News Release: New Evidence Shows Major Gaps in Suncor’s Plan to Mine the Internationally Significant McClelland Wetlands, Should Lead Regulator to Revoke its Approval
June 12, 2023
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Alberta Wilderness Association (AWA) has submitted new evidence to the Alberta Energy Regulator (AER) highlighting extraordinary gaps in Suncor’s mitigation plan for the McClelland Lake Wetland Complex (MLWC), providing further justification for the AER to revoke its approval of the plan.
This mitigation plan (also known as the Operational Plan) is supposed to demonstrate how Suncor could guarantee the protection of the unmined half of this internationally significant wetland complex – which includes a spectacular patterned fen – from the impacts of the expansion of construction and mining activities at their Fort Hills oil sands mine in northeast Alberta.
A previous report submitted by AWA to the AER on March 31, 2023, highlighted seven major concerns with Suncor’s Operational Plan, and resulted in the AER opening a Reconsideration Process for their decision.
AWA’s latest submission, provided to the AER on June 9, 2023, contains new and compelling information from three prominent wetland experts – Richard Lindsay (University of East London, U.K.), Dr. R. Kelman Wieder (Villanova University, Pennsylvania), and Dr. David Locky (MacEwan University, Alberta) – following their review of Suncor’s Operational Plan. Our submission also outlines why Suncor’s reply submissions to the AER, submitted May 31, 2023, are deficient and should have no bearing on the AER’s reconsideration.
In the opinion of these three experts, the approved Operational Plan contains many significant gaps, which – if left unaddressed – pose a significant risk to the ecological diversity and function of the unmined wetland complex. These concerns include (but are not limited to):
- No testing of the practical implementation of Suncor’s proposed complex system of construction works and mitigation measures;
- A potentially compromised vegetation monitoring program that could miss changes caused by mine operations due to insufficient pre-mining vegetation data, and which omits rare plant indicator species, which could disappear without any warnings;
- No consideration for potential catastrophic changes to McClelland wetlands and Lake from a single point-source failure caused by mining or mitigation activities, in which case monitoring systems and response plans have been demonstrated to be utterly inadequate;
- Insufficient information included regarding water sampling protocols and the design of shallow peat wells used for measuring water quality in the McClelland Lake fen;
- An increased likelihood of error by calculating normal ranges for water quality across all seasons, rather than calculated seasonally;
- No information on how Operational Plan systems will be maintained, or by whom, over the centuries and millennia that peatland ecosystems operate; the timescales for responsibility approach those of a nuclear power plant rather than a short-rotation conifer plantation timescale that Suncor explicitly addresses; and
- The potential loss of an unrivalled archive of regional environmental information recorded over 11,000 years by one of the oldest and earliest forming peatland ecosystems in continental western Canada.
The Fort Hills mine’s 2002 regulatory approval decision from the Alberta Energy and Utilities Board indicates that mining would only be permitted to occur in half of the MLWC so long as the ecological diversity and function of the unmined portion is maintained.
According to Richard Lindsay, Head of Environmental and Conservation Research at the University of East London’s Sustainability Research Institute, “it is impossible to offer any degree of assurance in terms of the planning condition that the MLWC will remain unchanged following mine construction and restoration.”
“The evidence provided by these three experts is further proof that Suncor’s Operational Plan is speculative at best,” says Phillip Meintzer, Conservation Specialist with AWA. “If this plan cannot guarantee the protection of the unmined half of the complex, it should never have been approved by the AER in the first place.”
This compelling new information, alongside the previously submitted report, should lead the AER to reconsider and revoke their approval of Suncor’s plan, which was approved in September 2022.
To read AWA’s latest submission, please visit the following link:
Richard Lindsay has worked in peatland ecology and conservation for almost 50 years. He was a founding member of the International Mire Conservation Group, a network of researchers and advisors to their respective governments on peatland ecology and conservation, and he served as its Chair for 11 years. He advised the European Commission on a variety of high-profile cases, and has represented peatland conservation cases on behalf of statutory agencies, non-governmental organisations and local groups in public inquiries and legal cases. For more than a decade Richard has been the Head of Environmental and Conservation Research at the University of East London, UK.
Dr. R. Kelman Wieder is a professor of biology at Villanova University in Pennsylvania, USA. He is a professional peatland ecologist and biogeochemist who has been conducting research on bogs and fens in North America for over 30 years. He has experience working in peatland ecosystems in the oil sands region of Alberta and has been involved as a principal investigator on research and monitoring projects as part of Alberta and Canada’s collaborative Oil Sands Monitoring (OSM) Program.
Dr. David Locky is an Associate Professor in the Biological Sciences Department at MacEwan University. He is a certified Professional Wetland Scientist and a Professional Biologist. David’s research covers many aspects related to wetlands and other freshwater ecosystems. His projects include wetland classification, policy, land use impacts, and restoration. David has been involved in local to regional scale environmental impact assessments, including oil sands, pipeline, and upgrader projects.
For more information, please contact:
Phillip Meintzer, AWA Conservation Specialist,
(403) 283-2025,
pmeintzer@abwild.ca
Richard Lindsay, Head of Environmental and Conservation Research, Sustainability Research Institute, University of East London,
+44 (0)20 8223 4088,
R.Lindsay@uel.ac.uk
