The Honourable Stephen Harper
Office of the Prime Minister
80 Wellington Street
Ottawa, ON K1A 0A2
The Honourable Ed Stelmach
Premier of Alberta
Room 307, Legislature Building
10800 – 97th Avenue
Edmonton, AB T5K 2B6
RE: Alberta Oil Sands Pollution Exceeding Industry Estimates
It has been brought to our attention that pollution from Alberta’s oil sands is far worse and widespread than we had all originally thought. We are very concerned not only with the oil sands operations and environmental effects they will cause, but also with the government’s lack of serious attitude and action towards protecting the environment and human health from this industry. We would like to take this opportunity to highlight the following particular concerns, which have come to light as the result of an independent study published in early December 2009.
1. Pollution Concerns
Concerns regarding the pollution caused by Alberta’s oil sands operations and their negative environmental consequences are hardly new. What is particularly troubling is that the recent study on the effects of oil sands development suggests that this pollution is nearly five times greater than and twice as widespread as industry figures say.
The oil sands industry is a known source of air pollutants and snow surveys as early as 1978 and 1981 identified elevated metal deposits within 10-25 km of Suncor and Syncrude facilities. From 2005 to 2007, mean annual releases of particulates measured by Suncor and estimated by Syncrude were 6037 +/- 927 T. During the 4 months before the independent study’s sampling in 2008, emissions were almost twice that and contaminated an area nearly twice as large. Assuming similar deposition rates during the year means that a total annual particulate deposition of 34,000 T is taking place. This is nearly five times current reported emission levels.
The close association of deposition with proximity to the upgrading facilities suggests that those facilities are the primary source of the pollution. The research team monitored water and snow pack concentrations of pollutants along the Athabasca and several of its tributaries in winter and summer of 2008. The monitoring found that petrochemical concentrations in the water did not increase until the streams flowed past oil sands facilities, particularly new construction.
Airborne polycyclic aromatic compounds (“PAC”) from oil sands development are also known to place a considerable burden on watersheds. The study found that the estimated annual release of PAC into the Athabasca watershed means that the toxic emissions from the oil sands operations are equal to those that would be present if a major oil spill occurred every year. Levels of PAC increased the closer the researchers got to the oil sands developments and even reached a point where the deposits were enough to form oil slicks on top of melted snow. The study states that “The increased deposition of particulates and PAC in snow close to the Suncor and Syncrude upgrading facilities clearly implicates them as sources.”
This latest study is only one of many that has questioned official figures put forth by industry and government and that has pointed out the oil sands industry’s true environmental costs. The new study joins a growing pile of research on the oil sands industry’s environmental impact, including the following findings:
- Up to 11 million litres of contaminated water a day is leaking from tailings ponds that are associated with the oil sands industry.
- Greenhouse gas emissions from the oil sands are being underestimated by nearly a quarter because official estimates fail to include carbon released from disturbed forests or peatlands.
- Oil sands mines, roads and other facilities in the area are destroying so much bird habitat that up to 166 million fewer songbirds could be flying North American skies within 50 years.
2. Monitoring Program Shortfalls
Both the provincial and federal governments are responsible for ensuring that development does not harm the environment or human health. However, Edmonton and Ottawa have largely chosen to “outsource” monitoring of oil sands development to the industry itself. This is a dereliction of the governments’ duty to protect the environment and human health and industry cannot be trusted with such a volatile matter.
The underestimation of pollution and other concerns by industry clearly shows that allowing self-monitoring in this field is unacceptable and entirely ineffective. However, Alberta’s monitoring program, the Regional Aquatic Monitoring Program (“RAMP”) also suffers from a variety of serious defects. For starters, over 10 years of inconsistent sampling design, inadequate statistical power and monitoring-insensitive responses have missed major sources of contamination to the Athabasca watershed. While government and industry officials say contamination in the area’s soil and rivers is natural, the new study firmly links the contamination to oil sands operations.
The failure of RAMP is not surprising when you consider its underlying problems – it is funded by industry, has no scientific oversight, the data are not publicly available and the methods used to analyze, interpret and report the data are not transparent. The ability of RAMP to detect effects was already the subject of severe criticism in a 2004 peer review. Despite this review, nothing has changed in the province’s monitoring program in almost six years.
Lack of concern and efforts by the Federal Government to adequately monitor the situation is also problematic. By way of illustration, the independent study took measurements at 60 locations along the Athabasca and its tributaries. The Federal Government, however, currently operates only one water quality collection point in the area. Again, it is not surprising that the monitoring programs in place and the independent study came up with different results.
3. Health Concerns
The new study does not make any conclusions regarding health implications for communities that are downstream from oil sands operations. However, it is worth keeping in mind that residents of one downstream community, Fort Chipewyan, have long complained of extremely high cancer rates.
The study also points out that there are already enough pollutants in the water to be toxic to some fish embryos. Furthermore, these compounds do not break down over time, but rather gradually accumulate wherever they land. This means that during the snowmelt in spring, PAC concentrations in the Athabasca tributaries could increase to levels that are toxic to both aquatic and terrestrial organisms.
The report’s main conclusion is clear: “The oil sands industry is a far greater source of regional PAC contamination than previously realized.” More confirmation that Alberta’s oil sands pose one of the largest ecological challenges in North America’s history. Rapid and unconstrained growth of oil sands development and production will result in increased GHG emissions; unsustainable water allocations and damage to the Athabasca watershed; and irreversible damage to Boreal Forest ecosystems and the corresponding loss of one of the last wild places on Earth.
Despite the above reports and the inevitable effects of oil sands development, the Federal Government and Government of Alberta have decided to allow this industry flourish and continue to assert that human health and the environment are not at risk. We are writing this letter to say that you cannot dismiss the environmental and human health impacts of oil sands operations.
We are also writing this letter to say that if governments refuse to put in a serious effort to studying the effects of this industry, they should at least be listening to the independent researchers who do put in the work, and heed their advice. This means making major changes to the way that environmental impacts of oil sands development are monitored and managed. For starters, the existing RAMP must be redesigned with more scientific, technical and independent oversight. This will make better use of monitoring resources and ensure that data are available for independent scrutiny and analyses. Then it will be incumbent upon government to act to protect human health and the environment based upon sound monitoring systems.
Sarah Newton, President
North Columbia Environmental Society
Cc: MP Jim Abbott
MP Jim Prentice (Environment Minister)
MP Linda Duncan (NDP Environment Critic)
MP David McGuinty (Liberal Environment Critic)
MLA Kevin Taft (Alberta Liberal Energy Critic)
MLA Rob Renner (Alberta Environment Minister)
MLA Laurie Blakeman (Alberta Liberal Environment Critic)
 E. Kelly, J. Short, D. Schindler, et al., “Oil sands development contributes polycyclic aromatic compounds to the Athabasca River and its tributaries” in Proceedings of the National Academy of Sciences of the United States of America vol. 106:22346-22351 (December 7, 2009).