Wednesday 10 November 2010

Reaction to Alberta Party Environment Policy, Part 1

Thoughtful analysis of policy takes time and I'm having trouble finding that in the aftermath of the Nenshi campaign. I'll start by sharing my reactions to Alberta Party draft policy to get the discussion going.
Be it resolved that the Alberta Party views the oil sands as a primary engine of Alberta’s economy. Alberta must optimize the return from our resource-based industries and protect our environment.
Key directions:
• Make eliminating and reclaiming tailing ponds a top priority
• Effectively and consistently enforce existing regulations
• Help industry find new ways to reduce its demand for fresh water
• Ensure regulators have full independence and are empowered to act
• Provide resource industries with clear, consistent and accountable direction
• Don’t wait for an environmental crisis to be more proactive with enforcement

The key directions are not inspiring - I think the Pembina Institute could do better. By drafting Directive 074, the Alberta Government has already made tailings ponds a top priority. In fact, industry has never really liked them either - they have been researching cost effective ways to deal with tailings since the oil sands began. When I worked at Syncrude, the chatter - even in the Upgrader - was always on the latest in tailings research. Eliminating and even reducing the volume of tailings ponds is no simple matter. This article in Engineering and Mining Journal outlines some of the work that is underway: http://www.e-mj.com/index.php/features/592-oil-sands-operators.html . Bottom line: eliminating and reclaiming tailings ponds is an extreme goal at this point in time. I recommend a change to "Reduce the volume of tailings ponds"

The second point seems to suggest that existing regulations are not effectively and consistently enforced, while not suggesting how a change in that regard might be accomplished. While enforcement is never perfect, I wouldn't say it is lacking.

Helping industry reduce demand for fresh water misses the crux of the problem. Industry currently has less than 10% of Alberta's fresh water allocations. The in-situ oil sands industry is already required to avoid the use of fresh water whenever possible. In fact, Alberta is only water short in the South Saskatchewan River basin. The primary use of water in Alberta is agriculture. While I recognize we can't always count on mother nature to water the crops, there are significant improvements that could be made in how water is used for agriculture. Invest in more effective sprinklers, and use them at night, for example. Let's get some focus on water use in agriculture. Maybe the policy should read: Enable agriculture sector to implement best available technology and practices to minimize fresh water use. Help the farmers, not the oil barons.
Link to Alberta water allocation chart: http://environment.alberta.ca/images/image235.png

Ensuring regulators have full independence and are empowered to act? Have you worked with the rogue ERCB? Or does this refer to a need for more funding to Alberta Environment specifically for enforcement? If I were writing the policy I would focus more on addressing the balance of power between departments of Energy, Environment, and Sustainable Resource Development. They currently spend some time on turf battles. This is understandable given their sometimes competing mandates but well worth addressing to the extent possible.

Next we come to a point I completely agree with: Give resource industries clear, consistent, and accountable direction.  This makes a lot of sense given all of the messing around that has gone on with respect to royalties and water policy. Add this to the list on economic policy too.

The final key direction on this list doesn't strike me as a key direction. Perhaps it could be reworded and combined with the second point. Something like: Be proactive, effective, and consistent with enforcement of regulations to avoid environmental crises.

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