Oil Sands Environmental Coalition

Transcription

1 Oil Sands Environmental Coalition Suite 602, Street, Edmonton, AB, T5J 1G4 31 August 2012 Alberta Environment and Water Attention: Patrick Marriot, District Approvals Manager Regulatory Approvals Centre Main floor, Oxbridge Place Street Edmonton, Alberta T5K 2J6 Re: TECK RESOURCES LIMITED FRONTIER OIL SANDS MINE PROJECT Application No , EPEA No , and Water Act File No Dear Mr. Patrick Marriot, Thank you for your letter dated July 19, 2012 responding to the Oil Sands Environmental Coalition s statement of concern for the Frontier Oil Sands Mine Project. We have provided responses to your questions below. 1. Please identify how many members of the Oil Sands Environmental Coalition are directly affected by the proposed Project. Please reply with particular reference to the nature and location of their individual activities relative to the location of the proposed Project. All members of OSEC are directly affected by the proposed Project. All OSEC members have access to our recreational leased lands. Members of OSEC include the Pembina Institute and the Fort McMurray Environmental Association (FMEA). OSEC has an interest in lands (description of lands attached) near Fort McKay and in close proximity to the proposed Project. The interest consists of a license to occupy lands on and near the McKay and Athabasca Rivers for recreational purposes, such as hiking, birdwatching, camping, swimming and boating. See attached photo documentation of OSEC s recreational use of lands (OSEC recreation.pdf). Therefore, 46 employees from Pembina and 37 members of FMEA will be directly affected relative to their recreation activities on the leased lands. The recreational lands are described in the attached document (OSEC recreational lease lands description.pdf). Individual members of FMEA living in nearby communities (Fort McMurray, Anzac, Fort Chipewyan) will also be affected by the proposed Project. 1

2 2. Please identify how you anticipate the proposed Project will directly affect specific members of the Oil Sands Environmental Coalition. As all members of OSEC have an interest in recreational lands near Fort McKay, all members of OSEC will be affected by environmental impacts in this region resulting from the proposed Project. The proposed Project is a significant source of air pollution emissions and OSEC is concerned that the addition of this Project will exacerbate air quality conditions in the region. As noted in the Project s application, the Local Study Area (LSA) extends south beyond Fort McKay including the location of OSEC s recreational leased lands. According to modelled data in the Project s applications, air quality in the LSA will be exceeding critical levels in the base case and the further addition of the Project in the Application case will make mitigating these impacts more challenging. Specifically: According to modelled data in the Base case, air quality in the LSA will be exceeding the Ambient Air Quality Objective (AAAQO) for the annual average concentrations of NO 2. The addition of any new sources of emissions beyond the Base case is of direct concern to OSEC members. Furthermore, according to the Application case, the Project will result in increased concentrations of NO 2 above Base case levels. Beyond the LSA, regions in the Regional Study Area (RSA) including Fort McMurray will be similarly impacted. According to modelled data in the application, air quality in the RSA will be exceeding the AAAQO and the Project will result in increased concentrations of NO 2 above Base case levels. This is also of direct concern to OSEC, particularly the membership of OSEC residing in Fort McMurray. According to modelled data in application, air quality in the LSA under the Base case will exceed Alberta s air quality guideline for 1-hour concentrations of PM 2.5. The addition of any new sources of emissions beyond the Base case is of direct concern to OSEC members. Furthermore, according to the Application case, the Project will result in increased concentrations of PM 2.5 above Base case levels. According to the application, ambient concentrations of PM 2.5 modelled specifically at community locations will exceed the 24-hour PM 2.5 AAAQO for Fort McKay (both scenarios) and Fort McMurray. In both, cases the addition of the proposed Project results in similar or higher ambient air concentrations of PM 2.5 for these locations. Members of OSEC living in Fort McMurray have additional concerns specific to the Project s impacts on their community of residence: Housing: the addition of a need for 1,085 dwelling units for the Project above and beyond the Base case may worsen already existing housing affordability challenges. As noted in the application, [s]trong population growth in Fort McMurray combined with a lack of available land and high costs of development have contributed to a housing shortage in Fort McMurray. One implication of the housing shortage in the region is high house prices. Social infrastructure: as noted in the application, The municipality still has some concerns in meeting infrastructure and service demands. OSEC is concerned that the 2

