Death by a

ThousandIMPACTS OF IN SITU OIL SANDS DEVELOPMENTCuts ON ALBERTA’S BOREAL FOREST

RICHARD SCHNEIDER • SIMON DYER August 2006

Oil SANDSFever SERIES Death by a Thousand Cuts Impacts of In Situ Oil Sands Development on Alberta’s Boreal Forest

Richard Schneider • Simon Dyer

August 2006

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS i Death by a Thousand Cuts ii About the Canadian Parks and Wilderness Society

The Canadian Parks and Wilderness communities, and the economy. Society (CPAWS) is Canada’s grassroots We have approximately 3,000 voice for wilderness. The Edmonton members led by a volunteer board Chapter works to maintain biodiversity of directors. More information about and wilderness in Alberta through the CPAWS Edmonton is available at establishment of protected areas and the www.cpaws-edmonton.org or by implementation of industrial practices contacting info @cpaws-edmonton.org. that are sustainable for nature,

About The Pembina Institute

The Pembina Institute creates research leadership and education on sustainable energy solutions through climate change, energy issues, green research, education, advocacy and economics, energy efficiency and consulting. It promotes environmental, conservation, renewable energy and social and economic sustainability in the environmental governance. More public interest by developing practical information about the Pembina Institute solutions for communities, individuals, is available at www.pembina.org or by governments and businesses. The contacting info @pembina.org Pembina Institute provides policy

ii DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Death by a Thousand Cuts iii Acknowledgements

We thank the Hewlett Foundation and Cover Photo: OPTI-Nexen plant the Richard Ivey Foundation for their south of Fort McMurray photo support of this report. We also thank by David Dodge © 2006 Dan Woynillowicz, Chris Severson- The Pembina Institute and inset Baker, David Dodge, Harry Stelfox, photo by © 2005 Google Earth, Wally Friesen, and Terry Osko for their © 2006 Digital Globe. insightful feedback and comments on Back Cover: Both satellite photos the report and Matthew Smith for his © TerraServer.com assistance with GIS. © 2006 The Pembina Institute and Death by a Thousand Cuts: Impacts of in the Canadian Parks and Wilderness situ oil sands development on Alberta’s Society, Edmonton boreal forest ISBN 0-921719-83-3 1st Edition, published August 2006 1st Edition v1.0-06-07-18 Printed in Canada The Pembina Institute Authors: Richard Schneider, Box 7558 Simon Dyer Drayton Valley, Alberta T7A 1S7 Editor: Randee Holmes Phone: 780.542.6272 Production Manager: David Dodge E-mail: piad @pembina.org Design and Layout: CPAWS Edmonton J&W Communications P.O. Box 52031 Illustrations: Richard Schneider, Edmonton, Alberta, T6G 2T5 J&W Communications Phone: 780.432.0967 and as credited E-mail: info @cpaws-edmonton.org Photography: Richard Schneider, Additional copies of this publication David Dodge may be downloaded from www.pembina.org, www.oilsandswatch.org or www.cpaws-edmonton.org.

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS iii Death by a Thousand Cuts iv Environmental Statement

Using FSC-certified paper is an This book is printed on Forest XX% easy and highly visible way to show Stewardship Council (FSC) environmental leadership. The FSC certified paper that is produced label guarantees that the paper we’re with the world’s highest standards using has been responsibly harvested. for environmentally and socially Cert no. SW-COC-1383 No clear cutting on stream banks. responsible forestry practices. No cutting in sensitive areas. And This book is printed on chlorine-free this is just the beginning. Go to paper made from 25 percent post- fsccanada.org for details. FSC is the consumer fibre. In choosing this only program endorsed by WWF paper, The Canadian Parks and Canada, National Aboriginal Forestry Wilderness Society (CPAWS) Association, ForestEthics, Greenpeace and The Pembina Institute saved and the Sierra Club of Canada. 4,168 litres of water, conserved This book was printed at 1.1 trees and diverted 43 kilograms grafikom.Speedfast, the first of waste from Alberta landfills. FSC printing company in Alberta. The Canadian Parks and Wilderness grafikom.Speedfast has been and Society (CPAWS) and The Pembina continues to be thoroughly audited Institute recognizes the importance by SmartWood, a program of the of sustainability. Rainforest Alliance.

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iv DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Death by a Thousand Cuts v Table of Contents

Executive Summary ...... vii

Summary of Recommendations ...... x

Introduction ...... 1

1 Case Study: The OPTI-Nexen Long Lake Project ...... 3 1.1 Overview ...... 3 1.2 Exploration ...... 4 1.3 Production ...... 6 1.4 Processing ...... 7

2 Regional Environmental Impacts ...... 9 2.1 Cumulative Impacts ...... 9 2.2 Environmental Effects ...... 12 2.2.1 Caribou ...... 14 2.2.2 Furbearers ...... 15 2.2.3 Forest Birds ...... 16 2.2.4 Other Environmental Impacts ...... 17

3 Solutions ...... 19 3.1 Policies and Planning ...... 19 3.1.1 Protected Areas ...... 20 3.1.2 Protection of Private Lands ...... 21 3.1.3 Regional Planning ...... 22 3.1.4 Cumulative Effects Thresholds ...... 25 3.1.5 Coordination of Operational Planning ...... 26 3.1.6 Requirements for Lease Evaluation ...... 27 3.2 Industrial Best Practices ...... 27 3.2.1 Seismic Exploration ...... 28 3.2.2 Bitumen Extraction and Processing: Alternatives to SAGD . .28 3.2.3 Well Pad Construction and Reforestation ...... 29 3.2.4 Integration with Forestry Operations ...... 30 3.2.5 Footprint Restoration ...... 31 3.2.6 Monitoring of Biodiversity and Disturbances ...... 31

4 Conclusion ...... 33

5 Endnotes ...... 35

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS v Death by a Thousand Cuts vi About the Authors

Richard Schneider Simon Dyer Dr. Richard Simon Dyer is a Senior Policy Analyst Schneider with the Pembina Institute. Simon is a has been member of Pembina’s Energy Watch with CPAWS team, where his research focuses on the Edmonton environmental implications of oil sands since 1993 and development. Simon is a biologist by currently serves training and has worked on land use as Conservation issues in Alberta’s boreal forest since Director for 1999. Simon represents the Pembina the chapter, Institute on the primarily Sustainable overseeing the Ecosystems chapter’s boreal Working program. Group of the Richard obtained a degree in veterinary Cumulative medicine from the University of Environmental Saskatchewan in 1985 and a Ph.D. Management in wildlife epidemiology from the Association University of Guelph. He then (CEMA). completed an NSERC postdoctoral Simon holds fellowship at the University of Alberta, a Master of studying the relationship between Science in wolves, bison, and disease in northern Environmental

Canada. Richard has been actively Biology PHOTOS: DAVID DODGE, involved in several landscape-level forest and Ecology THE PEMBINA INSTITUTE management initiatives in Alberta and from the University wrote the book Alternative Futures: of Alberta, and a Master of Arts in Alberta’s Boreal Forest at the Crossroads Natural Sciences from the University as well as numerous influential papers of Cambridge. on the management of Alberta’s forests.

vi DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Death by a Thousand Cuts vii Executive Summary

This report examines the land impacts of in situ development of deep oil sands that has the potential to occur over a region 50 times larger than the oil sands mining area north of Fort McMurray. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

Currently, most Alberta oil sands recovery is less destructive than production takes place in open pit open pit mining, it is significantly mines. It is these shovel and truck more damaging than conventional operations that most people have come oil extraction methods. Moreover, to associate with oil sands development. if in situ recovery of all of Alberta’s However, only a small fraction of the underground reserves is allowed to available oil sands deposits in Alberta are proceed, the area impacted will be close enough to the surface to be mined. vast – approximately 13.8 million The bulk of the established reserves hectares (ha), or 50 times the area (81%) are deep below the surface of the mining zone. This equals and must be extracted using in situ 21% of Alberta, or a land area the (in-place) techniques. Although in situ size of Florida.

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS vii Death by a Thousand Cuts

Executive Summary (CONTINUED)

The primary in situ extraction technique a conservative estimate and does not is called Steam Assisted Gravity Drainage take into account transient disturbances (SAGD). It involves the use of high- such as seismic exploration, forest pressure steam to liquify the tar-like oil harvesting, or wildfire. Furthermore, sands deposits so that they can be piped new leases are continually being awarded to the surface. by Alberta’s Department of Energy. The In this report, the 10,600 ha OPTI- implications are startling. By even the Nexen Long Lake project, now under most conservative estimate, there will be development, is used as a case study of a more long-term deforestation from state-of-the-art SAGD operation. A total SAGD development than if the entire of 8.3% of the Long Lake lease will be mineable oilsands region is completely cleared for SAGD infrastructure, cleared. The ecological effects will be including a 99 ha central facility, 234 many times greater still, because the exploration wells, 288 production wells, SAGD disturbances will be dispersed 89 km of access roads, and an extensive across a vast region. aboveground pipeline collection system. The boreal forest in which the SAGD Once construction is completed, developments are taking place is home approximately 80% of the 10,600 ha to many wildlife species known to be land parcel will be within 250 m of an sensitive to industrial disturbances. For industrial feature. Approximately 24,000 these species, useable habitat within a m3 of water will be needed each day for SAGD development area is reduced to steam production and processing; small scattered islands. Once a threshold although 90% will be recycled, the is reached where the remnant habitat remainder will be lost through disposal patches are too small and scattered to in deep wells. The anticipated lifespan maintain a breeding population, the of the project is 40 years. local population is extinguished. As of July 2005, the total area of land Multiply this effect by all projected leased for in situ development in Alberta SAGD developments and the result is a was 3.6 million ha. If all these leases, serious decline in regional biodiversity. most of which have yet to be developed, Although precisely defined ecological are subjected to the same industrial thresholds have not been defined, footprint as the Long Lake project, then evidence is steadily mounting that 296,000 ha of forest will be cleared for ecological tipping points for many SAGD infrastructure and over 30,000 species are already being exceeded at km of access roads will be built. This is current levels of industrial development

viii DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Death by a Thousand Cuts

Executive Summary (CONTINUED) in northern Alberta. The impacts of conservation offset measures, such as the SAGD development, which are much establishment of wildlife reserves where more intense and prolonged than those industrial development is not permitted, resulting from conventional forms of need to be implemented. In addition, petroleum development, will be additive a cap must be placed on cumulative to existing impacts of current and past industrial impacts so that basic oil extraction. Therefore, ecological ecological function is maintained on thresholds will be greatly exceeded in the industrial land base. Examples from the future under planned development elsewhere in Canada, such as the trajectories. In this report we present Muskwa-Kechika management plan evidence from studies of three wildlife in northern British Columbia and the groups – caribou, furbearers (e.g., lynx, draft Dehcho management plan in the marten) and forest birds – within which North West Territories, demonstrate some species are at risk of extirpation how regional planning, protected from oil sands development. areas, and limits on cumulative Given the severe and unavoidable impacts can be incorporated into impacts anticipated from widespread management planning. SAGD development, extra effort needs If there is to be any hope of balancing to be placed on finding alternatives to in ecological and economic objectives in situ extraction. Regardless of the the oil sands region then new approach used, the overall infrastructure approaches to land management, footprint and related impacts of in situ supported by appropriate policy and developments must be significantly planning frameworks, will need to be reduced. Several examples of industrial implemented. There is an urgent need best practices are reviewed in this report, for the development of a regional including reduced impact seismic strategic plan that includes long-term exploration, integrated operational management objectives and a planning, reduced impact well pad process for achieving these objectives. construction, and footprint restoration. The anticipated impacts associated Although mitigation and reclamation with unconstrained in situ oil sands efforts will be beneficial, it is becoming development are so great that no futher increasingly apparent that, even with oil sands leases should be awarded or state-of-the-art practices, the cumulative projects approved until a management ecological impacts of in situ develop- plan is in place to protect the regional ment will be devastating. Therefore, environment.

