A Review of Suncor’s McClelland Lake Wetland Complex Operational Plan for the Fort Hills Oil Sands Project

November 21, 2024

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Executive Summary:

The Fort Hills Oil Sands Project is an existing Suncor-owned oil sands mine that is proposed to expand mining activities into the McClelland Lake Wetland Complex (MLWC) in 2025.

The MLWC is a wetland ecosystem that includes several environmentally significant features including McClelland Lake, a large, patterned fen, other wetlands, and sinkhole lakes. The area provides an important stopover point and breeding ground for migratory bird species from across North America. In addition to its biophysical properties, the area has socio-cultural importance for Indigenous communities in the region.

According to the 2002 Fort Hills regulatory approval decision from the Alberta Energy and Utilities Board, mining would only be permitted to occur in half of the MLWC so long as the ecological diversity and functionality of the unmined portion is maintained. Suncor was required to submit an Operational Plan for protecting the unmined portion of the MLWC two years prior to mining within the watershed. On December 15, 2021, Suncor submitted this Operational Plan to the Alberta Energy Regulator.

Alberta Wilderness Association contracted the services of two boreal peatland experts – Dr. Lorna Harris and Dr. Kelly Biagi – to review Suncor’s Operational Plan and determine whether it would guarantee the protection of the unmined portion of the MLWC. The findings of the review conducted by Dr. Biagi and Dr. Harris indicate to AWA that the Operational Plan contains many uncertainties and deficiencies which pose a serious risk to the sustainability of the unmined portion of the MLWC, and which contravene the justifiably stringent regulatory requirements that have been placed upon the Fort Hills mine.

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 impacts to the ecological integrity and functionality of the patterned fen; and
7. Unrecognized impacts to peatland carbon stores and the resulting increase in greenhouse gas emissions.

These review findings indicate that Suncor has not provided evidence of sufficient knowledge and understanding of the complex natural water flow regime in the wetland complex to ensure that there will be no negative impacts to the ecological diversity and functionality of the unmined portion of the MLWC. The review findings also raise significant concern regarding whether the proposed underground wall and water pipeline system is robust enough to adequately substitute for these natural flows, and to counteract mining impacts upon local groundwater sources, continuously, throughout many decades of proposed mine operation and reclamation.

This Operational Plan cannot guarantee the protection of the unmined MLWC. The findings lead us to believe that Suncor’s mitigation strategy described within the Operational Plan poses a significant risk of irreversible damage to the unmined portion of the MLWC, and therefore, it should not have been approved by the AER.