SUBMISSIONS of the OIL SANDS ENVIRONMENTAL COALITION and APPENDICES to WRITTEN SUBMISSIONS AUGUST 31, 2018 ______
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IN THE MATTER OF THE RESPONSIBLE ENERGY DEVELOPMENT ACT Statutes of Alberta, 2012, C. R-17.3; AND THE OIL SANDS CONSERVATION ACT, R.S.A. 2000, C. 0-7 Section 10 and 11 and Sections 3, 24, and 26 of the Oil Sands Conservation Rules, Alberta Regulation 76/88; AND IN THE MATTER OF THE CANADIAN ENVIRONMENTAL ASSESSMENT ACT, 2012, SC 2012, c 19, s 52; AND IN THE MATTER OF A JOINT PANEL REVIEW BY THE ALBERTA ENERGY REGULATOR AND THE GOVERNMENT OF CANADA, REGARDING: FRONTIER OIL SANDS MINE PROJECT TECK RESOURCES LIMITED; CEAR Reference No.: 65505 AER Application No. 1709793 ______________________________________________________________________________ Volume 1 of 10 SUBMISSIONS OF THE OIL SANDS ENVIRONMENTAL COALITION and APPENDICES TO WRITTEN SUBMISSIONS AUGUST 31, 2018 ______________________________________________________________________________ Submitted To: Submitted By: Joint Review Panel Secretariat Ecojustice Canada Society 800, 744 – 4th Avenue SW Canadian Environmental Assessment Agency Calgary, AB T2P 3T4 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 Attention Kurt W. Stilwell & Barry K. Robinson Tel.: 1-866-582-1884 Fax: 613-957-0941 Phone: 403 705-0202 E-mail: [email protected] [email protected] 1 TAB DOCUMENT PAGE NO. Volume 1 Submissions by the Oil Sands Environmental Coalition And Appendices to Written Submissions Submission by the Oil Sands Environmental Coalition 1 APPENDICES TO WRITTEN SUBMISSION 1 Curriculum vitae of Dr. Chris Joseph 35 2 Report of Dr. Chris Joseph: Teck Frontier Mine: Review of Economic 44 Benefits and Cost-Benefit Analysis 3 Curriculum vitae of Jan Gorski 127 4 Report of Jan Gorski: Frontier Oil Sands Mine Project: Review of 128 greenhouse gas emissions 5 Curriculum vitae of Jodi McNeill 160 6 Curriculum vitae of Nina Lothian 162 7 Report of Jodi McNeill and Nina Lothian: Frontier Oil Sands Mine 166 Project: Review of liability management and financial security options 8 Curriculum vitae of Simon Dyer 190 Volume 2 Submissions by the Oil Sands Environmental Coalition Selected References from Frontier Oil Sands Mine Project: Review of greenhouse gas emissions and climate change commitments 9 Environment and Climate Change Canada, National Inventory Report 192 1990-2016: Greenhouse Gas Sources and Sinks in Canada, (Ottawa: 2018) 1 10 Government of Alberta, “Standard for Establishing and Assigning 208 Benchmarks V2.1 Carbon Competitiveness Incentive Regulation,” (Edmonton: June 2018) 11 Government of Alberta, “Total Oil Sands Production”, accessed online at: 259 http://osip.alberta.ca/library/Dataset/Details/46 12 Government of Alberta, “Capping oil sands emissions,” accessed online 260 at: https://www.alberta.ca/climate-oilsands-emissions.aspx (15 August 2018) 13 Excerpt from J. David Hughes, Canada’s Energy Outlook: Current 263 Realities and Implications for a Carbon-Constrained Future, (Vancouver: Canadian Centre for Policy Alternatives, 2018) Volume 3 Submissions by the Oil Sands Environmental Coalition Selected References from Frontier Oil Sands Mine Project: Review of greenhouse gas emissions and climate change commitments Cont. 14 Dinara Millington, Canadian Oil Sands Supply Costs and Development 284 Projects (2018-2038), Study No. 170 (Calgary: Canadian Energy Research Institute, 2018) 15 Experience Nduagu, Economic Potentials and Efficiencies of Oil Sands 355 Operations: Processes and Technologies, Study No. 164 (Calgary: Canadian Energy Research Institute, 2017) 16 Oil Sands Advisory Group, “Recommendations on Implementation of the 485 Oil Sands Emissions Limit Established by the Alberta Climate Leadership Plan (“ACLP”)”, (Edmonton: May 8, 2017) Volume 4 Submissions by the Oil Sands Environmental Coalition Selected References from Frontier Oil Sands Mine Project: Review of greenhouse gas emissions and climate change commitments Cont. 17 Environment and Climate Change Canada, Technical Paper on the 520 Federal Carbon Pricing Backstop, (Gatineau: 2017) 18 Environment and Climate Change Canada, Canada’s Mid-Century Long- 542 Term Low-Greenhouse Gas Development Strategy, (Gatineau: 2016) 2 19 Environment and Climate Change Canada, Canada’s Seventh National 633 Communication on Climate Change and Third Biennial Report, (Gatineau: 2017) 20 Environment and Climate Change Canada, Progress towards Canada’s 949 greenhouse gas emissions reduction target, (Gatineau: 2018) 21 Sonia Yeh et al, “Land Use Greenhouse Gas Emissions from 961 Conventional Oil Production and Oil Sands,” (2010) 44 Enviro. Sci. Tech 22 Statistics Canada, Report on Energy Supply and Demand in Canada, 2016 993 Preliminary (Ottawa, 2018) Volume 5 Submissions by the Oil Sands Environmental Coalition Selected references