May 22, 2013

Honourable Diana McQueen Minister Office of the Minister Environment and Sustainable Resource Development 204 Legislature Building 10800 - 97 Avenue Edmonton, AB T5K 2B6

Re: Fort Air Partnership input to the establishment of an arms-length Provincial Monitoring Agency

Dear Honourable Diana McQueen,

The Fort Air Partnership (FAP) is aware that Environment and Sustainable Resource Development (ESRD) is currently in the process of establishing an arms-length Monitoring Agency for the province. The FAP Board of Directors recently met to discuss how best we can support the development of this agency, ensuring that the many strengths of the FAP airshed model are not lost.

Fort Air Partnership is an independent, non-profit society led by a Board of Directors with representation from the public, government and industry. Our official name as registered with Alberta Registries is the Fort Saskatchewan Regional Air Monitoring Society. FAP’s vision is for the public, industry and government to have a clear, shared understanding of ambient air quality in the region. Our mission – to monitor and report credible and comprehensive ambient air quality information – guides our monitoring decisions. FAP believes that our mission and objectives, focused on ambient air quality monitoring and reporting, align very well with the current provincial objectives for regional effects monitoring.

FAP currently monitors a 4,500 square kilometer airshed north-east of Edmonton on behalf of industry, Alberta Environment and Sustainable Resource Development and Environment Canada. The FAP airshed is one of the most heavily monitored areas in Alberta.

P.O. B OX 3 0 5 1 F O R T S ASKATCHEWAN , A LBERTA T 8 L 2 T 1

The Fort Air Partnership model is very successful primarily because:

1. We receive sustainable, committed funding year over year. 2. We have a collaborative multi-stakeholder engagement and consensus based decision- making process in place. 3. We have made a major investment in educating and building positive relationships with stakeholders including the general public. 4. We have a scientific advisory committee composed of highly skilled and knowledgeable people. 5. We add value to airshed management because we are place-based.

Sustainable committed funding refers to the following:

- Fort Air Partnership is funded by the Northeast Capital Industrial Association (NCIA), Alberta Environment and Sustainable Resource Development and Alberta’s Industrial Heartland Association (AIHA). - NCIA provides the majority of FAP’s funding. This funding is based on a funding formula that has ensured sustainable and committed funding for air quality monitoring in the FAP airshed for the past 10 years. - FAP acknowledges that air quality monitoring needs to be funded equitably through a shared responsibility approach, and is supportive of a funding model that will enable this. However, it is critical to the integrity and credibility of monitoring programs that the funding model implemented through the Monitoring Agency avoids major annual government budget fluctuations and be sustainable year after year. - It is also important to note the volunteer support of an organization such as FAP. This support comes from many levels within the organization, including the Board of Directors, the Executive Committee, the Technical Working Group, the Communications Advisory Committee and several ad-hoc committees that are formed on a project specific basis. All stakeholder groups provide this support, knowledge and expertise, assisting with numerous tasks and projects. These in-kind contributions reduce the financial burden of running the airshed and FAP feels it is important to maintain this volunteer support.

The FAP model of a collaborative multi-stakeholder approach using a consensus based decision making process is one of the keystones of FAPs success. FAP has learned that the following aspects are the foundation for successful management and operation of a regional air monitoring network:

- Involving regional stakeholders who provide local knowledge and interpretive capabilities. This is an essential asset and this type of involvement should be retained. - FAP has invested a great deal of effort in relationship building with stakeholders in the airshed, which is another aspect of the FAP model that should be incorporated into any new system. Some examples of this include: o FAP has built strong relationships with provincial government departments, especially ESRD, as well as numerous municipal governments in the FAP region, including Alberta’s Industrial Heartland Association, City, County, Town and Village Councils throughout the airshed. We currently have an elected

