This morning, the Government of Alberta released its draft for the Lower Athabasca Regional Plan to be discussed in the Legislature and then passed on to Cabinet (press release by Government of Alberta). Despite initial appearances, protection for water in the oil sands region remains inadequate, and stewarding the regional plan without strong water protection places the waters of northern Alberta at risk.
The Lower Athabasca Regional Plan (LARP) speaks of protecting Alberta’s northern water resources, but from a scientific point of view it is hardly a plan, as the plan largely asks concerned citizens to trust the government with "to be" determined monitoring plans and panels. It should offer clear scientifically justifiable management thresholds and limits to ensure the strong protection of Alberta’s water resources. Water Matters strongly supports regional planning, but it is important for the Land-Use Framework to deliver regional plans that protect our resources, not merely offer the appearances of doing so. In that spirit, we offer the following critique of the draft LARP released today.
What’s Missing? Monitoring and Real Limits
The Government of Alberta’s plan for monitoring states:
“Monitoring, evaluation and reporting are key activities for the success of the
Lower Athabasca Regional Plan.To respond effectively to changing circumstances
and new information, government must have a way to assess regional planning
progress on objectives and outcomes and initiate corrective action where
Despite this claim, the Government of Alberta has yet to commit to a monitoring plan. The current knowledge of baselines for water quality and the effects of oil sands development on aquatic ecosystems are generally unknown. Simply put, the Government of Alberta cannot regulate limits if these limits are not clearly and scientifically defined. As evidence below, Environment Minister Rob Renner has stated as much himself. Additionally, the Royal Society question about the capacity to monitor adequately remain unanswered.
1) The provincial monitoring panel has handed the Ministry of Environment recommendations, concluding that “the overall state of environment is unknown”, for which even the Minister admitted current system is piecemeal and ad hoc (see July 5, 2011 CBC News story)
2)The LARP does not lay out how capacity to monitor oil sands will increase, or if approvals for oil sands projects will slow down. Unless approvals for oil sands projects slow down, monitoring could become ineffective because information on environmental impacts is scarce. Even the Government of Alberta (Provincial Panel) admits information on environmental impacts hasn't been adequately collected since oil sands development began decades ago. The same conclusion that inadequate data collection on oil sands development were raised by the Royal Society of Canada , Federal Oil Sands Advisory Panel, and Regional Aquatics Monitoring Peer Review .
In the draft plan, the Government of Alberta appears to be moving forward on water monitoring and limits by:
- Approving for Implementation the Surface Water Quality Management Framework
- Approving the Approach with Triggers and Limits to be Developed: Groundwater Management Framework
- Approved for Development: Surface Water Quantity management (see p. 26)
The reality is that monitoring of surface water and groundwater in the draft plan offers only guidelines. These guidelines cannot demonstrate the effects oil sands development has on ecosystems health or tell Albertans if oil sands development is using water (surface and ground) sustainably.
For monitoring to be effective in the oil sands region, the Government of Alberta needs increase the capacity to monitor so that they may develop a scientifically defensible and reviewed system in the region before rapidly approving oil sands projects. The government also needs to make it clear that operations and approvals may be curtailed if water resources are impacted beyond acceptable thresholds.
To assure Albertans that monitoring is going to be effective and measure the impact of oil sands development, monitoring should look into the effects on aquatic ecosystems and work with the Government of Canada to share resources. For more, see Water Matters Report on Effective Environmental Monitoring.
What’s Missing? Policies to protect surface water and groundwater
For water withdrawals from the Athabasca River, the Government has yet to protect the Athabasca River during low flows. Absolute cut offs for withdrawals from oil sands companies were a non-consensus item outlined in the Phase 2 Athabasca Framework Committee recommendations. 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. Instead of leading and standing up the environment, in this plan the government of Alberta has left the Lower Athabasca River Basin with weak guidelines.
The draft Lower Athabasca Regional Plan Groundwater Framework fails to provide a limit on licensing for regional withdrawals of groundwater. In other words, there is no stop button “management response” for groundwater withdrawals.
1) Sustainable yield (i.e. what can be withdrawn without harm to other
aquifers and aquatic ecosystems connected to rivers and lakes and
wetlands) not being measured.
2) Current limits are not binding under the draft plan.
3) Without understanding regional aquifers in the oil sands regions, the risks to the contamination of rivers, lakes, and wetlands remain unknown.
For the Lower Athabasca River Basin to sustain economic activity, wildlife, aquatic life, and people, strong management responses are necessary including absolute cut offs for water withdrawals of the river if required. The absence of absolute cut offs threatens the sustainability of the Lower Athabasca River.
For the protection of groundwater, the LARP is critical. In order for the LARP to protect groundwater resources that are connected to lakes, rivers, and wetlands, the Government of Alberta must immediately develop baselines for the sustainable yield of aquifers and withdrawal limits on groundwater licences, and implement a monitoring system to gather data on regional aquifers.
Albertans believe in action more than empty process. For the LARP — the first draft regional plan of the Land-Use Framework before Cabinet - to demonstrate real commitment the government needs to augment it in the ways described here so that it reaches beyond the appearance of protection to reach clear commitments to do so.