November 30, 2021
Due to the severe risks to global biodiversity and ecosystem function from greenhouse gas emissions, AWA is unable to support the development of Alberta’s bitumen/oil sands deposits, due to their higher intensity greenhouse gas emissions.
The terms Oil sands, Tar Sands and Bitumen Sands are all in usage in Alberta. The term Tar Sands was used in the earlier days of industrial development, but was later largely replaced by the more benign-sounding Oil Sands. The product contained within the sands is in fact more akin to bitumen than either oil or tar. On these pages, AWA uses the term “Oil Sands” as the one in most popular usage, though this is not intended to align AWA to any one position in relation to the resource or its extraction.
Greenhouse gas emissions and their contribution to anthropogenic climate change pose a severe risk to biodiversity and ecosystem function worldwide. AWA does not support the development of Alberta’s oil sands deposits due to the high intensity greenhouse gas emissions produced through their extraction and eventual combustion.
Recognizing that oil sands development is proceeding, AWA believes that regional land, air and water impacts of oil sands exploration and development must be properly regulated to uphold Alberta’s and Canada’s international obligations to mitigate climate change, to maintain and restore biodiversity, to protect species at risk, and to use water resources sustainably in a manner that is consistent with the maintenance of wilderness values.
There are significant environmental impacts associated with oil sands exploration, extraction, transport, and processing, for which extensive scientific evidence exists. Some effects can be mitigated by technological innovation and stringent regulatory requirements, but until these technologies are proven, a precautionary approach must be employed. Planning development today, on the basis of future technology being developed to mitigate the impact is fundamentally flawed.
Full-field life-cycle planning must be required for all new developments including phase-out, remediation, and reclamation planning. Adequate reclamation liability must be assessed on a per-project basis that accounts for all remediation and reclamation costs, and does not leave Albertans vulnerable to major financial risks.
AWA believes both the provincial and federal governments must act quickly to develop more stringent science-based environmental regulations that would inform a world-class air, water, and biodiversity monitoring system. Similarly, the public must be confident that these regulations will be enforced. Until a world-class monitoring system has been developed, AWA recommends that a precautionary approach must be taken, and that new leases should not be issued. AWA also supports accessible and meaningful consultation processes with all stakeholders, especially where treaty rights are implicated.
One of the by-products produced through oil sands extraction is the fluid waste collectively known as tailings or tailings effluent. Tailings fluids are produced when water and chemicals are used to separate bitumen from other materials (e.g., clay, sand and silt). Following the separation of bitumen, these tailings are then housed in large storage reservoirs known as tailings ponds. The term tailings pond is misleading given the large volumes being stored, and there are now more than 1.4 trillion litres of tailings effluent scattered across Alberta’s oil sands region. As of 2020, there are 30 active tailings ponds across nine oil sands projects, and the combined fluid tailings area now encompasses nearly 120 km2.
The extent and volume of the tailings ponds poses a major environmental risk due to the potential for spills and seepage which can harm nearby ecosystems and the water supply for neighbouring and downstream communities. Oil sands operators have not yet been able to demonstrate how they can safely store and/or treat tailings effluent to avoid causing environmental harm, and industry has only put aside a fraction of money needed to cover the costs of reclamation – now estimated at $28 billion.
The Government of Canada and the Government of Alberta are currently developing new regulations under the Fisheries Act which propose to allow for the release of tailings effluent back into the Athabasca River so long as the effluent is treated to meet specific limits for harmful substances. AWA opposes the proposed plan to allow for the release of tailings effluent back into the receiving environment, and we oppose the creation of any new tailings ponds until a comprehensive tailings reclamation plan has been developed for the entire oil sands region. This plan should prioritize environmental outcomes and the wellbeing of downstream communities.
