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Suncor Reply Submission to the AER’s Reconsideration Process for the Approval of the MLWC Operational Plan

July 27, 2023

Regarding the Reconsideration Process for the Alberta Energy Regulator’s (AER) approval of Suncor’s McClelland Lake Wetland Complex Operational Plan.

On Thursday July 27, 2023, AWA received Suncor Energy’s second reply submission to the Alberta Energy Regulator (AER), responding to the “new information” presented in AWA’s June 9 submission, as permitted by the AER’s letter to both parties on July 6, 2023.

Suncor’s second reply submission addresses the assessments made by 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.

In their submission, Suncor argues that AWA’s June 9 submission should be disregarded for the following reasons (among others):

  • It is contrary to law to use the AER’s Reconsideration Process to re-litigate issues from a separate proceeding that took place over 20 years ago (i.e., the 2002 EUB Decision).
  • The Operational Plan is not static and will continue to evolve over time.
  • Uncertainty in their approved Operational Plan is tolerable, stating that: “A degree of uncertainty always exists as plans are developed and uncertainty does not mean an activity should not be approved.”
  • Conceptual level design features are appropriate [at this stage] to identify and assess risks.
  • The MLWC has [already] experienced significant change over its history and that it is resilient and returns to a previous state following disruption and disturbance.

To read Suncor’s submission in full, please click the link below:


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