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AWA Letter: M.O. 17 Suspending Environmental Reporting Requirements

April 3, 2020

Honourable Jason Kenney
Premier of Alberta

Honourable Jason Nixon
Minister, Alberta Environment and Parks

M.O. 17/2020

Dear Premier Kenney and Minister Nixon,

Alberta Wilderness Association (AWA) has serious concerns with your recent memorandum, M.O. 17/2020, (referred to as “the M.O.”) which has modified the operation of the Environmental Protection and Enhancement Act (EPEA), the Public Lands Act, and the Water Act, so that requirements to submit reports and returns are suspended until August 14, 2020.

Founded in 1965, AWA works throughout Alberta towards the completion of a wilderness protected areas network, and for good stewardship of all lands that are the source of our clean water, clean air and wildlife habitat.

Environmental compliance reporting acts as a real-time enforcement of regulations, and is the basis of our regulatory framework. If reporting is suspended, how will the provincial government ensure that compliance measures are being met in the field?  Take for example water licenses, where reporting data provides an important snapshot in time for parameters such as instream flows. Without regular reporting from proponents, there will be a time lag in determining whether a proponent is meeting expectations.

When will the “suspended” reports eventually be required for submission to the provincial government? Will the provincial government continue to retain the staff required to process and enforce reporting requirements and environmental infractions – if so, what is the benefit in creating a backlog of reports to be processed?

The M.O. states that there is “hardship in having to comply with routine reporting requirements […] during this public health emergency”. Since many industries are being permitted to continue operating, and are supposed to retain complete information for reporting requirements, we question this alleged “hardship” and believe this is an abdication of responsibility by the Alberta Government. AWA fears that this M.O. will encourage approvals holders to increase environmentally risky activities and to cut corners with data gathering.

Infractions and incidents that cause potential harm to our lands and waters occur frequently in Alberta, and require constant vigilance. In the month of January 2020 alone, there were 18 “incidents” reported by the Alberta Energy Regulator (AER), which entail reportable releases of hydrogen sulphide, hydrocarbon, produced water, and/or releases which affect water bodies. Of these 18 incidents, 10 involved pipelines, 4 wells and 4 facilities; incidents included spills of crude oil, produced water, and condensate. Given that your government has recently listed petroleum, natural gas and coal production as an essential service, AWA believes it is irresponsible to abandon reporting requirements as production and storage of these materials continues.

Likewise, other industries and manufacturers – such as forestry, aggregate, refining, and petrochemical industries – have also been listed as essential services and have the potential to contravene EPEA, the Public Lands Act and Water Act.

Environmental health is a critical component of public health and wellbeing; the Acts listed in the M.O. provide important protections. The government also has responsibilities to protect our drinking water and fish and wildlife. Even relatively “small” spills of produced/salt water can kill native fish species such as Arctic grayling (Blair et al. 2016).

If industries are continuing to operate, a requirement to report is a bare minimum that can be expected. AWA respectfully requests that all standard reporting requirements for any industry that is continuing to operate be maintained and enforced.


Joanna Skrajny
Conservation Specialist

cc: Marlin Schmidt, Environment Critic,

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