AER Letter of Authorization re: Suncor’s McClelland Lake Wetland Complex Operational Plan
September 9, 2022
Suncor’s McClelland Late Wetland Complex Operational Plan was approved by a Letter of Authorization submitted by the Alberta Energy Regulator (AER) to Suncor on September 9, 2022. The AER provided Alberta Wilderness Association (AWA) with a copy of this Letter of Authorization on January 6, 2023, following our initial request for a copy on November 14, 2022. This letter states that “the AER authorizes the implementation of the Operational Plan” subject to the following three conditions:
- As outlined in both the Operational Plan and the Supplemental Information Request (SIR1) Response Letter, Fort Hills Energy Corporation (FHEC) has committed to various engagement, operational, monitoring and reporting activities. Authorization of the Operational Plan by the AER signifies that FHEC is required to comply with these commitments; any changes or amendment to the Operational Plan must be submitted in writing to the AER for review and authorization prior to their implementation.
- The SIR1 Response Letter, SIR #18 Response, stated that certain parameters were missing from Table 3.4-2. FHEC is required to provide an updated version of the Table 3.4-2, including all the missing parameters in all appropriate rows, to the AER for review, this updated Table is to be referenced in the 2022 Annual Progress Report.
- With regards to Surface Water Hydrology triggers: as discussed in the SIR1 Response Letter, SIR #8 Response, the AER expects the Operational Plan to include triggers that are designed to detect significant departures from the expected performance as quickly as practical. For example, in the case of a major performance failure, some of the Surface Water Hydrology triggers should be capable of detecting deviations within the first one to two years of operations. FHEC is required to assess the performance of the Surface Water Hydrology triggers in Annual Progress Reports and evaluate whether more sensitive triggers should also be included.
None of these conditions meaningfully address the concerns that our report highlighted with regards to the Operational Plan and Suncor’s ability to guarantee the protection of the unmined portion of the MLWC.
Click the link below to view a PDF version of the Letter of Authorization sent to Suncor on September 9, 2022 by the AER.