresh water consumption and disposal by multiple oil and gas fracking operations and operators in the Little Smoky exceeds the Alberta government’s capacity to monitor and manage cumulative impacts to water resources and aquatic ecosystems;
• Shell’s Iosegun watershed and fish population impact assessment is based on modelling that attempts to overcome significant water quantity and quality data gaps. The establishment of field-data-supported triggers and limits for water quantity and quality should be led by the provincial government rather than an energy company, and should precede approval of this application;
• cumulative effects management triggers and limits have not been set for upland, wetland and water course disturbance in west central Alberta. Without these limits, approval of applications under the Alberta Energy Regulator’s Duvernay pilot play-based regulation (PBR) will enable further regional land disturbance and watercourse sedimentation, which will likely harm important fish species populations in the Little Smoky watershed, such as sensitive arctic grayling (a species of special concern) and threatened bull trout;
• although this particular water use application will occur several townships east of the Little Smoky caribou range, the Alberta Energy Regulator started the regional Duvernay PBR pilot without setting net surface disturbance limits that are urgently required for recovery of endangered woodland caribou. Approval of applications under the regional PBR should not proceed without ensuring that endangered species’ habitat requirements are met.