CAPP respectfully requests that NWT Association of Communities make its decision on this resolution based on the facts and in consideration of a thorough, broad, balanced understanding of the issues.
May 22, 2009
NWT Association of Communities
Terry Kruger
Communications & Policy Coordinator
200, 5105-50th Street
Yellowknife NT X1A 1S1
Re: April 14, 2009 Resolution on development of Canada’s oil sands
The Canadian Association of Petroleum Producers (CAPP) in reference to the resolution passed by Yellowknife City Council for the NWT Association of Communities’ consideration concerning the development of the oil sands.
We understand that this resolution is based on concerns with the quality of water supply and share your concern for maintaining water quality within and beyond the Athabasca region. We would be grateful if you could share any data that you may have supporting your concerns with water quality and the potential link to oil sands development so that we may validate and take action as appropriate.
In the interest of discussing these complicated issues with full disclosure and consideration of all the available facts we would like to direct the Association’s attention to the following information, with a request that it be included in the public record, emphasizing our view of the importance of clarity and accuracy with respect to Athabasca River water quality. We therefore recommend that this resolution not be moved forward without greater opportunity for a more balanced consideration of the facts.
Environmental Performance
Provincial and national regulatory frameworks in Canada are among the most stringent in the world. Alberta Environment prohibits the release of any water into the Athabasca River that does not meet water quality requirements. As part of an industry commitment to compliance and continuous improvement, the Regional Aquatics Monitoring Program (RAMP), an industry-funded, multi-stakeholder environmental monitoring program, was initiated in 1997. RAMP integrates aquatic monitoring activities across different components of the aquatic environment, different geographic locations, and Athabasca oil sands and other developments in the Athabasca oil sands region, so that long-term trends, regional issues and potential cumulative effects related to oil sands and other developments can be identified and addressed. For more than a decade, detailed measurements have been taken both upstream and downstream of oil sands developments.
RAMP has detected no impacts to the Athabasca River ecosystem due to oil sands production. We would refer you to the appendices attached to this submission, addressing arsenic, PAH and dissolved organic carbon concentrations in the Athabasca River.
It is important to note that bitumen from exposed oil sands along the river banks seeps naturally into the Athabasca River as it cuts its way thought the landscape. As a result, natural water quality includes measureable hydrocarbon compounds. Aquatic monitoring in the Lower Athabasca River has shown no impacts associated with oil sands development.
Most tailings ponds are located more than one kilometer from the Athabasca River. Preventative measures to limit seepage include tailing sands dykes constructed with drains to intercept seepage and return it to the tailings ponds. Seepage into ditches and other interception systems are also returned to the tailing ponds. The industry acknowledges that some seepage may bypass the seepage interception systems. Again, however, aquatic monitoring both upstream and downstream of oil sands development shows no impact that can be associated with any seepage.
Ongoing testing supports the view that seepage, to the extent that it might occur, is at low quantities over very long periods of time. Before making a decision with respect to this resolution we invite council to review recent regulatory decisions that have addressed the issue of improvements in tailings performance. Government, public and industry standards are high, in Alberta, nationally and globally. In fact, current regulations provide the necessary and appropriate levels of environmental protection with respect to the possibility of a catastrophic breach of tailings ponds.
A great deal of inaccurate information has been published about the oil sands, water usage, water quality and environmental performance. We invite council to consider the following information to put oil sands development in context: The total amount of water allocated to the oil and gas sector from the Athabasca River is 2.2 per cent of the river’s natural flow. In terms of Athabasca River actual water usage, the total amount used in 2007 was 0.2% (2008 figures are not yet available).
With respect to water use, oil sands producers recycle a minimum of 85 per cent, and in some cases more than 90 per cent, of water used in production and, where feasible, use saline or brackish water. Water use is restricted further during the Athabasca River’s low-flow periods.
Canada’s oil sands can and are being developed in parallel with continuous improvement of environmental performance and technological improvements on several fronts. For example, the industry has reduced its average GHG emissions per barrel by 38 per cent since 1990. Approximately half of this reduction is due to technology advancements and energy efficiency improvements, and the balance is primarily due to the fact that an increasing percentage of oil sands production is being refined in the U.S. rather than in Canada. Again, to put the environmental impact of oil sands GHG emissions in context, they amount to 5 per cent of Canada’s total GHG emissions and 0.1 per cent of global GHG emissions.