2

representative from the Town of Bruderheim and both an administrative and elected AIHA representative on the FAP Board of Directors. We also meet on a regular basis with all Councils in the airshed. o FAP has built a strong relationship with public in the airshed; this is reflected in the fact that we have 8 public members currently participating on our Board of Directors. Another reason this relationship has become stronger over the past 10 years is the effort we have put into education and outreach. Examples include the curriculum package FAP developed for elementary schools in the airshed, and the air quality fact sheets package we developed in collaboration with ESRD that has subsequently been used by other agencies and airsheds throughout the province. FAP also communicates on a regular basis with the local media, and provides news releases and advertorials on subjects of interest to the public. Our regular communications links such as newsletters, website and annual reporting are also extensive. Providing the opportunity for local involvement and ensuring responsiveness to local issues has enabled us to build our credibility over the past several years. o Industry members are also very supportive of FAP and see participation in our organization as a benefit to them. Over the years, industry involvement and support has increased as companies realize the credibility of supporting and contributing to FAP, including several who are not required to conduct ambient air quality monitoring, or have assets on the ground today. o FAP also works in partnership with many other organizations including Alberta Environment and Sustainable Resource Development, Alberta’s Industrial Heartland Association, Life in the Heartland and the Northeast Capital Industrial Association. These partnerships enable all of the organizations involved to work together to meet common goals. - FAP has a very capable scientific/technical advisory committee consisting of public, industry and government members with many areas of expertise, including engineering, atmospheric science, air quality monitoring and environmental management. This committee ensures that the monitoring network meets FAPs objectives and produces high quality, credible data. This committee also guided the network assessment completed in 2012 that is enabling FAP to evolve from a fenceline monitoring network to a regional monitoring network. FAP recommends that the Agency consider implementing regional scientific advisory teams such as this across the province that would report to the provincial scientific advisory team.

There is also a high degree of added value in having a localized airshed management model in place. There are many aspects of FAPs learning’s in this regard that could be considered when implementing the new monitoring system:

- A place-based management system has contributed to FAP’s success. It allows for local management of on-the-ground contractors who operate the monitoring network. This continuous oversight ensures credible, quality assured data is generated on an ongoing basis. - A place-based management system also enables continuous improvement by assessing the network against monitoring objectives. An example of this is the network assessment FAP recently conducted. It is assisting us in the development of a long-term monitoring plan to ensure we meet regional monitoring objectives.

3

- A Board of Directors consisting of local stakeholders who have a vested interest in the success of the airshed has also contributed to FAP’s success. This Board has evolved over the past 10 years from an operationally focused Board to a governance Board dealing with policy development and oversight. It is essential that this local support be continued as part of the new system.

We believe the FAP model has a proven track record as a positive, regional monitoring and reporting organizational structure. Many aspects of this model could be used for regional purposes going forward. This could be easily arranged through a service agreement between each regional entity and the Agency. Again, FAP stresses the importance of incorporating the value-added activities of the current FAP model (e.g. local management of operations, stakeholder education, communications and engagement) over and above the operation of monitoring stations.

Although FAP understands these comments are unsolicited feedback, we strongly believe that our success is based on the strengths of our model. FAP sincerely appreciates the opportunity to provide input in guiding the development of the new provincial monitoring system, and offers to provide support to, and have continued discussions with, the Monitoring Agency. FAP also looks forward to meeting with Ernie Hui at our Board of Directors meeting on June 10 to discuss the contents of this letter in person.

As mentioned, we believe the FAP model is highly regarded in the region. To validate this opinion, we are asking our stakeholders to indicate in writing their view of FAP and its benefits to them. These documents will be provided to you in the near future.

Please contact me if you have any questions or would like to discuss further.

Sincerely,

Keith Purves FAP Board Chair 780-998-3921 cc. Ernie Hui, Monitoring Agency CEO Honourable , Minister of Energy Jacquie Fenske, MLA for Fort Saskatchewan-Vegreville , MLA for Strathcona-Sherwood Park Honourable Jeff Johnson, Minister of Education and MLA Athabasca-Sturgeon-Redwater Norman MacLeod, Clean Air Strategic Alliance

4