3 additional infrastructure associated with the Project will create further challenges for the City of Fort McMurray to address the existing infrastructure and service shortages. Traffic: members of OSEC are also concerned about the increase of traffic within the region and the risk of increased vehicle collision rates. While the application did not assess traffic within the City of Fort McMurray, it did note increased traffic levels resulting from the Project on highway segments north of Fort McMurray including a 1.6% increase over Base case volumes north of Fort McKay. The application notes While collision rates on Highway 63 remain below the provincial average for the applicable roadway type, the volume of larger vehicles, including hazardous goods, travelling along the region s highways, remains a concern for area residents. As well, the study area experiences higher peaking, both daily (morning and evening) as well as on shift turnaround days, which results in higher than average volumes during those periods. 3. Please identify the environmental consequences of the proposed Project of direct concern to specific members of the Oil Sands Environmental Coalition. OSEC s objectives are: monitoring the environmental implications of oil sands development, and minimizing the environmental impacts associated with oil sands development in the Athabasca Oil Sands region. OSEC has been engaged in reviewing and assessing oil sands development since the mid 1980's and has been particularly active in the assessment and management of long-term chronic and cumulative impacts. OSEC has provided evidence and submissions to the Alberta Energy Resources Conservation Board (formerly the Alberta Energy Utilities Board) at numerous hearings, including the following: The 1993 Syncrude expansion hearing (under the name Syncrude Environmental Assessment Coalition) The 1997 Syncrude Aurora Mine (Pembina Institute and Toxics Watch) The 1998 Shell Canada Muskeg River Mine Project The 1999 Suncor Millennium Project The 1999 Syncrude Canada Mildred Lake Upgrader Expansion The 1999 PanCanadian Christina Lake Project The 2000 Petro-Canada McKay River Project The 2002 TrueNorth Fort Hills Project The 2003 Joint Panel Review of the CNRL Horizon Project. The 2003 Joint Panel Review of the Shell Jackpine Mine Phase 1 Project The 2006 Suncor Voyageur Expansion Project The 2006 Shell Albian Muskeg River Mine Expansion Project The 2006 Imperial Kearl Project The 2010 Total Joslyn Mine Project 3

4 In accordance with OSEC s objectives, a number of environmental impacts from the Project are of specific concern to OSEC s members. While OSEC is still undergoing further review of the Project s application, a number of environmental impacts were identified in OSEC s statement of concern. These include: Increasing greenhouse gas emissions with Alberta and Canada The impact of the Project s air emissions on ambient air quality in the region The impact of the Project air emissions in terms of increases in the Potential Acid Input and its effect on terrestrial and aquatic ecosystems in the region Water impacts resulting from the cumulative water withdrawals from the Athabasca river The loss of wetlands and peatlands in the region Terrestrial impacts resulting from the Project s footprint (disturbed area) Impacts to wildlife species and wildlife habitat in the region Long-term reclamation of wetland and the loss of regional biodiversity Please refer to OSEC s Statement of Concern for further details. 4. Please provide a breakdown of the Oil Sands Environmental Coalition membership in terms of the communities that the members currently live in (e.g. how many reside in Fort McMurray, Fort Chipewyan, Fort McKay, etc). Please include documentation allowing us to verify the information provided. The Oil Sands Environmental Coalition is an unincorporated coalition of Alberta public interest groups and individuals with a longstanding interest in the Athabasca Oil Sands area. OSEC was formed to facilitate more efficient participation in the regulatory approvals processes for oil sands applications. Its current members include: the Fort McMurray Environmental Association, which consists of residents living in and around Fort McMurray who are concerned about the effects of oil sands development on human health, the ecosystem and the socio-economic quality of life in the municipality of Wood Buffalo. The Fort McMurray Environmental Association has 37 members as of the Pembina Institute, which is a non-profit environmental research and policy analysis organization founded in Alberta in One of Pembina s objectives is to minimize the environmental impacts associated with fossil fuel development in Alberta. The Institute has monitored the health and environmental implications of oil sands development since the mid 1980's and has been particularly active in the assessment and management of long term, chronic and cumulative impacts. The Pembina Institute has 46 employees, of which about 23 reside in Alberta. An employee list is attached. Therefore, the membership breakdown by location for the Oil Sands Environmental Coalition is as follows: Fort McMurray: 35 members Fort Chipewyan: 1 member 4

