AWA Concerns with the McClelland Lake Wetland Complex Operational Plan

April 3, 2023

• •
• •
• •

• McClelland Lake
• Oil Sands
• Wetlands
• WLA Archive

Wild Lands Advocate article by: Phillip Meintzer

Click here for a pdf version of the article.

Alberta Wilderness Association (AWA) is asking the Alberta Energy Regulator (AER) to reconsider and revoke its approval of Suncor’s Operational Plan for the Fort Hills Oil Sands Project.

The Fort Hills Oil Sands Project (FHOSP) is an existing Suncor-owned oil sands mine that began operations in 2018 and is proposed to expand mining activities into the McClelland Lake Wetland Complex (MLWC) in 2025. In 1994, AWA participated in a four-year sub-regional planning process that resulted in the protection of the MLWC from oil sands development. However, after the discovery of oil reserves underneath the MLWC, the sub-regional planning rules suddenly changed in 2002 at the request of True North Energy (a subsidiary of Koch Industries), which had acquired leases for the area in 1998 in spite of the existing protections for the area. Subsequently, the 2002 Energy and Utilities Board Decision Report permitted mining in roughly half of the wetland complex so long as the ecological integrity and functionality of the unmined portion is maintained.

The MLWC is a wetland ecosystem 90 kilometres north of Fort McMurray that includes several environmentally significant features including McClelland Lake, a large, patterned fen, and sinkhole lakes. The area provides an important stopover point and/or breeding ground for many migratory bird species from across North America (e.g., endangered whooping cranes [Grus americana], rusty blackbird [Euphagus carolinus] and yellow rail [Coturnicops noveboracensis]). With respect to birds, McClelland Lake is the largest natural waterbody between Fort McMurray and the Peace-Athabasca Delta, making it an important landing place for birds in an area dominated by hazardous tailings ponds, which have been responsible for numerous bird casualties. In addition to its biophysical properties, the area has socio-cultural importance for Indigenous communities in the region, who have relied on the MLWC as a source of drinking water, an area to harvest traditional foods and medicines, and as a place to practice and maintain their beliefs, customs, history, and languages.

According to the 2002 decision from the Alberta Energy and Utilities Board, Suncor was required to submit an Operational Plan for protecting the unmined portion of the MLWC two years prior to mining within the watershed. Based on AWA’s understanding of the foundational documents intended to guide the development of this project, this Operational Plan needed to guarantee that the unmined portion of the MLWC would be unharmed by the mining, closure, and reclamation activities within the proposed mine area, otherwise the expansion into the MLWC would not be authorized. On December 15, 2021, Suncor submitted this Operational Plan to the Alberta Energy Regulator for their assessment.

At the request of AER, Suncor provided AWA with a copy of the submitted Operational Plan for us to review on January 28, 2022. AWA’s intent with requesting a copy of the Operational Plan was to have an independent, third-party review of the plan conducted by experts in the disciplines of ecology, hydrology, and hydrogeology. We wanted this review to ensure that the mitigation measures proposed by Suncor within the Operational Plan would guarantee the protection of the unmined portion of the MLWC, as required by the 2002 and 2015 Water Act Approvals, and 2002 EUB Decision Report for the FHOSP to proceed with its expansion.

Over the next six months — from January to August — AWA contacted nearly 20 expert scientists, searching for researchers with specific expertise related to boreal wetland hydrology and/or peatland ecosystems. This search was time-consuming as it was difficult to find experts who did not have existing contractual ties or conflicts of interest with Suncor Energy.

In August 2022, AWA successfully contracted the independent services of two boreal wetland experts — Dr. Lorna Harris of WCS Canada and Dr. Kelly Biagi — who were willing and able to review Suncor’s Operational Plan in an effort to understand Suncor’s proposed mitigation plans and to determine whether any concerns had been left unaddressed, or if there were any evident deficiencies. Their review was completed on December 28, 2022. AWA has recently published a report that details the findings of this review, but our concerns have been summarized below for readers of the Wild Lands Advocate.

The assessments provided by Dr. Biagi and Dr. Harris indicate that the Operational Plan contains many concerns which pose a significant risk to the sustainability of the unmined portion of the MLWC.

These concerns include:

1. Unaddressed potential saline contamination of freshwater (wetlands and groundwater);
2. Lack of modelling for potential impacts to groundwater quality;
3. Insufficient observational data for hydrological model calibration;
4. Uncertainty and risk with proposed “conceptual stage” water management plan;
5. Assumption of negligible impacts from predicted water level changes;
6. Unrecognized potential impacts to fen structure maintenance; and
7. Unrecognized impacts to peatlands and potential contribution to greenhouse gas emissions.

Unfortunately, in November 2022, AWA was notified that the AER had already approved the OP via Letter of Authorization, submitted to Suncor on September 9, 2022, which seems to indicate that mining activities will be permitted within the wetland complex beginning in 2025.

AWA believes that the activities proposed within the Operational Plan may violate the conditions of the 2002 EUB Decision Report and 2002/2015 Water Act approvals. Given the concerns expressed by our expert reviewers and the high level of risk associated with the activities proposed by the Operational Plan, AWA are asking the AER to rescind their approval and for Suncor to abandon their plans to mine within the entirety of the McClelland Lake Wetland Complex.

We feel that it is important to highlight that peatlands – such as the MLWC – are critical for preventing and mitigating climate change, because they store an incredible 30 percent of all land-based carbon while only occupying three percent of Earth’s land area. Destroying peatlands not only releases stored carbon back into the atmosphere, but it also hinders our ability to capture and store those emissions in the future. Estimates from our review indicate that the minable area of the MLWC may store between 2.2 and 9.7 million tonnes of carbon, which would be released as mining activities at the FHOSP progress. Those estimates only represent the emissions produced from peat destruction and ignore any downstream emissions produced through the burning of mined petroleum by consumers. Given this knowledge, the destruction of peatlands not only threatens Canada’s ability to meet our international climate change commitments, but the future habitability of our planet as well.

We recognize that consideration of peatland destruction was not a requirement under the approval conditions set out by the 2002 EUB Decision Report or the 2002 and 2015 Water Act approvals. However, we feel that it is important to highlight that the loss of stored carbon from destroyed or degraded peatlands will only make fighting climate change that much harder.

The full report on the findings of our expert review of the Operational Plan will be made available on the AWA website for those who are interested in learning more. Our report will be submitted to the AER for their consideration. The report will also be provided to Pete Guthrie, Alberta Minister of Energy, Sonya Savage, the Alberta Minister of Environment and Protected Areas, Steven Guilbeault, federal Minister of Environment and Climate Change, as well as Jonathan Wilkinson, Canada’s federal Minister of Natural Resources.