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS ix Death by a Thousand Cuts x Summary of Recommendations

1. Alberta Sustainable Resource precautionary standards for wildlife Development should develop a habitat to ensure that ecological regional plan to protect the boreal thresholds are not exceeded and forest of northeastern Alberta with the environmental values are protected. following elements: 5. Alberta Sustainable Resource • A clear expression of public values, Development should establish a expressed as long-term management Land Management Planning objectives for the region; Standard, modeled on the Forest • Land use designations and Management Planning Standard, to quantitative management targets guide the development of operating that direct the timing, location, and plans for all resource companies intensity of development at the working in a given management area. regional scale, to be implemented The standard would compel companies through the tenure allocation process to work together to devise workable and regulatory mechanisms; and integrated solutions for achieving shared landscape-scale land manage- • The establishment of a ment objectives. A single government comprehensive environmental agency dedicated to integrated land baseline characterizing northeastern management should be established Alberta prior to industrial to provide oversight and facilitation development (i.e., circa 1950), to of this process. A key role for the serve as the reference against which government is to ensure that the the impacts of future developments solutions companies devise are are compared. equitable, and consistent with 2. Alberta Energy should suspend new regional land management and tenure allocations and Alberta conservation objectives. Environment should suspend new 6. All government departments project approvals until the regional should establish minimum standards, plan is in place. reflecting industrial “best practices,” 3. Alberta Sustainable Resource that companies must employ to Development should establish new minimize damage to the boreal forest: interconnected protected areas • Implement alternatives to SAGD that representative of the boreal region, as a are less environmentally destructive conservation offset measure. (less water, less energy, less land 4. Alberta Sustainable Resource disturbance, less duration) as rapidly Development should establish as possible; quantitative limits on cumulative • Conduct seismic programs in such a industrial disturbances and way that the lines are visibly

x DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Death by a Thousand Cuts Summary of Recommendations

reintegrated into the forest within • Limit cumulative linear disturbances five years. This can be achieved by reusing or reforesting existing by cutting narrow lines (< 2.5 m), disturbances before additional leaving soil and root systems disturbances are added to the intact, and including barriers system; and to motorized access; • Incorporate monitoring programs like • Integrate planning with forestry the Alberta Biodiversity Monitoring companies operating on the same Program into operations and track and land base, including harmonized report on the cumulative industrial road construction; disturbance related to projects.

The boreal forest of northern Alberta will be dramatically affected if plans to exploit oil sands on 138,000 km2 are carried out. SOURCE: DAVID DODGE, THE PEMBINA INSTITUTE

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS xi The OPTI-Nexen Long Lake project includes an upgrader to convert bitumen into synthetic crude oil. SOURCE: DAVID DODGE, PEMBINA INSTITUTE Death by a Thousand Cuts Introduction

Canada’s boreal region contains one- What is not well known is that only a quarter of the world’s remaining original fraction of the total available oil sands forests. It is home to a rich array of deposits are close enough to the surface wildlife including migratory songbirds, to be mined. The bulk of the waterfowl, bears, wolves and the world’s established reserves (81%) must be largest caribou herds. Canada’s boreal is extracted using in situ (in place) a major part of the global boreal region techniques.2 Although in situ recovery that encircles the Earth’s northern hemisphere, storing more freshwater in its wetlands and lakes and more carbon in its trees, soil, and peat than anywhere else on the planet. The Canadian boreal forest is also the location of one of the world’s largest deposits of oil – Alberta’s oil sands. With conventional oil reserves in North America in steady decline, Alberta’s oil sands have begun to attract significant attention, both locally and internationally. Currently, the majority of oil sands production comes from open pit mining facilities, and it is these shovel and truck operations that most people have come to associate with oil sands development. The mining zone currently extends across approximately 3,300 km2 of northern Alberta1 and, when fully developed, will likely qualify as the world’s largest open pit mining complex. FIGURE 1: Map of Alberta’s oilsands

SOURCE: RICK SCHNEIDER, CANADIAN PARKS AND WILDERNESS SOCIETY

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 1 Death by a Thousand Cuts Introduction is less destructive than mining, it is McMurray. The intent is to provide a significantly more damaging than the detailed description of a SAGD project conventional oil operations to which it at ground level, using a real-world is often compared. Moreover, if all example that incorporates a number of available deposits are to be extracted, new features designed to minimize the potential area impacted will be environmental impacts. We then vast – approximately 138,000 km2 provide projections of anticipated (13.8 million hectares), which is 50 regional environmental impacts by times larger than the area of the mining extrapolating the ecological footprint of zone.3 This is equivalent to 21% of individual projects, such as the Long Alberta, or a land area the size of Lake project, to the entire oil sands Florida (Fig. 1). region. As with many oil sector In this report we focus on Steam activities, it is the regional cumulative Assisted Gravity Drainage (SAGD), the impact of multiple developments, not primary technique for in situ oil sands the impact at any specific site, that is of recovery. We provide a description of greatest concern. Finally, we discuss the process through a case study of the practices and planning options for OPTI-Nexen Long Lake project, now maintaining the ecological health of the under development near Fort oil sands region.

2 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE 1 Case Study: The OPTI-Nexen Long Lake Project

1.1 Overview

FIGURE 2: Schematic of a SAGD production system. SOURCE: J&W COMMUNICATIONS, THE PEMBINA INSTITUTE

The type of oil found in oil sands steam, which rises to form a high- deposits, termed bitumen, is heavy, temperature steam chamber above the viscous and not easily extracted. In the well. Within the steam chamber the SAGD process, two horizontal wells heated bitumen becomes less viscous separated by a small vertical distance are and flows by gravity to the lower well placed near the bottom of the oil where it is collected, along with the formation (Fig. 2). The top horizontal condensed water. well is used to inject high-pressure

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 3 1 Case Study: The OPTI-Nexen Long Lake Project

OPTI Canada and Nexen Inc. are joint- venture partners developing the $3.5 billion Long Lake SAGD project located on a 10,600 ha site 40 km southeast of Fort McMurray (Fig. 3).4 Approval for the project was granted in 2003 and production is slated to begin in late FIGURE 3: Map of Long Lake 2006. The SAGD operation will be SAGD project. coupled with an on-site upgrader and SOURCE: OPTI/NEXEN, EIA cogeneration facilities and is anticipated to produce 60,000 barrels of synthetic crude oil per day. Over the 40-year life of the project, approximately 288 well pairs will be drilled from up to 48 well pads.5 It is expected that at least 50% of the original bitumen in place within the project area will be recovered.6

1.2 Exploration

Outside of the surface mineable region the geological layer comprising the oil sands is generally less than 30 m thick.7 Therefore, successful implementation of the SAGD process demands precise placement of the horizontal wells. This in turn requires detailed information about the location and extent of the deposits, gathered through extensive exploration activities. The initial phase of exploration is focused on assessing the commercial viability of the deposit and delimiting its extent. This is accomplished by drilling a systematic grid of core holes and conducting two-dimensional (2D)

FIGURE 4: Map of core holes and 2 dimensional seismic lines. SOURCE: OPTI APPLICATION, SECTION C, FIG. 1.6

4 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Case Study: The OPTI-Nexen Long Lake Project 1

FIGURE 5: Satellite photo of core holes and access roads on Long Lake site. SOURCE: GOOGLE EARTH © 2005 GOOGLE, IMAGE © 2006 DIGITAL GLOBE

seismic exploration (Fig. 4). As the sequentially exploded the reflected name suggests, core holes are used to sound waves are recorded at the surface retrieve core samples of the subsurface using portable recording equipment. geology. These core holes are generally Until a few years ago, seismic lines drilled using conventional drilling were typically 6-8 m in width.9 practices that include developing access The average width in the Long Lake routes for heavy machinery and clearing project will be 4 m.10 between 0.5 and 1 hectare of forest Conventional 2D seismic is sufficient (Fig. 5). A total of 234 core holes are for coarse delineation of deposits, but 8 planned for the Long Lake site. not for the accurate placement of Seismic exploration involves the horizontal wells. Therefore, prior to production and analysis of underground production additional seismic sound waves to generate a computer exploration is conducted to produce model of subsurface geological detailed 3D models of the deposit. structures. In forested areas a corridor is To produce these detailed models usually first cleared for access and then intensive 3D seismic techniques must truck-mounted drilling equipment is be employed where lines are laid out used to drill a series of shot holes at in a tight cross-hatch pattern (Fig. 6). defined locations. Dynamite charges are In some cases seismic programs are placed in the shot holes and then repeated, in so-called 4D seismic, detonated to generate seismic sound to monitor changes in the deposit waves. As the dynamite charges are over time.11

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 5 1 Case Study: The OPTI-Nexen Long Lake Project

After exploration activities have been completed the core holes and seismic lines are reclaimed. On the Long Lake site initial reclamation efforts have included backfilling of holes, scarific- ation of well pads, and redistribution of debris piles across the area.12 A grass seed mixture including fowl bluegrass, sheep fescue, Canada wildrye, awned wheatgrass and tufted hairgrass is being planted to minimize erosion. Other efforts have included the decommis- sioning and reclamation of access roads. FIGURE 6: Aerial photo of 3D seismic on Long Lake site, with 60 m line spacing. SOURCE: DAVID DODGE, THE PEMBINA INSTITUTE 1.3 Production

The Long Lake project is designed to will continually be added as older wells produce 9,600 m3/day (approximately cease production. It is anticipated that 60,000 barrels/day) of bitumen over 48 well pads will be required in total. 13 FIGURE 7: a period of 35-40 years. Because Plans call for the reclamation of Horizontal well. individual well pads only have a individual well pads immediately after SOURCE: PETRO-CANADA projected life of up to 12 years before they cease operating. The reclamation local reserves are exhausted, new pads of such long-term disturbed areas will include the replacement of stockpiled reclamation material followed by the replanting of appropriate tree and shrub species.14 Well pads will be 3.8 ha in peatlands and 4.4 ha in uplands (the larger size in upland sites is needed to accommodate soil storage).15 Each well pad will host five paired wells (Fig. 7). Approximately 500 m3 of drilling waste will be generated from the drilling of each well pair.16 This drilling waste will be disposed of using the mix, bury and cover method,17 or shipped to a landfill following government guidelines. Well pads will be bermed to contain accidental spills.