5 Anzac: 1 member Other communities in Alberta: 23 members Please see attached the supporting documentation: Pembina Staff list (Pembina Staff list - Aug pdf) Fort McMurray Environmental members list (Fort McMurray Environmental Association - Membership.pdf) Sincerely, Marc Huot Policy Analyst The Pembina Institute MarcH@Pembina.org On behalf of the Oil Sands Environmental Coalition 5

6 Environmental Assoc. Membership List Dort- MacLean 2. S. Holden 3. R. Lefort 4. S. Pearce 5. J. Bourque Fort Chipewyan 6. m. Matheson 7. A. Drover 8. T. Jackson 9. k. Nolan 10. A. Boisvert 11. D. Gabriel 12.A. Roberts 13.M. Tilley 14. A. Purcell 15.L. Simms 16.M. Janes 17.R. McCallum 18.M. Callaghan 19. M. Tolen 20. R. Woodward Anzac 21. A. Adams 22. L. Henry 23. J. Peckham 24. S. Miron

7 25. V. Fustic 26. B. Simcoe 27. D. Ross 28. M. McMurrer 29. C. DiProse 30. D. Baggs 31. J. Hicks 32. T. Grantham 33. P. Helmer 34. L. Upton 35. A. McEachern 36. D. O Neil 37.D. McKeough

8 OSEC members recreating on lands near the MacKay River

9 OSEC members recreating on lands near the MacKay River

10

11

12

13

14

15 Current Staff - Pembina Institute Generated By: Barb Bundt 29/08/2012 5:47 PM Total Staff: 46 Total Staff in Alberta: 23 Relationship First Name Last Name Role Mailing Street Mailing State/Province Mailing City: Calgary 10 Staff Simon Dyer Street NW AB Staff Matt McCulloch Street NW AB Staff Jesse Row Street NW AB Staff Jason Switzer Street NW AB Staff Ben Thibault Street NW AB Staff Chris Severson- Baker Street NW AB Staff Ed Whittingham Street NW AB Staff Gail Foster Street NW AB Staff Nimra Amjad Archer Street NW AB Staff Eli Angen Street NW AB Mailing City: Canmore 2 Staff Jennifer Grant Suite 204, 820 Main Street AB Staff Julia Kilpatrick Suite 204, 820 Main Street AB Mailing City: Drayton Valley 4 Staff Bev Broks PO Box 7558 AB Staff Pam Taks PO Box 7558 AB Staff Sarah Smith PO Box 7558 AB Staff Cindy Baxter- Gaeler PO Box 7558 AB Mailing City: Edmonton 7 Staff Tim Weis Suite 602, Street AB Staff David Dodge Suite 602, Street AB Staff Roberta Franchuk Suite 602, Street AB Staff Marc Huot Suite 602, Street AB Staff Kristi Anderson Suite 602, Street AB Staff Matt Dow Suite 602, Street AB Staff Duncan Kenyon Suite 602, Street AB Mailing City: Kenora 1 Staff Katie Laufenberg Second St ON Mailing City: Ladysmith 1 Staff Alison Bailie PO Box 1869 BC Mailing City: Nelson 3 Staff Dave Lovekin 402 Robson Street AB Staff Dan Woynillowicz 402 Robson Street AB Staff Steven Cretney 402 Robson Street BC Mailing City: Ottawa 1 Staff Nathan Lemphers 130 Albert Suite 910 ON Mailing City: Toronto 6 Staff Cherise Burda Suite 302, 720 Bathurst Street ON Staff Graham Haines Suite 302, 720 Bathurst Street ON Staff P.J. Partington Suite 302, 720 Bathurst Street ON Staff Devika Shah Suite 302, 720 Bathurst Street ON Staff Lori Johnston Suite 302, 720 Bathurst Street ON Staff Louise Gilmour Suite 302, 720 Bathurst Street ON Mailing City: Vancouver 10 Staff Claire Beckstead Suite Water Street BC Staff Matt Horne Suite Water Street BC Staff Josha MacNab Suite Water Street BC Staff Ryan Kilpatrick Suite Water Street BC Staff Lynne Whenham Suite Water Street BC Staff Penelope Comette Suite Water Street BC Staff Tom- Pierre Frappe- Seneclauze Suite Water Street BC Staff Kevin Sauvé Suite Water Street BC Staff Ellen Pond Suite Water Street - Staff Tim Shah Suite Water Street BC Mailing City: Yellowknife 1 Staff Shauna Morgan th Street NT Confidential Information - Do Not Distribute Copyright (c) salesforce.com, inc. All rights reserved.