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AWA Letter to AER Re: Suncor Requesting the AER Disregard AWA Reply Submissions

June 21, 2023

Regarding the Reconsideration Process for the AER’s approval of Suncor’s McClelland Lake Wetland Complex Operational Plan.

On June 21, 2023, Alberta Wilderness Association (AWA) sent the following letter the Alberta Energy Regulator (AER), in response to Suncor’s letter to the AER dated June 16, 2023, which requested that the AER disregard AWA’s June 9 reply submissions, as well as the AER’s letter to AWA dated June 19, 2023, which asked if AWA would like to provide reply submissions to Suncor’s request, and if yes, to submit a response by 4:00 p.m. on Friday, June 23, 2023.

AWA’s letter concludes that:

“AWA included the appendices to its reply submissions to specifically address new issues raised in Suncor’s response submissions. AWA’s submissions were thus properly within the domain of reply as a matter of procedural fairness. Moreover, Suncor is not without opportunity to test the evidence in AWA’s reply submissions during Phase 2 of these proceedings. The Regulator should consider AWA’s reply submissions in full in making its determination of whether to proceed with a reconsideration, and Suncor does not need a further opportunity to test the evidence in AWA’s reply submissions prior to Phase 2 of these proceedings.

Contrary to Suncor’s assertion that AWA has somehow denied Suncor an opportunity, Suncor had plenty of opportunity to raise and argue new issues, and Suncor spent that opportunity. Suncor knew full well that AWA then had the subsequent opportunity to provide reply submissions regarding those new issues which Suncor raised. For Suncor to then claim that AWA should be denied the opportunity to provide its reply submissions is disingenuous and offensive to the fairness of these proceedings, especially given that Suncor will have ample opportunity to test the evidence in Phase 2. The Regulator should therefore dismiss Suncor’s request regarding AWA’s reply submissions.”

To read AWA’s letter in full, please click the link below:


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