6 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Case Study: The OPTI-Nexen Long Lake Project 1

There will be an above ground interconnecting pipeline system between the well pads and the central facility including a steam supply line, produced bitumen/water line, and a produced gas FIGURE 8: Pipeline and steam line (Fig. 8). There will also gathering be overhead power lines to each pad, an system. underground pipeline for lift gas (see SOURCE: PETRO-CANADA below), and an all-weather service road. The proposed access routes will follow existing cleared rights-of-way wherever possible; however, about 70% of all roads and corridors will require new Steam for the project will be produced 18 clearing. A total of 31 road and in the central facility (described below). pipeline crossings of watercourses are Approximately 24,000 m3/d of water 19 proposed for the project. will be needed to recover the projected The project design includes the use 9,600 m3/d of oil (a 2.5:1 ratio).21 Most of artificial gas lift to aid production.20 of the process water will be recycled, but Up to 5 m3 of natural gas per m3 of about 10% will be disposed of through produced fluids will be injected into deep well injection into a formation of the bottom of the production well. The water-bearing sand below the bitumen addition of the gas reduces the density resource. This disposal is necessary to of the column of water-bitumen avoid accumulating too high a mineral sufficiently to allow it to flow to the content in the water for steam surface. Lift gas will be returned to the generation. The disposal wells will be central facilities with the produced connected to the central plant by an fluids, treated, and then utilized as fuel 8.7 km underground pipeline. Make-up in the project facilities. Lift gas for the water will be drawn from new wells project will be supplied through a new located on the lease.22 A 24.8 km 10.2 km pipeline linked to the underground pipeline will connect the TransCanada pipeline system. water wells to the central plant. 1.4 Processing

The Long Lake project will include a 400 MW of electricity, of which large (98 ha) central processing facility approximately 40 MW will be used by where steam for the wells will be project facilities and the balance sold produced and where processing of into the wholesale Alberta grid.23 bitumen will occur (Figs. 9-10). The market for crude bitumen is very Plans call for the construction limited, so normally it is diluted and of a cogeneration plant that will transported by pipeline to refineries for produce both steam and electricity. upgrading to synthetic crude. Dilution The cogeneration plan will produce

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 7 1 Case Study: The OPTI-Nexen Long Lake Project

with lighter petroleum products is hazardous slag, formed from minerals necessary to reduce the viscosity of the and metals in the feed, and sulphur.25 bitumen enough that it will flow in a Subsequent to the construction of the pipeline. The Long Lake project will gasification facilities, approximately initially follow this approach, bringing 50% of the project’s fuel requirements, diluent in via a 5.8 km Enbridge including operation of the cogeneration 24 pipeline. However, the central plant, will be provided by synthetic gas. processing facility will eventually Natural gas from the TransCanada include an upgrader that will produce pipeline will provide the balance of synthetic crude oil on-site (Fig. 11). the fuel requirements. Excluding the The central facility will also include cogeneration plant, only about 11% FIGURE 9: Long Lake a gasification facility that will use by- of the project’s fuel requirements will ground view. products of the upgrading process to come from off-site natural gas.26 SOURCE: NEXEN produce sweet synthetic gas for use in All SAGD produced gas will be project facilities. By-products of the recovered, collected and combined with gasification process include a non- upgrader produced gas for treatment. Treatment involves amine sweetening followed by glycol dehydration to generate dry sweet fuel gas.27 This gas will be used in project heaters and steam generators to reduce natural gas requirements. Hydrogen sulphide will be removed from the gas and will be recovered and sold. No SAGD gas will be flared under normal operation.28

FIGURE 10: Land clearing associated with the OPTI-Nexen central processing facility. SOURCE: GOOGLE EARTH © 2005 GOOGLE, IMAGE © 2006 DIGITAL GLOBE FIGURE 11: Hydrocracker component of the Long Lake upgrading facility SOURCE: NEXEN

8 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE 2 Regional Environmental Impacts 2.1 Cumulative Impacts

The Energy and Utilities Board Department of Energy issues more leases The central estimates that 142 billion barrels of through its land sales process, with no facility of the OPTI-Nexen bitumen can be recovered using current consideration of the possibility of staged Long Lake 29 in situ technology. The total volume development or the preservation of SAGD project. of bitumen in place is over ten times regions with high conservation value. SOURCE: DAVID DODGE, this amount; therefore, it is anticipated While individual projects do undergo THE PEMBINA INSTITUTE that established reserves will grow environmental impact assessments even larger as technology advances.30 (EIAs), projects are permitted to Moreover, only 1.0% of the 142 billion proceed if they meet standard industry barrels of established reserves have been practices, and no projects have been recovered to date. This means that substantially modified to reflect projects like Long Lake are just the conservation concerns. tip of the oil sands iceberg. To gain a realistic appreciation of There is no terrestrial cumulative the scope and magnitude of future impacts framework to guide oil sands in situ development we projected the development. Instead, the process is disturbance footprint that will result driven by geology and the price of oil. from the development of oil sands When the price of oil is high, the leases that have already been awarded.

THE PEMBINA INSTITUTE DEATH BY A THOUSAND CUTS 9 2 Regional Environmental Impacts

BOX 1. SUMMARY OF PROJECT As the basis for our projections we used INFRASTRUCTURE 34 Long Lake as a template of a state-of- the-art SAGD project, primarily because Main access road (7.9 km) extensive data and satellite photography Other access roads (81 km) Seismic lines (total km unknown) were available. We quantified the various Core holes (164 ha) disturbances associated with the Long Well pads and infrastructure (457 ha) Lake project as described in the project’s Gas supply line (10.2 km) EIA and then assumed that other Oil pipeline (5.8 km) existing leases would be subjected to Power line (5.8 km) Water supply and disposal wells (31 ha) similar types and amounts of Central facility (99 ha) disturbance. Total = 884 ha of disturbance The Long Lake Project lease area is approximately 10,600 ha in size.31 BOX 2. SUMMARY OF CENTRAL According to the EIA, the well pads, FACILITY COMPONENTS roads, pipelines, central facility, initial seismic exploration, and other Fired steam generators Bitumen/water separation vessels miscellaneous features will result in the Bitumen upgrading facilities long-term clearing of 884 ha of land, Power and steam cogeneration representing 8.3% of the project site Water recycling and treatment facilities (Boxes 1 and 2).32 Of the total Gasification facilities disturbance, 96% (846 ha) will occur Desulphurization facilities Utility systems; office in previously undisturbed forests and Produced and by-product gas handling peatlands. A review of the EIAs of other Diluent and product storage SAGD projects indicates that this level Spent lime disposal of disturbance is typical of such Reclamation material storage developments.33

The actual long-term impact will be Although 884 ha, or 8.3% of the project significantly greater than our projections site, may not seem like an excessive because new leases continue to be amount of disturbance, there are two granted, now at a record pace. Even characteristics of the disturbances that when underestimated, the initial results are cause for significant concern: First, demonstrate that the boreal forest will with the exception of the central facility, be subjected to unprecedented levels the disturbances are widely distributed of disturbance. across the project area. Based on the EIA

BOX 3. SUMMARY OF PROJECTED IN SITU DISTURBANCES

(see text for explanation) Land clearing per lease 8.3% Density of roads, pipelines, and power lines within leases 3.2 km/km2 Total in-situ lease area (2005) 3,568,000 ha Total projected area cleared 296,000 ha Total projected roads 30,000 km

10 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Regional Environmental Impacts 2

data,35 on the Long Lake site the density of roads, pipelines, and power lines 2 (seismic excluded) will be 3.2 km/km . FIGURE 12: Considering that the ecological effect SAGD disturbance of each disturbance extends out into template modeled on the surrounding forest, the majority the Long Lake project. of the forest will be impacted SOURCE: THE PEMBINA INSTITUTE (see Environmental Effects, next page). The other concerning characteristic of this type of disturbance is its duration. Not only are the disturbances at high FIGURE 13: density and widely distributed, but most Projected SAGD will persist on the landscape for decades. disturbance footprint at medium scale This is in stark contrast to natural (approximately 20% disturbances, such as fire, which are of the in situ region is generally intense but have only a shown). The location transient impact because regeneration of the Long Lake occurs quickly. project is outlined in red for reference. The extensive 3D seismic exploration SOURCE: CANADIAN PARKS visible on recent aerial photos of the AND WILDERNESS SOCIETY Long Lake site (Fig. 6) was not included in the Long Lake EIA data. Pre-existing disturbances in the lease area (e.g., roads, earlier seismic activity) were not included in the 884 ha total either, unless they were reused in the project. We could not incorporate these additional disturbances into our base- case footprint because they have not been quantified. Therefore, our projections underestimate the actual likely impact. As of July 2005, the total area leased for in situ development was 3,568,000 ha, approximately 11 times the size of the mineable oilsands region.36 If all the leases are subjected to a similar industrial footprint to the Long Lake project then 296,000 ha of forest will be cleared for SAGD infrastructure and over 30,000 km of access roads will be built (Box 3). This is a conservative estimate and does not take into account transient disturbances such as seismic

THE PEMBINA INSTITUTE DEATH BY A THOUSAND CUTS 11 2 Regional Environmental Impacts

exploration, forest harvesting, or wildfire. Furthermore, new leases are continually being awarded. By even the most conservative estimate, there will be more long-term deforest- ation from SAGD development than if the entire mineable oilsands region were to be completely cleared. The ecological effects will be many times greater still, because the SAGD disturbances will be dispersed across a vast region. To fully appreciate the intensity and spatial scope of the projected impacts it is helpful to see them in map form. Therefore, we developed a template of an industrial footprint modeled on the Long Lake project (Fig. 12) and then projected this template in random orientation across all existing oil sands leases (Figs. 13-14). Given the long lifespan of the projects, the extended lag time associated with successful reforestation, and the fact that new leases continue to be awarded, the projected footprint is a very conservative

FIGURE 14: Projected SAGD disturbance footprint across estimate of what Alberta’s boreal forest northern Alberta based on existing leases. The location of may look like in the future as a result of the Long Lake project is shown in red for reference, as is the oil sands administrative boundary unconstrained in situ development. SOURCE: CANADIAN PARKS AND WILDERNESS SOCIETY 2.2 Environmental Effects