In April 2022, AWA participated in a kickoff meeting for the newly formed Responsible Tailings Management Alliance (RTMA) – a coalition of concerned groups focused on the issue of oil sands tailings. This introductory session was the first larger meeting for organizations interested in ongoing participation as the group looks to prepare for the imminent release of tailings effluent discharge regulations by Environment and Climate Change Canada (ECCC). The RTMA intends to serve as an information sharing hub for organizations to collaborate and strategize cohesively on this important issue. AWA are intending to participate in the RTMA in an ongoing capacity as we do not support the plan by both the federal and provincial governments to allow for the release of harmful effluent back into our already stressed aquatic ecosystems.
AWA participated in the annual work planning process to outline monitoring priorities for the Oil Sands Monitoring 2021/22 program year. We were disappointed to see that the wetlands monitoring Technical Advisory Committees only received 45% of their requested funding for the year, with terrestrial biodiversity monitoring only receiving roughly two–thirds of the funds they had requested. One major concern with the funding decisions that was voiced across the Oil Sand Monitoring program is that the geospatial work plan was cut by 85%. This will result in negative consequences for the intended monitoring work to be conducted by other Technical Advisory Committees.
AWA participates on the Oil Sands Monitoring program wetlands monitoring and terrestrial biodiversity monitoring Technical Advisory Committees. These committees are accountable for designing monitoring programs to address the priorities set out by the Oversight Committee.
AWA urges the Canadian government to reject Teck Resources Ltd.’s proposed Frontier open pit bitumen mine because of significant adverse effects to the environment and to the rights, land use and culture of Indigenous groups who use the project area. The federal–provincial joint review panel for Teck Frontier concluded that the proposed mitigation measures were not proven to be effective or to fully mitigate project effects. AWA also cited Alberta’s weak oil sands mine reclamation regulations, including inadequate financial security provisions and timelines, which we believe make it unlikely these mines will be reclaimed by their operators.
In February, Teck decides to withdraw the mine project. AWA welcomes this decision.
OSM 2020–21 funding decisions were made public. They included significant cuts to Terrestrial Biodiversity Monitoring ($4.2 million compared to $8.3 million funded the year before) and Wetlands Monitoring ($0.6 million compared to $2.7 million the year before). AWA looks forward to revived programs for 2021–22.
In early April 2020, AWA voiced concerns about the Government of Alberta’s March 31 decision to suspend most energy industry environmental compliance reporting requirements. We were unconvinced that this was a pandemic safety–related measure since all data gathering and record–keeping requirements remained. We joined First Nations and other ENGOs in raising concerns when Alberta further suspended most environmental monitoring requirements in late April and early May; this occurred at a time when other economic activities were re–opening with pandemic safety measures in place. Although reporting and monitoring resumed in July 2020, AWA remains concerned about the interruption of compliance reporting and loss of data collection without transparent justification.
In November, AWA becomes the AEN delegate to the new Wetland Monitoring TAC.
From autumn 2019 to February 2020, intensive workshops and meetings occurred at the Terrestrial Biological TAC to confirm and ensure monitoring programs align with OSM “stressor–pathway–receptor” conceptual models. There were discussions of ongoing integration across OSM Program elements of Air, Surface Water, Ground Water and Data and Integrated Analytics. The new Wetlands TAC built upon OSM–related Wetlands work of past few years and had similar discussions.
A positive new governance framework for the joint federal–provincial Oil Sands Monitoring (OSM) program was finalized. It includes significant Indigenous participation at all levels. This OSM framework includes a role for ENGOs on technical advisory committees (TACs). TAC members provide advice on monitoring and evaluation activities to date and review new work plans.
Since December, AWA has been the Alberta Environmental Network (AEN) delegate
on the Terrestrial Biological Monitoring TAC.
Oil Sands Monitoring program (OSM) begins as a collaboration between the Governments of Canada and Alberta. It replaces the previous Joint Canada–Alberta Oil Sands Monitoring (JOSM) program. The program is created to monitor, evaluate, and report on the environmental impacts of oil sands development in the Oil Sands Region, to assess the risks of impacts, and to improve our understanding of the state of the environment in an open and transparent manner.
The Joint Canada–Alberta Oil Sands Monitoring (JOSM) program begins.