CAPP would be pleased to provide, as requested and should the opportunity be provided, more detailed information on improved tailings technologies and assessment of the cumulative effects of the oil sands.
Regulatory Oversight
We invite council to consider the following:
- Tailings pond dykes require extensive geotechnical design prior to construction. All tailings dykes require government approval before construction begins.
- All dykes are monitored to ensure they have been constructed to the geotechnical design specifications and meet their design performance criteria. Annual monitoring reports are submitted to regulatory agencies and are available for public review.
- Given the rigour applied to the design, construction and monitoring processes, an oil sands containment dyke breach is extremely unlikely and there is no need for additional contingency plans.
- Estimates of seepage and the potential environmental effects are included in a project's EIA and thoroughly reviewed during the regulatory approval process.
- Extensive research on tailings has been conducted since the 1960s and the industry continues to develop better technologies and approaches to tailings management in order to further reduce the environmental impact of tailings.
We would direct Council to the Alberta ERCB Tailings Performance Criteria Directive 074 issued by the ERCB in February 2009. The Directive requires all oil sands operators to be converting fine tailings into reclaimable landscapes by 2012. This will result in significant reductions in accumulation of fine tailings, a decrease in the number of new tailings ponds required to support oil sands development, and considerable acceleration of the progressive reclamation of new and existing tailings ponds.
Further to the ERCB Tailings Performance Criteria Directive, various new technologies are currently under development that will enable oil sands mines (not just future developments) to comply with the Directive.
These technologies include:
- Mixing tailings with gypsum, lime, polymers or CO2 which collapses the structure of the clays and releases the water, thereby speeding up the reclamation cycle.
- Mechanical tailings thickeners or centrifuges can also be used to reduce the water content of the fine tailings.
- Air drying or freeze/thaw desiccation in the winter is an alternative but, unlike the former alternatives, the trapped water is lost to the environment and cannot be recycled in the process.
- Dry tailings processing.
Economic growth and energy supply
CAPP urges Council to consider the impact of the measures proposed in this resolution. Prior to the recession, the oil sands industry component of the oil and gas industry affected the livelihoods of 240,000 Canadians – 44 per cent of whom live outside of Alberta – and the potential to create, over a 20-year period, $123B in royalty and tax revenues that support health care, education and social services across Canada. The projected capital spending for all oil and gas activity in Canada for 2009 is $34B, including $500M in Northern Canada.
That said, and notwithstanding the critical impact of the industry on Canada’s economic and social well-being, the industry recognizes that it must continually uphold and improve environmental performance, as noted above, as development proceeds. These are not mutually exclusive objectives and form the basis of a Triple-E approach to responsible resource development: Environment, Energy and Economy.
In the context of the importance of the oil and gas sector to the Northwest Territories, it would be unfortunate if Council were to make this decision without recourse to a broader and more balanced understanding of the impact it would have on the lives and well-being of many Canadians, now and in the future.
Thank-you for the opportunity to submit the information above. We understand that this is the first of several steps in this or similar resolutions that will proceed, if approved, to the Northwest Territories Association of Communities and its AGM in May. CAPP understands that our industry must improve communications on the substance and extent of the industry’s water quality protection measures and the regulations, laws and monitoring in place to ensure compliance on this and related issues. At the same time, CAPP and its members feel that it is important, for the record, to table for Council’s information accurate information regarding the actual, as opposed to speculative, impact of oil sands development on the Athabasca River.
CAPP respectfully requests that Council make its decision on this resolution based on the facts and in consideration of a thorough, broad, balanced understanding of the issues.
Sincerely,
D.R. Collyer
President
PAH Concentration in Athabasca River Sediments
Shows PAH mg/kg, Normalized to 1% TOC
shows no change across the region
Note: the "Upstream East" sampling area is located adjacent to a large bitumen seep into the Athabasca River.
Dissolved Organic Carbon Concentrations in Athabasca River
Shows dissolved organic carbon mg/L
shows no change across the region
Arsenic Concentrations in Athabasca River Water
Shows Arsenic mg/L
shows no change across the region