Future SAGD developments will have Recent studies in Alberta have shown environmental impacts on land, water that forests adjacent to roads, well sites and air, as well as contribute to climate and pipelines are avoided by a variety change. In this report we focus on of forest mammals and birds due to terrestrial ecosystems, where the most their sensitivity to human disturbances.37 significant change will be a regional For these animals, useable habitat within decline in biodiversity. This is because a SAGD development area is reduced the boreal forest in which these develop- to small scattered islands. Within the ments are taking place is home to many Long Lake project approximately 80% wildlife species known to be sensitive to of the land will be within 250 m of an industrial disturbances (Box 4). industrial feature (Fig. 15). The direct

12 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Regional Environmental Impacts 2

loss and avoidance of habitat results BOX 4. SPECIES IN DECLINE AS A RESULT in declining wildlife populations. OF INDUSTRIAL DEVELOPMENT Further declines occur once a threshold IN NORTH-EASTERN ALBERTA is reached where the landscape as a whole becomes unsuitable (i.e., once Caribou Lynx the remnant habitat patches are too Marten small and scattered to maintain a Fisher breeding population).38 Wolverine Boreal chickadee Project developers have acknowledged Rose-breasted grosbeak a local risk to biodiversity as a result Yellow-bellied sapsucker of SAGD developments39 but have Red-breasted nuthatch discounted regional impacts, ostensibly Brown creeper because they have been unable to Various warblers quantify them. In lieu of understanding what the impacts might be, companies pin all hope on reclamation. For example, the Long Lake EIA states,

Ecological thresholds have not yet been established regarding impacts to biodiversity as a result of fragmentation by development. Until thresholds have been defined, it is difficult to quantify effects of development on ecosystem function. Although the actual effects on overall biodiversity and ecosystem function are not known, it is expected that biodiversity will also be restored to baseline conditions if reclamation is successful.40

There are several reasons why this fragmented at closure than at baseline FIGURE 15: approach is untenable. First, reclamation due to the permanent loss of portions of Satellite view of is unlikely to be fully effective. The track these types.”42 Another problem is that the Long Lake site showing wildlife record to date has certainly not been impact assessments are conducted in the positive. According to the Long Lake avoidance zones absence of a cumulative impacts (red) around roads EIA there is not even an objective of framework. In fact, this report represents and well pads restoring the site to its previous state, the first attempt to quantify the total (Source: same photo just of being “capable” of returning it to impact of proposed SAGD develop- as Fig. 5, with 200 41 m buffers on roads the previous state. Moreover, the EIA ments. Remarkably, EIAs ignore most openly admits that some ecotypes and 300 m buffers future in situ development, even though on well pads). simply cannot be restored: “Most thousands of square kilometres have SOURCE: GOOGLE EARTH, wetland types in the lease will be more ©2005 GOOGLE, IMAGE © 2006 DIGITAL GLOBE

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already been leased. Finally, although are much more intense and prolonged oil sands developers speak of the impacts than conventional forms of petroleum as transient, the fact is that 40 years is development it seems likely that not equivalent to several generations for only will ecological thresholds be greatly affected wildlife species. Given the vast exceeded in the future, but several area affected, there may be no breeding species may be extirpated from populations left for repopulating the northeastern Alberta under proposed sites even if reclamation is indeed development trajectories. successful. Although precise ecological tipping 2.2.1. Caribou points have not been defined, evidence Woodland caribou is one of the species is steadily mounting that ecological likely to be extirpated from regions thresholds for many species are already subjected to SAGD development. being exceeded at current levels of Caribou declines across Alberta have industrial development in northern been correlated with the level of Alberta. We present evidence below for industrial development within their three animal groups for which research ranges.43 In the past ten years, the East findings from the oil sands region are Side Athabasca River caribou herd, available. Other species are likely to be whose range overlaps much of the similarly affected, though only limited current SAGD development, has research has been done to date. Given declined by almost 50% (Fig. 16). that the impacts of SAGD development Studies have shown that forests within 1 km of roads and well sites tend to be avoided by caribou44 and that roads further fragment caribou habitat by acting as barriers to movement.45 It is believed that this fragmentation concentrates woodland caribou into smaller portions of their range, where they become more susceptible to predation by wolves.46 Three separate studies predict dire consequences for caribou under the current management regime. A government-led study concluded that woodland caribou will continue to decline unless limits to development and aggressive restoration of existing disturbances are implemented.47 An industry-funded modeling study Woodland caribou populations in the region have declined within the oil sands region determined by 50% over the past 10 years. Government and industry that, due to projected industrial studies predict caribou will be lost from areas underlain by development, available caribou habitat oil sands under current development trajectories. PHOTO: WAYNE LYNCH

14 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Regional Environmental Impacts 2 100 FIGURE 16: Population change of the East 95 Side Athabasca River caribou 90 herd from 1993 to 2004. 85 SOURCE: ALBERTA WOODLAND CARIBOU RECOVERY TEAM 80 75 70 65 Population Change % 60 55 The lynx in one of several 50 mammals this is negatively 1993 1995 1997 1999 2001 2003 affected by industrial development. Year PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE will decline from 43% of the landscape to 6% over the next 20 years.48 Finally, a study at the University of Alberta concluded that caribou will be extirpated from northern Alberta in less than 40 years if linear densities exceed 1.2 km/km2 (less than half the projected linear density within SAGD developments).49 The consistent message is that, unless significant changes are made in the way we allocate and develop land for in situ oil sands production, caribou are likely to be lost from the entire oil 1.0 sands region. Observed 0.8 Expected 2.2.2. Furbearers 0.6 Furbearing mammals such as lynx, martens, and fishers are another group of animals negatively impacted 0.4 by industrial development. A recent Probability of Occurrence study has shown that population sizes 0.2 have remained at expected levels in relatively intact regions of northeastern 0.0 Alberta, but have significantly declined Fisher Lynx Marten Coyote in regions subjected to industrial 50 FIGURE 17: development (Fig. 17). Researchers Probability of mammal occurrence in the Dry Mixed also found that declining population wood Boreal Region of northeastern Alberta: Observed size is strongly correlated with road vs.expected mean in intact forest.50 SOURCE: SCOTT NIELSEN, ERIN BAYNE, JIM SCHIECK, J. HERBERS & STAN BOUTIN

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1.0

FIGURE 18: Probability of lynx occurrence in 0.8 Alberta’s Central Mixedwood Boreal Region relative to 50 0.6 road density. SOURCE: SCOTT NIELSEN, ERIN BAYNE, JIM SCHIECK, J. HERBERS & STAN BOUTIN 0.4 Probability of Occurrence 0.2

0.0 0.0 0.1 0.2 0.4 0.6 0.8 1.0 1.2 1.4

2 Road Density (km/km )

density (Fig. 18). As the populations of 2.2.3. Forest Birds sensitive species have declined, the abundance of species tolerant of Projections are also bleak for several disturbance, such as coyotes and deer, forest birds, including some migratory has increased (Fig. 17). The intense species already of conservation concern and prolonged disturbance footprint of as a result of previous industrial SAGD developments will accelerate development. Many forest birds are these trends, leading to further declines sensitive to industrial disturbance and in furbearer populations and possibly tend to avoid using otherwise suitable the loss of species in many areas. habitat within 100 m of roads, pipe- lines, well pads or similar features.51

2.5

Low Footprint

FIGURE 19: 2 Abundance of four High Footprint species of birds in northeastern Alberta relative to 1.5 the intensity of industrial footprint (low, high).53 1 See Box 4 for full species names. SOURCE: STEVE G. CUMMING Mean Number of Detections 0.5 & FIONA A. SCHMIEGELOW

0 Brown Creeper Red-breast Yellow-belly BTG Warbler Grosbeak Sapsucker

16 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Regional Environmental Impacts 2

There is evidence that landscape effects, • Depletion of freshwater reserves, above and beyond local avoidance either through direct use or through effects, are responsible for additional the secondary effects of drawing declines in the abundance of some down saline aquifers (e.g., although species.52 A recent study in northern the Long Lake project uses saline Alberta determined that the abundance water for steam production, draw- of some bird species was reduced by down effects are expected to reduce over 80% in townships with a high the flow of the nearby Gregoire river level of industrial footprint compared by up to 3.4%55 ); to relatively undisturbed townships • Damage to aquatic ecosystems from 53 (Fig. 19). The declines in SAGD sites the disruption of normal flow are bound to be even greater, given that patterns caused by roads and other the intensity of SAGD disturbance is industrial features; substantially greater than that of the conventional oil and gas disturbances • Acidification of land and water in included in the bird study. The loss of the oil sands region (e.g., the Long some bird species from the oil sands Lake EIA predicts that some lakes in region seems highly likely. the region may acidify sufficiently to affect amphibian embryos56); 2.2.4. Other Environmental Impacts • Regional contamination of ground and water from thousands of tons of Impacts of oil sands development on drilling wastes, production wastes, air and water have been reviewed in byproducts of upgrading, byproducts other reports and will not be covered of desalination, and accidental spills; in detail here. In particular, we refer readers to Oil Sands Fever and to • Conversion of wetlands such as fens Troubled Waters, Troubling Trends.54 and bogs to upland landscapes after Some of the most significant impacts reclamation; and from in situ development are as follows: • Large increases in emissions of greenhouse gases.

