2020 & Beyond – the New Era for

Agriculture and the

Environment

Michelle Cotton, P.Ag.March 25, 2021

WE ARE ALL TREATY PEOPLE

Solstice Environmental team members work and reside in Treaty 6, Treaty 7, and Treaty 8 territories. Out of respect, truth, and reconciliation, we acknowledge that these regions are home to First Nations, Cree, Blackfoot, Nakota Sioux, Dene, Inuit, and Metis peoples, both past and present.

We honour the intimate connection that the First Peoples of Canada share with this traditional territory and wish to further empower the Indigenous sovereignty of land management through a partnership grounded in a mutual respect of the Earth. We believe we have much to learn and share in our desire to protect the natural landscapes and sacred lands that were first cared for by the First Peoples of Canada.

Leaving the 20th Century behind and modernizing our approach to

agriculture and the environment though the integration of traditional

knowledge and western science, and the innovation of process. The

foundational pieces that have held up the premises and basic

assumptions that we use in western science don’t always hold true

leading us to global issues of cumulative effects.

How do we move forward? Technology is only part of the solutions;

real change has to come in how we solve problems and who we let

participate in the process. To move forward in the new era, the

language, economic and environmental behaviours must change,

and the environments impact on health and safety must be

considered.

ABSTRACT

1990-1996

1996-2001

2001-2002

2002-present

SOME CONTEXT: • 1990: AB T1 Criteria (mineral oil and grease 1000 mg/kg)

• ~25,000 inactive wells/~29,000 abandoned wells

• Real remediation & research happening

• Optimistic & excited to clean sites – we are remediating!

• EPEA, C&R regs, Rec Criteria – all come into effect

• Landfilling extravaganza – remediation is too $$, rem

tech from Alberta looks to international op’s

• Don’t worry about the salts…. Or the metals

• OWA replaces the Abandonment Fund

• AEUB introduces the LLRP (Licensee Liability Rating)

• Mandatory PI ESAs, Revised Tier 1 & 2 Criteria, Salt

Guidelines – risk-based numbers starting to happen

• Still landfilling extravaganza

• Rec becomes desktop review & audit system

• Prof sign-off requirements (PI/PII ESAs, rec)

• New AB T1 & T2 Criteria

• ERCB becomes the AER

• ABC becomes a thing

• 2021: Officially more inactive and abandoned wells

than active wells (162,500 vs 168,000)

https://thenarwhal.ca/wp-content/uploads/2019/04/AER-inactive-oil-and-gas-well-growth.png

https://www.alberta.ca/oil-and-gas-liabilities-management.aspx#:~:text=Alberta%20has%20an%20estimated%3A,71%2C000%20abandoned%20wells

https://economicdashboard.alberta.ca/OilPrice

2021: Officially

more inactive and

abandoned wells

than active wells

(162,500 vs

168,000 inactive

& abandoned

wells)

Doesn’t show the cumulative

abandoned wells (>70,000)

Oil Prices Jan 1990 to Jan 2021

Polluter Pays!

• 2008 GoA grants OWA $30M

• Redwater Energy Corp./ATB Case (2016)

• GoA lends $ to OWA x 2 – 2017 = $235 M; 2020 = $100 M

• GoC gives $30 M to OWA (2017)

• GoC grants $1 B to O&G cleanup (2020)

• Who’s paying the lease payments to landowners?

• 2020: New GoA program announced (but not functional) to address the growing O&G liability in Alberta - Liability management Framework to replace the failed LLRP program. The LMF will try to reduce the environmental liability while a company is still financially viable – when it is developed and implemented. Will it come in time to prevent additional taxpayer bailouts of the privately owned oil and gas companies?

(To be fair, O&G liability is not be the only liability that we need to worry about…)

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

Giant Mine, Yellowknife NWT

August 2012

Reclamation Costing (Assessment, Remediation, Reclamation)

• Full-life cycle accounting – environmental liabilities accurately on industries books

• Now in 2021 – How many companies are applying for the SRP funding and the overall cost for assessment, remediation and reclamation of those wellsites is between $16,500 and $42,000?

