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Nice Plan No Action

Environmental monitoring plans from the Government of Canada and Government of Alberta look good in terms of promoting sound science for monitoring, however, these plans are just plans and demonstrate no real action. Here's why:

1)    There has been no indication from either government that approvals for oil sand projects are going to slow down even though independent reports (Royal Society of Canada, Federal Oil Sands Advisory Panel, Regional Aquatics Monitoring Peer Review) - including from the Government of Alberta (Provincial Panel) - admit that information on environmental impacts hasn't been adequately collected since oil sands development began decades ago.

a. The Regional Aquatics Monitoring Program (RAMP) responsible for environmental monitoring of aquatic ecosystems has consistently failed to achieve its mandate. In its most recent scientific peer review, RAMP failed to meet 8 out of 9 objectives, and the only objective achieved was the commitment to the scientific review itself.

b. The recent report by the Provincial Expert Advisory Panel (see Provincial Panel) acknowledges that the "overall 'state of environment' is not well understood."

2)    So far, the Government of Alberta is only reviewing and considering panel recommendations. The Government of Alberta has not committed to implementing any of the changes that have been recommended during the last year.

3)    Neither the Government of Canada nor the Government of Alberta has demonstrated a move to regulating the oil sands industry in a way that is consistent with either the spirit or the requirements of their environmental laws and regulations.

4)    The Government of Alberta's current policies and management plans do not protect surface waters or groundwater.

a. The Phase 2 Athabasca Framework Committee recommendations for the Lower Athabasca Water Management Framework includes no absolute cut-off for withdrawals of water from rivers by oil sands companies, no matter how low flow get. First Nations and environmental groups did not agree with this critical aspect of the plan, while industry and government were the primary supporters of it.

b. The draft Lower Athabasca Regional Plan Groundwater Framework fails to limit licensing or regional withdrawals of groundwater.

c.  Alberta's draft monitoring plans for surface waters and groundwater continue to be designed with the priority on detection of industrial compliance to water quality guidelines, rather than detection of effects of regional development on surface water or groundwater sustainability or ecosystem health (i.e., so long as concentrations of a very limited number of contaminants don't exceed guideline concentrations, everything is fine and where the contaminants end up and what their effect is don't matter).

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