THE PEMBINA INSTITUTE DEATH BY A THOUSAND CUTS 17 Alberta’s boreal forest is a mosaic of forests, wetlands, rivers and lakes. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE 3 Solutions

We present here a suite of government All of our recommendations are based policy options and industrial best on specific examples of policies and best practices that, taken together, would practices that have been implemented reduce some of the environmental risks either in Alberta or elsewhere in North associated with in situ oil sands America, and are directly applicable for development. It is important to note in situ development in northeastern that industrial best practices are Alberta. Unfortunately, although insufficient in the absence of clear practical, these approaches have policy and regional planning designed generally not been widely adopted to to balance environmental protection date. Our hope is that by drawing and industrial development. This attention to these workable solutions, is particularly relevant in the case while showing the perils of maintaining of oil sands development given the the status quo, these approaches intensity and pace of development will become standard practice under a on the landscape. new regulatory framework for in situ development in Alberta. 3.1 Policies and Planning

Although industrial best practices will manage the impacts of rapidly be beneficial, it is clear that even with expanding industrial development in state-of-the-art practices the cumulative Alberta. The Alberta Chamber of ecological impacts of in situ develop- Resources, an industry group that has ment will be devastating. By their very pioneered voluntary partnerships to nature these projects are inextricably reduce the impacts associated with linked to an intensive, widespread, and overlapping developments, acknow- long-term disturbance footprint. Even if ledges that limits to land uses are individual disturbances are reduced in inevitable in order to maintain size, the sheer number of seismic lines, environmental values.57 In a recent core holes, roads, well pads, pipelines, survey commissioned by the Alberta and other infrastructure components, Forest Products Association, 75% of along with a large central facility, will respondents felt that the government greatly exceed the tolerance limits of needs to put limits and set priorities on many wildlife species. who is able to use the forest, how, when 58 As the limitations of industrial best and where. practices have become more apparent If there is to be any hope of balancing there has been a growing consensus that ecological and economic objectives in additional measures will be needed to the boreal forest of Alberta, then new

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 19 3 Solutions

approaches to land management function in the boreal forest. Given supported by appropriate policy and that oil development in the region is planning frameworks in a broad regional projected to last well into the next context will need to be implemented. century, the wildlife reserves should be Developing and implementing these new permanent entities. A designation of policies and planning frameworks will Wildland Provincial Park, which permits require leadership by both government traditional uses but prevents industrial and industry. In the following sections activity, would be most appropriate. we outline some of the key elements that Besides serving as reservoirs of should be considered. biodiversity, protected areas also play a vital role as ecological benchmarks. 3.1.1. Protected Areas Monitoring within these areas provides important baseline data that can be To maintain the full complement of used to assess ecological changes in the native species in the oil sands region in industrial landscape as part of an the face of widespread in situ develop- adaptive management system. Further, ment, parts of the landscape will have to they can serve as representative areas be set aside as wildlife reserves. The of ecological integrity for ongoing establishment of such reserves can be research into improving reclamation thought of as a conservation offset of oil sands developments. Protected measure (i.e., an action taken to offset or areas also serve as important sites for balance ecological losses resulting from traditional, spiritual and recreational intensive industrial activity). Unless this uses. Finally, the preservation of step is taken, species will be lost. wilderness as an end in itself is a To effectively serve as reservoirs of high priority for the public.59 biodiversity the reserves will need to Currently, Wood Buffalo National Park meet several criteria. First, the sites must serves as the core protected area for be fully protected from industrial use, Alberta’s boreal region. While of including both petroleum development immense ecological value, much of this and forestry. Second, the sites should be park is centred around a unique delta part of an integrated system designed to system that has different characteristics provide full representation of Alberta’s from the forests found in the oil sands boreal ecosystems (in which the oil region. The park is also north of the oil sands lie). It follows that new sites sands region, which means that it has a should emphasize ecosystems not well different climatic regime. As a result, represented in existing protected areas. many species typical of the boreal forest Third, the sites should be large enough found in the oil sands region, including to support viable populations of native woodland caribou and a variety of song species and to maintain natural birds, are not found in the park. ecological processes. This implies a size Therefore, notwithstanding Wood of several thousand square kilometres – Buffalo National Park, there are still sufficient to withstand the large fire many gaps in the existing system of events that are a key driver of ecological protected areas that need to be filled.

20 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Solutions 3

Much of the technical groundwork for establishment of new protected areas in identifying priority areas for protection the region rests largely with the in the boreal region has been done. It is government. However, since the end of beyond the scope of this paper to Special Places 2000 there has been no discuss all of the candidate sites and the process in place whereby discussions selection methodologies used. Instead, leading to the establishment of new we refer the reader to the relevant protected areas could take place. Alberta literature.60 But it is worth highlighting Sustainable Resource Development two prospective sites of high ecological should lead the establishment of new value that exist in the heart of the oil interconnected protected areas represent- sands region, near Fort McMurray ative of the boreal region as part of a (Fig. 20). What makes these sites of broader land use strategy for the region. particular interest is the fact that they are largely devoid of recoverable oil 3.1.2. Protection of Private Lands deposits, even at today’s high oil prices. Oil and gas leases are virtually absent in A more direct approach to conservation these sites (Fig. 20) and their protection offsets being explored by some oil sands could proceed with minimal conflict companies is the purchase of privately with the petroleum sector. Furthermore, held forested land in the Peace River the major forestry company in the region. As a conservation offset measure, region, Alberta-Pacific Forest Industries, this approach has much merit. The has been actively pursuing legislated main limiting factor is that it is difficult protection of these two sites (albeit using somewhat smaller boundaries) under its ecological benchmark initiative. Some oil sands operators have begun to support the conservation offset concept. For example, several have written letters of support for the Alberta-Pacific Forest Industries ecological benchmark initiative. Some are also beginning to incorporate the need for ecological benchmark areas into their EIAs. For example, the EIA for the Imperial Oil Kearl Oil Sands Project identifies the need for regional ecological benchmark areas as reference areas to compare to reclaimed portions of project leases.61 Because the oil sands lie largely on public lands, responsibility for the FIGURE 20: Candidate protected areas (black lines) near Fort McMurray in relation to petroleum leases. The two areas outlined are 1,700 and 3,300 km2 in size, respectively. SOURCE: CANADIAN PARKS AND WILDERNESS SOCIETY

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 21 3 Solutions

RECOMMENDATION

Alberta Sustainable Resource Development should establish new interconnected protected areas representative of the boreal region as a conservation offset measure.

Conservation offset areas should be established.

PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

to assemble large contiguous blocks Conservation Association and Suncor of protected land, given the high cost that started in 2003, when 190 ha of of land and the fact that not all land is land were purchased or secured through for sale. Also, as in other areas of the protective land use reservations in the province, ownership of the land does Winagami Lake area of northwestern not extend to subsurface rights. Unless Alberta to offset habitat affected by oil the areas are formally designated as sands operations in Fort McMurray. protected areas by the government, oil and gas development can still occur. 3.1.3. Regional Planning Protection of private land can take the form of purchasing and donating lands The most effective application of the in partnership with conservation conservation offset concept will be organizations or through purchasing achieved if the efforts of individual conservation easements. Suncor’s companies and the government are involvement as a founding member of coordinated through regional planning. the Boreal Habitat Conservation The same can be said of wildlife Initiative is a good example of how this movement corridors, conservation of can be accomplished in practice. Suncor old growth, and indeed any regional has committed to invest a total of $1.05 management objective. However, there million over three years to help the is currently no regional plan that Alberta Conservation Association secure demonstrates how future oil sands boreal forest habitat that will be turned development will be integrated with over to Alberta Parks and Protected protecting the regional environment. Areas for ongoing stewardship and Whatever the desired future may be management.62 This commitment builds for northeastern Alberta, it cannot be on an agreement between the Alberta achieved without a common blueprint.

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Arguably the most important element of regional planning is the allocation of The April 2003 Muskwa-Kechika pre- tenure plan truly adopts a result-based tenure, including the decision about management framework. The plan which lands to lease for oil sands does an excellent job in incorporating development. Tenure decisions can be views from a diverse set of stake- linked to an identification of priority holders and generating a useable land uses, but in most regions of Alberta plan to guide oil and gas activity in the Muskwa-Kechika”. this type of planning is not done. It is at this stage where the greatest latitude Shira Mulloy, 64 exists for directing the timing, location, Canadian Association of Petroleum Producers and intensity of development at the regional scale. Once tenure rights have The logical planning process in the been allocated, discussions focus Muskwa-Kechika is in contrast to the narrowly on mitigation measures to disposal of in situ oil sands leases in minimize cumulative impacts. We have Alberta, which occurs without any demonstrated in this report that a failure landscape-level strategic planning. The to consider environmental objectives in only review that occurs prior to tenure the allocation process poses significant allocation is by the multi-departmental risks to the boreal forest landscape. Crown Mineral Disposition Review Committee, which is expected to Successful Tenure Approaches highlight any environmental restrictions associated with individual land parcels. The Muskwa-Kechika region of This process is closed to the public and northern British Columbia is a good does not solicit stakeholder input. In the model of how pre-tenure planning absence of a cumulative impacts for petroleum development can be framework the committee has not had successfully applied. The Muskwa- any discernable effect in influencing the Kechika Management Area Act requires location or rate of in situ development. that pre-tenure plans, which provide It has been argued that the lack of binding directions on oil and gas transparency, accountability and formal developments, must be prepared by mandate for this committee also government prior to the issuance contributes to its ineffectiveness.65 63 of oil and gas tenures. Pre-tenure Over 3.5 million hectares of boreal forest plans include landscape objectives have been leased for intensive in situ and quantitative numeric thresholds development in Alberta without a long- for land-based disturbances. This term landscape plan, and new leases approach provides both certainty continue to be awarded at a record pace. of appropriate access for petroleum companies, while ensuring cumulative We recommend that a regional land limits to disturbance are not exceeded management plan be developed, and and environmental values are protected. that no further tenure allocations be The need for pre-tenure planning is made until this plan is in place. broadly supported by many stakeholders: Slowing down the rate of petroleum

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 23 3 Solutions

development is a prudent step in Finally, the plan needs to include any case, given the severe labour directives for implementation. These and infrastructure shortages facing should include land use designations the province from oil projects already and quantitative management targets, under way. such as maximum levels of disturbance The regional plan should include a and road densities that can guide tenure comprehensive environmental baseline, allocations, as in the Muskwa-Kechika. characterizing northeastern Alberta prior Making the bridge between public to industrial development (i.e., circa values and an implementation plan is 1950). This baseline should serve as the the most difficult step because trade-offs reference against which the impacts of are invariably necessary. The best future developments are compared. approach for grappling with such Current government expectations require tradeoffs is to use future scenario companies to present their projects in modeling, wherein the state of the the context of the landscape condition at landscape under alternative management the time of application, ignoring the approaches is projected into the future progressive regional-level deterioration in using computer models. The Sustainable environmental indicators. Ecosystem Working Group of the Cumulative Environmental Manage- The plan should also include a clear ment Association has recently under- expression of public values, expressed as taken a project to do just that, and long-term management objectives for results will provide valuable insights the region. This can be achieved for the future management of the oil through a description of the desired sands region. However, the continued future landscape along with the societal allocation of lands for in situ oil sands benefits to be derived from it. development before this assessment is complete is of grave concern.66

RECOMMENDATION

Alberta Sustainable Resource Development should develop a regional plan for in situ development that will protect the boreal forest. Alberta Energy should suspend new tenure allocations and Alberta Environment should suspend new project approvals until the regional plan is in place. Maximum allowable levels of disturbance should be established.

PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

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3.1.4. Cumulative Effects Thresholds Threshold Approaches Example 1: The Muskwa-Kechika Management Area Quantitative thresholds are a useful way The Muskwa-Kechika provides a working to manage environmental impacts model of how land-based cumulative associated with development activities. effects thresholds can be put into practice. Numeric limits for air and water In the Muskwa-Kechika, habitat thresholds emissions are entrenched in manage- vary depending on the nature of the ment decision-making, both as project- planning area, as defined in pre-tenure plans.67 For example, for the Halfway- specific thresholds and regional targets. Graham region, 23% of the 234,902 ha Despite the potential efficiencies area may be impacted by oil and gas involved in incorporating land-based activities. This includes both the physical thresholds, Alberta has resisted infrastructure (roads, well pads and incorporating thresholds into land-based pipeline corridors) associated with oil and gas developments, and the ‘zone decision making, particularly with of influence’ around these developments. respect to the oil and gas sector. The zone of influence is an area around Since thresholds for cumulative a disturbance feature where impacts to environmental values may be felt. industrial impacts have not been To determine whether new developments implemented in Alberta, as a result, can be accommodated within the forested lands in northern Alberta are thresholds, development plans are overlaid being transformed by an industrial on habitat maps for six different wildlife footprint that is steadily increasing in species. Disturbances are time limited, and when they are decommissioned and extent and intensity. The issue is restored they no longer contribute to exacerbated by the fact that most areas calculation of cumulative effects thresholds. are subjected to impacts from multiple industrial operators (e.g., oil sands, conventional oil and gas, hardwood Threshold Approaches Example 2: forestry, softwood forestry). Alberta’s The Dehcho Land Use Plan boreal forest is well on its way to becoming one large intensive use zone, The Dehcho Land Use Plan, for the Dehcho territory directly north of Alberta, is another with disastrous consequences for excellent model for the establishment of biodiversity. This is at odds with public land-based thresholds.68 Opportunities values and government commitments for industrial development are provided to sustainable development.70 A balance in development zones, provided that between economic and environmental thresholds are not exceeded. The plan is flexible, and provides clear direction values must be achieved, either by regarding management options when the fully protecting a large proportion of thresholds have been reached. The draft the land base or by protecting a smaller plan provides proposed land use proportion but setting strict limits thresholds for road density, total linear on the intensity of development in density, habitat availability, core areas and stream crossings.Thresholds are based the industrial areas. The examples cited on best available scientific information above from surrounding jurisdictions about the response of wildlife species to demonstrate that workable solutions industrial development.69 do exist.

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 25 3 Solutions

RECOMMENDATION

Alberta Sustainable Resource Development should establish quantitative limits on cumulative industrial disturbances and precautionary standards for wildlife habitat to ensure that ecological thresholds are not exceeded and environmental values are protected.

Most areas are exposed to multiple forms of development.

PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

3.1.5. Coordination of northwest of Nordegg.71 While coordination of development was a Operational Planning core element of the draft Mineable In addition to a broad regional strategic Oil Sands Strategy, the focus was plan, a framework is needed to guide primarily on coordinating mining the development of integrated operating projects, and there was no attempt to plans to ensure that different industries balance environmental and economic operating on the same landscape values.72 The Forest Management coordinate their development activities. Planning Standard provides perhaps the Integrated planning is too important to most useful template for coordinated leave as a voluntary industrial best planning.73 It includes a framework and practice with inconsistent implement- a list of landscape-scale management ation. Moreover, it is not just companies indicators that forestry companies must that need to be integrated at the use when developing their integrated operational level, but also individual forest management plans. However, no government departments, which often attempt has been made to expand the have conflicting management objectives scope of this document beyond the and regulations. forestry sector. Although the Alberta government has We recommend that a Land been working on the issue of integra- Management Planning Standard, tion, a workable solution has not yet modeled on the Forest Management been forthcoming. A recent Information Planning Standard, be established to Letter recommended that energy and guide the development of operating forestry operators discuss requirements plans for all resource companies for joint infrastructure, but it was working in a given management area. limited to a small planning area The standard would compel companies

26 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Solutions 3

to collaboratively devise workable woodland caribou ranges in integrated solutions for achieving northeastern Alberta, where levels of shared landscape-scale land management development generally already exceed objectives. A single government maximum levels required to maintain agency dedicated to integrated land caribou populations in most areas. management should be established to Part 6 of the Oil Sands Tenure provide oversight and facilitation of this Regulation enables the Minister of process. A key role for the government Energy to prescribe an acceptable level is to ensure that the solutions companies of evaluation that is less than that devise are equitable, and consistent with identified above. It is unclear if this regional land management and flexibility is ever exercised by the conservation objectives. minister. We recommend that the government consider the requirements 3.1.6. Requirements for for evaluation in terms of landscape Lease Evaluation impacts, and either lower the minimum evaluation requirement, or provide The Oil Sands Tenure Regulation guidance whereby the minister may 50/2000 is an impediment to waive evaluation requirements in order sustainable land management. The to mitigate landscape impacts. regulation generally requires that oil sands proponents drill one evaluation RECOMMENDATION well in each section (square mile) in not less than 60% of the sections within Alberta Sustainable Resource their oil sands lease to evaluate the Development should establish a Land nature of the oil sands resource. This Management Planning Standard, means that before an EIA has been modeled on the Forest Management completed, or an in situ project is Planning Standard, to guide the development of operating plans for all approved, a significant level of land resource companies working in a given disturbance has already taken place. management area. This is of critical importance in 3.2 Industrial Best Practices

Although improved industrial practices developments. In the sections below alone will not be sufficient to avert we outline some of the key practices severe declines in biodiversity and other that could and should be put into environmental problems in the forests widespread use. The Departments of of northeastern Alberta, best practices Sustainable Resource Development will be important for keeping in and Energy should require these situ developments below ecological practices as minimum standards for thresholds and generally tempering in situ development. the cumulative impact of proposed

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 27 3 Solutions

RECOMMENDATION lines are no longer perceived as ecological features has yet to be All government departments should determined by scientists, preliminary establish minimum standards, reflecting evidence suggests that the 2.5 m lines industrial “best practices,” that companies being cut by some operators are an must employ to minimize damage to the appropriate interim target for 2D boreal forest. programs. Because the density of seismic lines in 3D programs is usually extremely high, hand-cut lines and 3.2.1. Seismic Exploration heliportable techniques should be predominantly used for these Seismic lines account for the majority developments. of the linear disturbance associated with in situ development. The average If new lines 1) are cut at minimal width, seismic program associated with a 2) do not disturb the soil and root SAGD project includes approximately systems, and 3) include barriers to 1,000 km of line cutting.74 Minimizing motorized access, then anecdotal the seismic footprint is essential if evidence suggests that no extra effort environmental values are to be (or cost) is required for reclamation. protected in northeastern Alberta. The lines appear to be visibly reintegrated into the forest within five years. There are several problems with conventional seismic lines. First, they are perceived by wildlife as gaps in the 3.2.2. Bitumen Extraction forest, affecting their movement and and Processing: 75 territory establishment. Second, because Alternatives to SAGD regeneration is extremely slow, the lines usually become long-term features on The infrastructure, water and energy the landscape.76 Finally, conventional needs, and wastes associated with in situ lines often become used as human access developments are far greater than those corridors, with various secondary effects. associated with conventional oil and gas Seismic operators need to address all operations. As described earlier, the of these issues. Given the enormous cumulative impacts of proposed in situ number of lines being cut, the working developments using SAGD technology objective should be to cut seismic lines would be ecologically unsustainable that have no discernable ecological if all were to proceed. It is imperative effect within five years. that alternatives to SAGD that are Reducing the width of lines and less environmentally destructive be installing barriers to travel are the developed and implemented as rapidly two main approaches for reducing as possible. the ecological impacts of seismic lines. Two alternative approaches, now in The seismic industry in general is the pilot phase, are VAPEX and in situ making excellent progress in this regard. combustion.77 These new technologies Although the minimum width at which have the advantage of not requiring

28 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Solutions 3

external energy or a large central facility to create steam, which may reduce the disturbance footprint associated with this extraction practice. They also have substantially reduced water and energy requirements, as well as emissions of greenhouse gases. Another promising alternative in situ technique, now undergoing field testing, is electrical heating.78 This technique has been used throughout North America for bioremediation and is now being applied to the oil sands. The process involves passing an electrical current from surface power distribution thousands of abandoned well pads from FIGURE 21: equipment to large vertical underground earlier oil and gas activities that are Electrodes. PHOTO: E-TENERGY electrodes placed in a grid pattern classified as reclaimed, but have not (Fig. 21). The electrical current heats returned to a forest ecosystem.79 Most the bitumen and vertical production of the delay in reforestation has to do wells bring the heated fluid to the with inadequate care of the sites during surface. This approach is highly efficient the initial clearing process and with and is expected to produce an equivalent inadequate reclamation objectives and volume of bitumen in a tenth of the regeneration techniques at closure. time required by SAGD, while using Given the large number of new wells substantially less energy. The process anticipated with in situ development, it also uses substantially less water than is critical that better approaches to well SAGD. The short duration of the pad development and closure be project is a key feature because it implemented. means that any disturbances would One of the key steps for reducing the approximate transient natural impact of well pads is to reduce the disturbances to which wildlife species spatial and temporal extent of their are adapted, as opposed to extended footprint. Specific practices that can be SAGD disturbances that are likely to undertaken are as follows: result in the extirpation of species. • Minimize the area affected by clearing the minimum area possible 3.2.3. Well Pad Construction for drilling and then immediately and Reforestation reforesting the majority of the site except for the actual well One of the main concerns associated infrastructure; with in situ well pad development • Minimize the number of exploratory is the risk of long-term loss of forest core holes drilled, and ensure that productivity and habitat potential. they are reforested immediately; Northeastern Alberta is dotted with

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 29 3 Solutions

• Minimize the number of well pads 3.2.4. Integration with through directional drilling of multiple wells from the same pad Forestry Operations and reusing existing well sites such The majority of the area proposed as core holes when possible; and for in situ oil sands development is • Reduce related infrastructure (roads, also licensed for forestry development etc.) by maximizing the use of remote through Forest Management Agreements operating technology. and quota holder licences. A significant reduction in the combined impact Another suite of best practices falls of these industries could be achieved under the heading of minimizing on-site through integrated planning. In impacts: particular, there are opportunities • Avoid introducing native and non- for placing forestry cutblocks in areas native invasive plant species; proposed for in situ infrastructure • Minimize long-term changes to the and for harmonized road construction. site by drilling under frozen Reducing the road footprint is conditions; this means avoiding especially important because of the stripping of top soil, using snow and large ecological impact associated with slash for filling contours and roads (access issues, disruption of water 80 constructing well pads, and avoiding flow, erosion, etc.). the use of off-site materials for pad Integration of in situ oil sands Planning between construction; development and forest harvest was forestry operations and • Where top-soil stripping is first explored between Gulf Canada oil sands could reduce unavoidable, ensure proper handling (now ConocoPhillips Canada) and road access and the Alberta-Pacific Forest Industries (Al-Pac) amount of area cleared and storage to protect and retain for industrial facilities. natural propagules; and in the Surmont area. By overlaying PHOTO: DAVID DODGE, development plans for the next 30 years, PEMBINA INSTITUTE • Leave construction slash whole. the companies were able to show that coordinated planning could result in a 34% reduction in overall road access and a 16% reduction in areas cleared for facility development.81 In the integrated operational plan Al-Pac adjusted its harvest plans to coincide with the SAGD footprint. This offset the need to harvest elsewhere, reducing cumulative levels of disturbance. Timber harvested from these areas was transported using ConocoPhillips’ well site roads, therefore reducing additional forestry road requirements. Being able to coordinate activities between SAGD development and forestry operations is dependent on the