• OWA isn’t able to stick to these numbers for the work that they are conducting. OWA assessment, remediation, reclamation average costs ? $220 and $300 K/site.

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

Reclamation Liability by Region (D011)

https://static.aer.ca/prd/documents/directives/Directive011_March2015.pdf

Remtech Proceedings: Pat Payne, Oct 2013, What can we learn from Orphan Sites?

Exova Environmental Seminar, Pat Payne, Feb 2013, What have we learned in 10

years?

Ecological Impacts, EIA Impact Ratings - Assumptions and Predictions… I’ve borrowed the following assumptions from Janz (2018)

• Long-term ecological impacts of industrial activities on Alberta’s private and public lands are well known and predictable

• Ecological impacts at private and public lands are minimal and diminish over time

• Public Interests are assured

How often have we gone back and checked these assumptions.?

Here are the predictive evaluation Criteria that we use for Environmental Impact Assessments, do we ever go back and check to see how we did with our predictions. Did we get it right? Or do we keep churning out the same “products” with outdated assumptions – because the risk to our industrial development is too great?

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

It’s Safe, those are the Guidelines, and they’re risk-based…

• Primarily focused on acute and chronic testing in the laboratory, both of which are on relatively short timescales and rely solely on something killing most of the exposed individuals. So, if it kills things after the end of some fixed time period (24 hours, 7 days, etc.), or kills less than 50% of organisms, it doesn’t meet the test criteria for something like an LD50 or LC50 test – it is therefore not “acutely” toxic.

• Similarly, those tests will never identify long-term chronic toxicity effects, either when something like reproductive rates or offspring survival rates reduce because of genetic damage, physiological impacts, etc.

• Or when a toxin bioaccumulates or magnifies so that top predators are impacted despite that the chemical was released in “safe” concentrations and amounts.

• New chemicals are almost always tested individually and not as complex mixtures – antagonistic and synergistic effects are generally not looked at.

Examples

• DDT almost wiping out peregrine falcons because it resulted in thin egg shells – unintentional consequences

• Methyl mercury poisoning of Grassy Narrows First Nations in northern Ontario and residents of the fishing community in Minimata Japan, by industrial polluters

• Acid rain stripping out carbonates from water columns in lakes and killing off all the zooplankton and invertebrates needing the carbonates to build their exoskeletons, resulting in fisheries collapses from

• Round-up is so safe (low toxicity) that you can practically drink it

• Ditching inconvenient data out of the studies – personal example with a herbicide (already approved in the USA)

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

Our guidelines are protective enough of peatlands…

• Are we properly addressing organic soils – shallow and deep organics, peatlands, muskeg, bogs, fens???

• Do our current Alberta Guidelines for Soil and Water properly address these ecosystems.

• Is the toxicity testing and the species used in the guidelines relevant to peatlands?

• Our guidelines say that peatlands are not considered drinking water – up until oil and gas development in the 1970’s indigenous people very much considered peatlands to be drinking water.

• Can we confidently say that the lesions in the animals and on the fish are ‘natural’?

Are our guidelines protective enough for organic soils, and traditional land uses?

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

https://open.alberta.ca/dataset/aa212afe-2916-4be9-8094-42708c950313/resource/157bf66c-370e-4e19-854a-3206991cc3d2/download/albertatier2guidelines-jan10-2019.pdf

https://open.alberta.ca/dataset/842becf6-dc0c-4cc7-8b29-e3f383133ddc/resource/a5cd84a6-5675-4e5b-94b8-0a36887c588b/download/albertatier1guidelines-jan10-2019.pdf

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

General Reductionist Approach

We tend to focus on single impacts rather than the interactions or accumulation of these impacts. We like to look at things in isolation.