from Frontier Oil Sands Mine Project: Review of liability management and financial security options 23 Dalmia, Avinash, “Analysis of naphthenic acids in filtered oil sands 1126 process water (OSPW) using LC/TOF with no sample preparation” (2013) Perkin Elmer: Application Note 24 Grewer DM et al., “Naphthenic acids and other acid-extractables in water 1131 samples from Alberta: What is being measured?” (2010) Science of the Total Environment. doi:10.1016/j.scitotenv.2010.08.013 25 Alberta Environment and Parks, Oil Sands Information Portal, “Regional 1145 Totals for Reclamation and Disturbance Tracking, by Year” (2016), online at http://osip.alberta.ca/library/Dataset/Details/27 26 Auditor General of British Columbia, An Audit of Compliance and 1146 Enforcement of the Mining Sector, (Victoria: 2016) 27 Auditor General of Alberta, Report of the Auditor General of Alberta, 1255 (Edmonton: July 2015) Volume 6 Submissions by the Oil Sands Environmental Coalition Selected references from Frontier Oil Sands Mine Project: Review of liability management and financial security options Cont. 28 Alberta Energy Regulator, “Mine Financial Security Program – Security 1373 and Liability”, (Calgary: September 2017) 3 29 Branko Bošković and Andrew Leach, “Leave It in the Ground? 1374 Incorporating the Social Cost of Carbon into Oil Sands Development”, (2017) University of Alberta School of Business Research Paper No. 2920341. 30 Excerpt from Canada’s Ecofiscal Commission, Responsible Risk: How 1406 putting a price on environmental risk makes disasters less likely, (Ottawa: 2018). Volume 7 Submissions by the Oil Sands Environmental Coalition Selected references from submissions of Simon Dyer 31 Alberta Environment, Regional Sustainable Development Strategy for the 1500 Athabasca Oil Sands Area, (Edmonton: 1999) 32 Joint Review Panel for the Jackpine Mine Expansion Project, Report of 2013 the Joint Review Panel, Shell Canada Energy Jackpine Mine Expansion Project, 2013 ABAER 011 Volume 8 Submissions by the Oil Sands Environmental Coalition Selected references from submissions of Simon Dyer Cont. 33.1 Government of Alberta, Lower Athabasca Regional Plan, 2012-2022 1985 (Edmonton: 2012) – Part 1 Volume 9 Submissions by the Oil Sands Environmental Coalition Selected references from submissions of Simon Dyer Cont. 33.2 Government of Alberta, Lower Athabasca Regional Plan, 2012-2022 2022 (Edmonton: 2012) – Part 2 Volume 10 Submissions by the Oil Sands Environmental Coalition Selected references from submissions of Simon Dyer Cont. 34 Environment Canada, Recovery Strategy for the Woodland Caribou 2082 (Rangifer tarandus caribou), Boreal population, in Canada (Ottawa: 2012) 4 0001 IN THE MATTER OF THE RESPONSIBLE ENERGY DEVELOPMENT ACT Statutes of Alberta, 2012, C. R-17.3; AND THE OIL SANDS CONSERVATION ACT, R.S.A. 2000, C. 0-7 Section 10 and 11 and Sections 3, 24, and 26 of the Oil Sands Conservation Rules, Alberta Regulation 76/88; AND IN THE MATTER OF THE CANADIAN ENVIRONMENTAL ASSESSMENT ACT, 2012, SC 2012, c 19, s 52; AND IN THE MATTER OF A JOINT PANEL REVIEW BY THE ALBERTA ENERGY REGULATOR AND THE GOVERNMENT OF CANADA, REGARDING: FRONTIER OIL SANDS MINE PROJECT TECK RESOURCES LIMITED; CEAR Reference No. 65505 AER Application No. 1709793 SUBMISSION BY THE OIL SANDS ENVIRONMENTAL COALITION AUGUST 31, 2018 ______________________________________________________________________________ Submitted To: Submitted By: Joint Review Panel Secretariat Oil Sands Environmental Coalition c/o Ecojustice Canada Canadian Environmental Assessment Agency 800, 744 – 4th Avenue SW 160 Elgin Street, 22nd Floor Calgary, AB T2P 3T4 Ottawa, ON K1A 0H3 Attention Kurt W. Stilwell & Tel.: 1-866-582-1884 Barry K. Robinson Fax: 613-957-0941 Counsel to Oil Sands Environmental Coalition Phone: 403 705-0202 E-mail: [email protected] [email protected] 0002 Table of Contents DESCRIPTION OF INTERVENORS ................................................................................ 1 NATURE AND SCOPE OF OSEC’S INTENDED PARTICIPATION ........................... 8 REQUESTED DISPOSITION ............................................................................................. 8 CONDITIONS REQUESTED ............................................................................................ 10 COST-BENEFIT ANALYSIS OF THE PROJECT ........................................................ 12 GREENHOUSE GAS EMISSIONS OF THE PROJECT ............................................... 16 I Teck has underestimated the GHG emissions from the Project. ....................................... 17 II The Project’s GHG emissions intensity will not be best-in-class. .................................... 18 III Teck has underestimated the cost of compliance within the 100 Mt GHG limit. ............. 18 IV Teck has underestimated the cost of compliance with the Carbon