30 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Solutions 3 presence of merchantable timber, the disturbances to be reforested to the same ability of forestry companies to change standards used by the forestry sector. harvest plans, and a willingness to The importance of restoring existing invest additional up-front resources disturbances as an appropriate best in collaborative planning. The initial practice has been recognized by the Surmont plan indicated that Boreal Caribou Committee, a approximately $1 million in savings government–industry group developing may be realized in road construction recommendations for land management 82 over the life of the project. So far, within caribou ranges in Alberta. ConocoPhillips has saved approximately Through computer modeling projections $100,000 in associated tree clearing and based on field data this committee 83 Timber Damage Assessment costs. concluded that aggressive reforestation By using ConocoPhillips’ higher grade of existing developments, and in some roads, Al-Pac also has reduced road instances developing maximum construction costs and will slightly thresholds for development, would decrease haul cycle times. It is important be required to maintain stable caribou to note that, although integrated populations in northeastern Alberta: operational planning is an effective mitigation tool to help minimize disturbance impacts of multiple land uses, the levels of disturbance associated Throughout the East Side of the Athabasca River (Caribou) Range, with coordinated projects such as the existing and future industrial footprints Surmont project are still very high. need to be reduced in order to sustain the caribou population. Both industry and government must establish 3.2.5. Footprint Restoration innovative techniques and policies to develop the natural resources on a The conventional approach to the smaller footprint, while restoring restoration of seismic lines, roads, historical footprints.85 and well sites has been to simply plant grass on the site at closure. This has seriously delayed reforestation of these disturbances. A recent study found that 3.2.6. Monitoring of Biodiversity 65% of seismic lines cut three decades and Disturbances ago are still in a cleared state.84 As a There is a need to integrate resource result, there is a significant historic management decision making with footprint that should be restored before information about changes in in situ development begins in earnest. biodiversity. There is currently Serious attention must be paid to the insufficient information for in situ reforestation of existing industrial operators to be able to demonstrate disturbances before additional their operations are not impacting disturbances are added to the system. regional biodiversity. To more effectively mitigate in situ impacts, Alberta Sustainable Resource Development of an Alberta Biodiversity Development should implement reclam- Monitoring Program (ABMP) was ation standards that require in situ initiated in 1997. As currently designed,

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 31 3 Solutions

this initiative has the potential to be There is also an urgent need to track the most advanced and comprehensive disturbances as they occur. Despite the biodiversity monitoring program in the fact that land clearing by the petroleum world.86 The ABMP consists of a grid industry now approaches that of the system of 1,656 sites across Alberta forest industry, the rate and distribution where the presence of more than 2,000 of landscape disturbance associated with different species will be monitored to petroleum development is poorly tracked determine changes over time. by both government and industry. The The ABMP is supported by a broad Alberta Government does not track or range of stakeholders from government, report on cumulative terrestrial footprints, the forestry and energy sectors and and reporting of disturbances by individ- environmental organizations, and is ual oil and gas companies is limited or currently in a pilot phase. For the absent. Without readily available inform- ABMP to be fully operational in 2007, ation about the current status of the land- significant funding from a broad range scape it is difficult to make meaningful of land users will be required. assessments about the progress of individual companies in reducing Some in situ operators such as impacts, or to determine whether ConocoPhillips and OPTI-Nexen are ecological thresholds are being exceeded. piloting the incorporation of monitoring programs like the ABMP into their A voluntary data collection pilot program operations. Both projects has invested by the Canadian Association of Petroleum funds typically assigned to a project- Producers was planned for 2005, but was 87 specific monitoring program into sites delayed to 2006. Although an industry- monitored according to ABMP sponsored program would be a positive protocols. Consistent monitoring step, what is ultimately needed is a protocols across northeastern Alberta province-wide land information system are essential to be able to determine that provides up-to-date land use regional level changes to biodiversity information for government, stakeholders that could be associated with large-scale and proponents to assist in the in situ developments. implementation of a sustainable land management framework.

32 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Conclusion

In this report we have demonstrated that in situ development of Alberta’s oil To ensure current and future generations continue to enjoy sands will result in unprecedented wildlife resources, habitat and impacts to Alberta’s forests and pose population objectives will be grave risks to regional wildlife achieved within a regional and populations. Existing in situ leases provincial context through regional already total 3.6 million ha, which is and provincial programs. more than ten times the size of the mineable oil sands region. To put this in perspective, we are talking of an In reality, the lands outside the mining intensive industrial use zone larger zone continue to be allocated for in than Vancouver Island. If existing leases situ development and there are no are subjected to the same industrial biodiversity objectives or plans at either footprint as the Long Lake project then the regional or the provincial scale. 296,000 ha of forest will be cleared for There is still no concrete evidence that SAGD infrastructure and over 30,000 the government of Alberta is acting km of access roads will be built. upon its stated intent to establish Furthermore, new leases continue to an Alberta Biodiversity Strategy88 – be awarded at a rapid pace, and new a strategy that could and should technologies for extracting less accessible provide direction and support for the reserves are continually being developed. development of regional biodiversity If the entire area underlain by oil objectives. Rather, as we have shown sands is eventually developed, in situ in this paper, declines in a number infrastructure could impact almost of monitored species indicate that 14 million hectares of forest – a land ecological tipping points are already area the size of Florida. being exceeded in northern Alberta. Moreover, in situ development, Until now, environmental concerns proceeding at an unprecedented rate, about oil sands development have is likely to push many species over the largely focused on the impacts of brink. Without a doubt, we are at a oil sands mines. In response, the critical juncture with respect to land government has suggested that management in northern Alberta. extra conservation efforts will be Decisions made today will determine undertaken outside of the 3,300 km2 the fate of many wildlife species that mineable zone to offset the damage are an important part of Alberta’s, done by the mining. The draft and indeed Canada’s, natural heritage. Mineable Oil Sands Strategy states,

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 33 Conclusion

The current development trajectory is It is clear that Albertans would never at odds with public values. According support the idea of treating the entire to a poll released by the Alberta Forest boreal forest underlain by oil sands (an Products Association in 2006, 84% area the size of Florida) as a “write-off” of Albertans believe that “Access and area, yet this appears to be the implicit use of forests should be based firstly objective of Alberta’s oil sands strategy. on preserving and protecting the Changes to the current development environment and sustaining wild life trajectory will need to be made if the habitat at the expense of sustained government is to meet its commitments economic benefits and jobs.”89 This to sustainable management of our same poll also found that only 23% of forests and the maintenance of Albertans believe that the oil and gas biodiversity. Fortunately, as shown in industry is doing a good job minimizing this report, solutions do exist – though impacts in the forest and 67% do the window of opportunity is narrow. not believe that the oil industry is A top priority is to develop a long-term accountable in how it uses forest lands. plan for the region that defines where In short, the petroleum sector is not and when development is allowed to meeting the terms of its social licence to proceed, along with ecological access resources on public lands. thresholds limiting the intensity of development in any given area. The plan Provincial Land Use Planning and Biodiversity Strategy should also define where new protected areas are to be established. As illustrated in Fig. 22, changes to land use policy will provide greater Protected Areas (Conservation Offsets) benefits than operational-level integrated landscape management or best practices and should therefore be given the greatest attention. Given Cumulative Impact Limits the current symptoms of environmental degradation and projected impacts under a business-as-usual approach, no new oil sands leases should be Integrated Landscape awarded or developments approved Management until this planning is complete.

Best Practices FIGURE 22: Summary of strategies for addressing the environmental effects of SAGD development, showing the relative importance of each.

