Who’s in Charge? The Secret Standoff in CFB Suffield by Dr. Shirley Bray, December 2006, Wild Lands Advocate
Thereʼs a story told in Sufﬁeld of the time EnCana drilled a well in a wetland, going against the rules of the Department of National Defence (DND). When DND told them to remove it, EnCana argued about the deﬁnition of a wetland, even though DND had given them clear deﬁnitions and a map. DND gave EnCana a choice – remove the well by a certain date or be barred from the Base. On the eve before the deadline, and after much dithering on the part of EnCana, the company ﬁnally removed the well. DND won that battle, but the question is, why did they have to ﬁght it at all?
The Base Commander has begun to hire staff with environmental and oil and gas industry regulatory expertise in an attempt to address the deﬁciency in stewardship.The current staff of three is overwhelmed, and about a dozen new staff positions are reportedly planned to deal with management, monitoring, and reclamation. Lack of Base capacity to review development applications and monitor industry activity means there is a high level of uncertainty and disagreement about environmental impacts and industry adherence to rules on CFB Sufﬁeld.
The lack of on-site capacity resulted in a situation where Range Safety/SIRC was signing off as landowner on development applications to EUB. SIRC is supposed to be an agent of Alberta, but a Google search for SIRC on the World Wide Web leads immediately to EnCanaʼs website. Is this a situation of the proponent and regulator being one and the same? The current Base Commander is moving to remedy the situation. He is asserting his authority to approve applications to the EUB and conﬁning SIRCʼs role to that of gatekeeper in monitoring movement of industry vehicles on the Base. Affected parties are bristling over this proposed change in practice. Over the last few years, EnCana and other companies have been required to support their development applications with environmental overviews. The rationale by the Base Commander is that these overviews enable more environmentally sound
Staff from the EUBʼs [now ERCB] Medicine Hat ofﬁce conduct routine inspections of drilling rigs and facilities and respond to operational emergencies such as pipeline breaks, spills, and well blowouts. However, due to provincial government downsizing and with such a large amount of industry activity on CFB Sufﬁeld, there is heavy reliance on voluntary compliance.
Spraying drilling waste on native prairie is not allowed on public lands in Alberta. Previously a frequent practice in CFB Suffield, land-spraying while drilling (LWD) is now allowed only on pipeline right of ways. A 2003 study by Alberta Sustainable Resource Development, only recently released, documents significant problems with LWD on native prairie, including high application rates harming vegetation and breeding birds, especially during periods of drought. The study, which used several examples of industry activity in CFB Suffield, also identified major operational issues, including failure of companies to comply with guidelines. A controlled study of LWD using experimental plots on CFB Suffield is currently underway, supported by Agriculture Canada, DND and EnCana. Operational issues related to LWD continue to fester.
Alberta Environment grants water licences under the provincial Water Act to industry operating on CFB Sufﬁeld. Ground or river water is provided for industry and cattle in dugouts. Monitoring and enforcement to ensure the honouring of licensed limits for water extraction are lacking.
• Lack of cumulative effects assessment: The environmental focus is on minimizing and repairing disturbances related to individual sites and there is no monitoring of overall effects on the prairie ecosystem in the long term. The assumption is that gas well densities up to 16 per section are neutral to ecological integrity, which is unfounded
• Degradation of wetlands: A 2000 report commissioned by DND found degradation of developed wetlands and dugouts used by AEC [now Encana and Cenovus] for a water supply. Report authors recommended restoration of developed wetlands, setting limits on water withdrawal by industry, and ensuring that industry activity avoids wetlands. Spills in 2000 and 2003 contaminated wetlands. EnCana is slow in undertaking clean-up and remediation. Despite advice to industry to avoid wetlands, drilling still occurs in or near wetlands.
• Problems with disposal of drilling waste: Problems were identiﬁed in the handling and storing of drill cuttings by industry as recently as 2003. A 2003 audit of remote sumps found four failed EUB criteria for oil content. EnCana is excavating these and attempting to bring them up to standard. A 2003 survey of sites where drilling waste had been spread on native prairie in CFB Sufﬁeld found signiﬁcant problems, but the report of results was suppressed.
• Potential air quality effects on troops: Concerns over potential gas leaks and exposure on troops training on CFB Sufﬁeld.
The End Game
According to SEAC minutes, the Base Commander asked EnCana to restrict its drilling in the Middle Sand Hills and SNWA due to environmental sensitivity and the goal of preserving nature. EnCana responded that the corporation has an obligation to its shareholders to proceed. This statement begs the following questions: Have citizens of Alberta and Canada not already given enough to EnCana and its shareholders? Has the prairie not already suffered enough? By what rationale does EnCana believe it is entitled to free rein in such a signiﬁcant protected area?
The situation on CFB Sufﬁeld provides a microcosm of the challenges that those who want to conserve signiﬁcant natural ecosystems are faced with when industry is given free rein. If the armed forces of Canada cannot deal with it effectively, then it begs another question: who can? [Emphasis added]
[Refer also to: Alberta Landspraying While Drilling (LWD) Review by Alberta Sustainable Resource Development, released three years after completion only because of FOIP and public pressure ]