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Kearl Oil Sands Project – Mine Development

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Kearl Oil Sands Project – Mine Development REVIEW OF COMPONENTS OF THE IMPERIAL OIL RESOURCES VENTURES LIMITED SUPPLEMENTARY INFORMATION AND RESPONSE TO THE MIKISEW CREE STATEMENT OF CONCERN REGARDING THE KEARL OIL SANDS PROJECT – MINE DEVELOPMENT Prepared for: Mikisew Cree First Nation (Mikisew Cree) Industrial Relations Council (IRC) Fort McMurray, Alberta Prepared by: Integrated Environments Ltd. In Association with: DTC Consulting October 2006 Supplementary Information Review Kearl Oil Sands Project TABLE OF CONTENTS 1. Background ..................................................................................................................2 2. Review Process.............................................................................................................3 3. Environmental Management Systems ..........................................................................4 4. Tailings Management...................................................................................................6 5. Liability and Closure Management ..............................................................................7 Integrated Environments Page 1 of 10 Supplementary Information Review Kearl Oil Sands Project 1. Background The Mikisew Cree First Nation (Mikisew Cree) has become increasingly concerned about the long-term effects of Oil Sands and other related developments in North-eastern Alberta. The Mikisew Cree have stated, and continue to state, these concerns directly to Industry and Government in private meetings, and at various regional forums. The reviews of several Oil Sands project Terms of Reference (TOR) and Environmental Impact Assessment (EIA) documents have focused on these concerns. The Mikisew Cree will continue to conduct these technical reviews in order to validate that Oil Sands Proponents’ supporting information and interpretations are reasonable and well founded. We will continue to provide comments on deficiencies and/or improvements for each regulatory application. While the above regulatory review approach is useful, the Mikisew Cree believe that there are significant concerns that are not fully addressed as part of the current review process. These relate to both project-specific and regional effects of oil sands mining and in-situ extraction on traditional ways of life and access to the land. Without a full understanding of these concerns and the consequences, the long-term impacts Oil Sands development cannot be defined in an adequate and relevant manner. Ensuring Aboriginal Standards are achieved in reclamation with the return of an acceptable and fully functional landscape is one of the cornerstones of the Mikisew Cree requirement for certainty. As currently stated in EIA applications, the Mikisew Cree believe that there is a real risk that such restoration will not occur. Equally, there is no guarantee that Oil Sands Proponents’ proposed reclamation plans will be achieved as stated. Not achieving these desired outcomes will ultimately result in environmental, cultural and social liabilities being transferred to the Mikisew Cree and future generations without proper recourse. Reclamation to the Aboriginal Standard must also be placed in a regional context that considers the cumulative effects of mining and in-situ extraction activities. Due to their nature, large oil sands mining projects, have a significant long-term impact on landscape integrity. The large-scale impacts of bitumen mining extraction are augmented by additional impacts of adjacent SAGD operations. These cumulative impacts of oil sands activities have been identified in numerous EIAs, but as of yet there is no effective management regime in place to assign responsibilities for the implementation of effective broad scale mitigation actions. The Mikisew Cree are concerned about long-term impacts to the land, air and water resulting from the cumulative effects of all Oil Sands related activities. This has not been adequately addressed to date on a project-by-project review basis, nor has government demonstrated an adequate and effective mechanism for cumulative effects management. Mikisew Cree have long indicated that a project terms of reference (TOR) is useful for all regulatory applications as a starting reference point. The continued challenge for the Mikisew Cree is to explain the First Nations’ perspective, one that stresses their key issues of concern. The Mikisew Cree wish to ensure that they fully understand the long-term Integrated Environments Page 2 of 10 Supplementary Information Review Kearl Oil Sands Project consequences of Oil Sands development and likewise wish that their concerns are also fully understood by Governments, corporations and other Albertans. The following is a response to Supplementary Information Request, subsequent to the Kearl Application and a response to the Mikisew Cree Statement of Concern. 2. Review Process The following review of the Supplementary Information Request has been prepared by Integrated Environments Ltd. (the Reviewer), under the direction of the Mikisew Cree Industry Relations Council (IRC). The comments expressed in this report are those of the Reviewer, unless otherwise denoted. We have reviewed the Supplemental Information provided by Imperial Oil Resources Ventures Limited (IOR) for the Kearl Mine Project in relation to comments on: • Environmental Management Systems, • Tailings Management, and • Liability and Closure Management The reviewer’s comments on the Kearl Oil Sands Project Application were developed based on the viewpoints and concerns being expressed by the Mikisew regarding oil sands development. In that regard IOR needs to discuss with Mikisew the appropriateness of their responses specifically as these relate to Mikisew. The reviewers note that many of the questions posed by Mikisew have not been addressed directly by IOR. The reviewers have posed these questions in an attempt to have the Mikisew concerns articulated in a fashion appropriate to IOR Corporate policies (as published) and to Alberta Environments regulatory obligations. We encourage IOR to continue a dialogue and to discuss Mikisew’s viewpoints on these issues. As the Kearl Project application relies on IOR’s initiatives and commitments we encourage Mikisew to seek IOR agreement to develop a binding commitment registry which is supported by Alberta Environment. Additionally we encourage Alberta Environment to increase transparency in the development of key policies and management strategies such as the present MLMP process. Such actions would provide further opportunities for Mikisew involvement in planning and decision making. This will assist all parties in managing projects risks and help to address everyone’s interests. Integrated Environments Page 3 of 10 Supplementary Information Review Kearl Oil Sands Project 3. Environmental Management Systems The Reviewer has examined the Supplemental Information provided to the Mikisew Cree and does not find any reference or response from Imperial Oil Resource Ventures Limited (IOR) to specific concerns raised by the Mikisew Cree regarding the proposed Environmental Management System for the Kearl Mine Project. The following documentation was reviewed: • Kearl Oil Sands Project – Mine Development. Supplemental Information • Kearl Oil Sands Project – Mine Development. Additional Supplemental Information • Kearl Oil Sands Project – Mine Development. Supplemental Information Appendices • Kearl Oil Sands Project – Mine Development. Responses to MCFN Statement of Concern In the original Statement of Concern, the Reviewer stated that…..The Environmental Management Plan does not provide details specific to the Kearl Oil Sands Project and is not consistent with ISO 14001 standards. The following information was requested from IOR: • Details specific to the Kearl Oils Sands Project – the EIA refers to IOR’s general safety, health and environmental management but does not provide the Mikisew Cree any assurance that specific socio-environmental effects arising from the project will be managed in such as way as to minimize impacts to First Nations lands and peoples. More specific details relating to the Project description and its environmental aspects as described in the EIA are required; • How the EMS/EMP is integrated with the environmental impact assessment and associated environmental and social risks. Little or no reference in the EIA is provided as to how this will be done; • Provide a conceptual schedule for implementation, including timelines; • Provide an organizational framework for the EMS, including responsibilities; • Identify socio-environmental risks and priorities arising from the EIA and identify options as to how they will be addressed; • Identify how socio-environmental risks are to be addressed by project phase – e.g. there is no reference as to how environmental management will be addressed in construction versus operations; • Provide budgets for the above. No written response to the above was provided to the Mikisew. Integrated Environments Page 4 of 10 Supplementary Information Review Kearl Oil Sands Project Forward Looking Recommendations The Reviewer recognizes that environmental management is a process carried out throughout the Project life cycle and that complete details on the structure and organization of the Project EMS may not be completely available at the time of Application. However at this time, IOR should disclose to stakeholders their intent toward EMS implementation and provide a framework approach as to how this will be specifically undertaken for the Kearl Mine
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