34 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE Endnotes 1 - 46

1 Government of Alberta, Mineable Oil Sands Strategy, draft for 25 OPTI Canada, Application for Commercial Approval, Section B discussion (2005), area calculated by digitizing Fig. 1, p. 3. (2000), p. B1-79. 2 Alberta Energy and Utilities Board, Alberta’s Reserves 2004 and 26 OPTI Canada, Application for Commercial Approval, Section B Supply/Demand Outlook 2005-2014, Report ST98-2005 (2000), p. B1-83. (2005), p. 2-2. Established reserves for the mineable oil sands 27 OPTI Canada, Application for Commercial Approval, Section B are 5.09 billion m3 vs. 22.57 billion m3 for in situ. (2000), p. B1-31. 3 Alberta Energy, Alberta’s Oil Sands (2004), p. 1. 28 OPTI Canada, Application for Commercial Approval, Section B 4 Project overview available at www.longlake.ca. (2000), p. B1-31. 5 All disturbance data for the OPTI-Nexen Long Lake Case 29 Alberta Energy and Utilities Board, Alberta’s Reserves 2004 and study were obtained from the OPTI Canada Application for Supply/Demand Outlook 2005–2014, Report ST98-2005 Approval and Environmental Impact Assessment 2000, approved (2005), p. 2-2. by the Alberta Government. Through application amendments and innovation, OPTI-Nexen are working to reduce these 30 Alberta Energy and Utilities Board, Alberta’s Reserves 2004 and impacts by implementing best practices and alternative Supply/Demand Outlook 2005–2014, Report ST98-2005 engineering approaches. Innovations include implementing a (2005), p. 2-2. mega-pad concept to reduce the requirement for the number 31 OPTI Canada, Application for Commercial Approval, Section B of well pads, narrower seismic technologies and strategies to (2000), p. B1-6. Stated project area equals 41 sections, which reduce water use (Michael Burt personal communication). converts to 10,600 ha. More information about amendments to the Long Lake project is available at www.longlake.ca. 32 OPTI Canada, Application for Commercial Approval, Section G (2000), p. G1-18. 6 OPTI Canada, Application for Commercial Approval, Section B (2000), p. B1-22. 33 Examples: Petro-Canada, MacKay River Expansion Project Environmental Impact Assessment Report (2005); Rio Alto 7 Alberta Energy and Utilities Board, Alberta’s Reserves 2004 and Exploration Ltd., Kirby Project, Application for Approval Supply/Demand Outlook 2005–2014, Report ST98-2005 (2002); Deer Creek Energy Limited, Josyln SAGD Project – (2005), Fig. 2.3, p. 2-6. Phase 2 Application for Approval (2003); Devon Oil, Jackfish 8 OPTI Canada, Application for Commercial Approval, Section Project, Application for Approval (2004). C1.6 (2000), Fig. C1.6-A1, Attachment C1.6.A. 34 OPTI Canada, Application for Commercial Approval, Section G 9 Government of Alberta, Exploration Regulation, AR 214/98, (2000), p. G1-16 and Project and EIA Summary (2000), sec. 43 (1998), www.gov.ab.ca/qp/ p. 26-27. 10 OPTI Canada, Application for Commercial Approval, Section G 35 OPTI Canada, Application for Commercial Approval, Section G (2000), p. G1-18. (2000), p. G4-16. Total length of rights-of-way (roads, pipelines, power lines) is 339 km on 10,600 ha = 3.2 km/km2. 11 OPTI Canada, Application for Commercial Approval, Section B (2000), p. B1-37. 36 Alberta Energy, Oil Sands Agreements (2005), www.energy.gov.ab.ca. 12 OPTI Canada, Application for Commercial Approval, Section C1.6 (2000), p. C1.6-33. 37 Simon J. Dyer, Jack P. O’Neill, Shawn M. Wasel and Stan Boutin, Avoidance of industrial development by woodland 13 OPTI Canada, Application for Commercial Approval, Project caribou, J. Wildl. Manage. 2001, 65:531-542. and EIA Summary (2000), p. 24. 38 D. Burke and E. Nol, Landscape and fragment size effects on 14 OPTI Canada, Application for Commercial Approval, Section reproductive success of forest-breeding birds in Ontario. Ecol. C1.6 (2000), p. C1.6-45. Appl. 2000, 10:1749–1761. 15 OPTI Canada, Application for Commercial Approval, Project 39 Petro-Canada, MacKay River Expansion Project Environmental and EIA Summary (2000), p. 24. Impact Assessment Report, Volume IIC (2005), p 5-42. 16 OPTI Canada, Application for Commercial Approval, Section B 40 OPTI Canada, Application for Commercial Approval, Project (2000), p. B1-34. and EIA Summary (2000), p. 105. 17 Alberta Energy and Utilities Board, Drilling Waste 41 OPTI Canada, Application for Commercial Approval, Project Management, Directive 050 (1996). and EIA Summary (2000), p. 91. 18 OPTI Canada, Application for Commercial Approval, Project 42 OPTI Canada, Application for Commercial Approval, Project and EIA Summary (2000), p. 58. and EIA Summary (2000), p. 103. 19 OPTI Canada, Application for Commercial Approval, Project 43 Elston Dzus, Status of the Woodland Caribou (Rangifer tarandus and EIA Summary (2000), p. 84. caribou) in Alberta. Alberta Wildlife Status Report No. 30 (2001). 20 OPTI Canada, Application for Commercial Approval, Section B (2000), p. B1-18. 44 Simon J. Dyer, Jack P. O’Neill, Shawn M. Wasel and Stan Boutin, Avoidance of industrial development by woodland 21 OPTI Canada, Application for Commercial Approval, Section B caribou, J. Wildl. Manage. 2001, 65: 531-542. (2000), p. B1-40. 45 Simon J.Dyer, Jack P. O’Neill, Shawn M. Wasel and Stan 22 OPTI Canada, Application for Commercial Approval, Project Boutin, Quantifying barrier effects of roads and seismic lines on and EIA Summary (2000), p. 27. movements of female woodland caribou in northeastern Alberta. 23 OPTI Canada, Application for Commercial Approval, Section B Can. J. Zool. 2002, 80:839-845. (2000), p. B1-82. 46 Alberta Woodland Caribou Recovery Team, Alberta Woodland 24 OPTI Canada, Application for Commercial Approval, Section B Caribou Recovery Plan 2004/05-2013/14. (2005). (2000), p. B1-47.

THE PEMBINA INSTITUTE / CPAWS DEATH BY A THOUSAND CUTS 35 Endnotes 47 - 89

47 East Side Range Planning Team, Boreal Caribou Committee, 67 BC Ministry of Agriculture and Lands, Muskwa-Kechika East Side of the Athabasca River Range Plan (2005). Management Plan (1997), http://ilmbwww.gov.bc.ca/ilmb/lup/ lrmp/northern/frtnelsn/app7/toc.html. 48 Richard Schneider, Brad Stelfox, Stan Boutin, and Shawn Wasel, Managing the cumulative impacts of land-uses in the 68 Dehcho Land Use Planning Committee, Western Canadian Sedimentary Basin: A modeling approach. Respect for the Land: The Dehcho Land Use Plan (2005), Cons. Ecol. 2003, 7, issue 1, article 8. www.dehcholands.org/docs.htm. 49 Petr Weclaw and Bob J. Hudson, Simulation of conservation 69 Salmo Consulting Inc., Dehcho Cumulative Effects Study. and management of woodland caribou. Ecol. Model. 2004, Phase 1: Management Indicators and Thresholds (2004), 177:75-94. www.dehcholands.org/docs.htm. 50 Scott Nielsen, Erin Bayne, Jim Schieck, J. Herbers, and 70 Government of Alberta, Alberta’s Commitment to Sustainable Stan Boutin, A new method to estimate species and biodiversity Resource and Environmental Management (1999). intactness using empirically derived reference conditions. Biol. Cons., in review. 71 Alberta Sustainable Resource Development, Chungo Creek Industrial Access Management Information Letter (2005). 51 Steve G. Cumming and Fiona A. Schmiegelow, The Remote www.srd.gov.ab.ca/land/pdf/IL_2005-01_Chungo_Creek.pdf. Areas Project: Landscape and Local Effects of Habitat Structure and Anthropic Disturbance on Boreal Forest Birds, draft 72 Government of Alberta, Mineable Oil Sands Strategy, draft for manuscript. discussion (2005), p. 3. 52 Steve G. Cumming and Fiona A. Schmiegelow, The Remote 73 Sustainable Resource Development, Forest Management Areas Project: Landscape and Local Effects of Habitat Structure Planning Standard (2005). and Anthropic Disturbance on Boreal Forest Birds, draft 74 Don Pope, Land Management Forester, Alberta-Pacific Forest manuscript. Industries, personal communication. 53 Steve G. Cumming and Fiona A. Schmiegelow, from Fig. 5.11 75 Erin Bayne, Steve Van Wilgenburg, Stan Boutin and Keith in Alternative Futures: Alberta’s Boreal Forest at the Crossroads by Hobson, Modeling and field-testing of Ovenbird (Seiurus Richard Schneider (2002), p. 74. aurocapillus) responses to boreal forest dissection by energy sector 54 Dan Woynillowicz, Chris Severson-Baker, and Marlo development at multiple spatial scales. Land. Ecol. 2005, Raynolds, Oil Sands Fever (2005), www.pembina.org. 20:203-216. 55 OPTI Canada, Application for Commercial Approval, Project 76 Phil Lee and Stan Boutin, Persistence and developmental and EIA Summary (2000), p. 79. transition of wide seismic lines in the western boreal plains of Canada, J. Ecol. Mgmt. 2006, 78:240-250. 56 OPTI Canada, Application for Commercial Approval, Project and EIA Summary (2000), p. 109. 77 Petroleum Technology Research Centre, JIVE Project, www.ptrc.ca. 57 Alberta Chamber of Resources, Integrated Landscape Management Brochure (2005). 78 www.e-tenergy.com. 58 Alberta Forest Products Association, Alberta Forest Usage 79 Dave Cheyne, Management Forester, Alberta-Pacific Forest Survey Results (2006), www.yourforest.org. Industries, personal communication. 59 Natural Resources Canada, Tracking Survey of Canadian 80 S. Trombulak and C. Frissell, Review of ecological effects of roads Attitudes towards Natural Resources (1997), www.nrcan.gc.ca. on terrestrial and aquatic communities, Cons. Biol. 2000, 14:18-30. 60 Canadian Parks and Wilderness Society and World Wildlife Fund Canada, Identification of Priority Areas for Protection 81 Canadian Association of Petroleum Producers, Within the Al-Pac Management Area Based on Ecological Evolving Approaches to Minimize the Footprint of the Criteria (2004), www.cpaws-edmonton.org. Canadian Oil and Natural Gas Industry (2004), www.capp.ca/raw.asp?x=1&dt=NTV&e=PDF&dn=81251. 61 Imperial Oil Resources Ventures Limited, Kearl Oil Sands Project Environmental Impact Assessment Report (2005), 82 Canadian Association of Petroleum Producers, Volume 2 p. 2-21. Evolving Approaches to Minimize the Footprint of the Canadian Oil and Natural Gas Industry (2004), 62 Alberta Conservation Association, Unique Partnership Helps www.capp.ca/raw.asp?x=1&dt=NTV&e=PDF&dn=81251. Conserve Northern Forest Habitat (2005), News release dated November 22, 2005. 83 Canadian Association of Petroleum Producers, Evolving Approaches to Minimize the Footprint of the 63 BC Ministry of Agriculture and Lands, Muskwa-Kechika Canadian Oil and Natural Gas Industry (2004), Management Plan (1997), http://ilmbwww.gov.bc.ca/ilmb/lup/ www.capp.ca/raw.asp?x=1&dt=NTV&e=PDF&dn=81251. lrmp/northern/frtnelsn/app7/toc.html. 84 Phil Lee and Stan Boutin, Persistence and developmental 64 Quote from Shira Mulloy, Canadian Association of Petroleum transition of wide seismic lines in the western boreal plains of Producers, found in B.C. Ministry of Sustainable Resource Canada, J. Ecol. Mgmt. 2006, 78:240-250. Management and Ministry of Mines News Release, Pre-tenure Plans Open Muskwa-Kechika to Gas Exploration (2003), 85 East Side Range Planning Team, Boreal Caribou Committee, http://ilmbwww.gov.bc.ca/ilmb/lup/lrmp/northern/mk/news_r East Side Athabasca River Caribou Range Plan (2005). eleases/nr062503.htm. 86 Alberta Biodiversity Monitoring Program, Annual Report 65 Michael Wenig and Michael Quinn, Integrating the Alberta Oil (2004), www.abmp.arc.ab.ca. and Gas Tenure Regime with Landscape Objectives: One Step 87 Canadian Association of Petroleum Producers, Stewardship Towards Managing Cumulative Effects. Proceedings from, Progress Report (2005), www.capp.ca/default.asp?V_DOC_ID Access Management: Policy to Practice, A Conference =763&PubID=97224. Presented by the Alberta Society of Professional Biologists, March 18-19, 2003. 88 Government of Alberta, Strategic Business Plan 2006-09 (2006), p. 22. 66 www.cemaonline.ca. 89 Alberta Forest Products Association, Alberta Forest Usage Survey Results (2006), www.yourforest.org.

36 DEATH BY A THOUSAND CUTS CPAWS / THE PEMBINA INSTITUTE OIL SANDS MINING NORTH OF FORT MCMURRAY, ALBERTA DEEP OIL SANDS EXTRACTION NEAR COLD LAKE, ALBERTA Cuts by a

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