Our entire economic and industrial approach to land management results in silos like agriculture, forestry, oil and gas, transportation corridors, etc. and has resulted in completely different restoration guidelines amongst overlapping industries.

Examples

• Drilling waste disposal regulations from ERCB vs AENV Tier 1 & 2 Guidelines

• When a wellsite is in a cut block – completely different standards to restore well sites and cut blocks

• Reviewing EIA’s – kept the review teams in silo’s

(In a non-western approach, these would be combined from the start)

We are Monitoring…

• I used to have so much confidence and feel comforted that we were monitoring things. Monitoring them means we are taking action.

• We monitor gas plants, mines, etc.

• If we are monitoring it, we are doing something? Monitoring isn’t management & more often than not the data sits on a shelf. What happens when things are over threshold? Is action being taken.

• How is the Lower Athabasca Regional Plan going? How are the other Regional Plans the GoA committed to going?

• “We” collect a lot of monitoring data, how are we using that data to ensure the public interests?

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

https://landuse.alberta.ca/RegionalPlans/UpperAthabascaRegion/Pages/default.aspx

Professional Sign-off… protecting and serving the public

• When was the last time that the AER did a subsurface audit on any sites to verify the system is working? The audit results that were done – the ones in 2011 showed that over 25% of the sites failed for various reasons, how was that information used to improve the system. What was the feedback given to the Professionals involved in the sign-off and their Professional Associations?

• A missing piece is that government does not inform the professions, in a timely manner or at all, of members who have demonstrated incompetent and/or unethical work. In these cases, government does not support the mandate of the professions to hold their members to account.

• Collaboration, at an early stage of misconduct, between government and professions is fundamental to ensure that unprofessional conduct is dealt with firmly so that “public interest is truly protected and served”.

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

Food for Thought: Globe & Mail News Article

January 14, 2021

Energy firms misled Alberta regulators on cleanup of well

sites• ~60 wells owned by Aeraden Energy Group had their reclamation

certificates revoked because they were inadequately reclaimed

• A serious case of falsification of documents by the oil company and their

consultant CEPro Energy & Environmental Services Inc.

https://www.theglobeandmail.com/business/article-energy-firms-misled-alberta-regulators-on-cleanup-of-well-sites/

“AER is an independent regulator… Alberta’s

regulatory process is strict, thorough and

independent…”

FOUNDATIONAL PIECES/BASICS ASSUMPTIONS

Jordan Walker, GoA MLA, Facebook Page January 19th 2021https://unitedconservativecaucus.ca/coalhardfacts/

Technology is only part of the solutions; real change has to come in how we solve problems and who we let participate in the process. To move forward in the new era, the language, economic and environmental behaviours must change, and the environments impact on health and safety must be considered.

• Professional Agrologists as keepers of the land, should have a competence requirement on the history of indigenous/crown relations, the history and legacy of residential schools and specific legislation regarding indigenous people in Canada.

• Political innovation and change is as important to success as the latest scientific insights and technical development (Ian Urquhart)

• Incorporate values, and not just look at the economic value of everything

• True full lifecycle accounting.

• We need ecologists and scientists and indigenous people at the table actively involved in the policy and decision making – not just consulted.

• We need to use our extensive monitoring data, and have transparency around the results and the actions required to protect human health, safety & the environment.

• We need to incorporate indigenous land users in the monitoring and oversight that industry and the government are not capable to doing

• We need to use language and communicate in a way that is transparent and assessable to everyone.

GOING FORWARD

THANK YOU FOR THE IDEAS AND THE INPUT

• Ian Urquhart

• Keith Wilson

• Arnold Janz

• William Donahue

• Mathew Wheatley

• David Lloyd

• Mark Carney – Value vs Values

• Many, many others… these are ideas that have evolved over time

Edmonton: PM 2.5 = 170Beijing: PM 2.5 = 30

Michelle Cotton – President/Sr.

Technical Advisor

780-777-9078mcotton@solsticecanada.com

Questions!?

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what we

do!