How can some cut seismic lines and a few thousand wells create concern that is even worth serious discussion? These activities, when looked at closer, are of considerable magnitude in just the province of Alberta alone. Between 1986 and 1992, in Alberta's "Green Area" (generally not settled and usually forested), almost 300,000 kilometres of seismic line were cut totalling some 1400 square kilometres of disturbed land. By 1992, in all of Alberta, there were approximately 54,000 active oil and gas wells, 35,000 suspended wells and 73,000 abandoned wells which had cumulatively disturbed over 160,000 hectares of land. Seismic cutlines and thousands of wells create quite a potential environmental problem.
The above activities affect the environment that includes various aspects of the planet which relate to: air, land, water and all the organic, inorganic and living organisms and interacting natural systems they encompass. In other words, just about everything on this earth that we use and can change or modify can be considered the environment.
What mechanisms and standards are there to control the above issues and are of concern to geophysical operations? As mentioned in previous articles on this page, there are two major governmental acts which direct activities in Alberta that come under the broad heading of "The Environment". The topic of this article concerns Alberta and will briefly cover the Alberta Environmental Protection and Enhancement Act (the Act), better known by its acronym AEPEA. The other Act or Law that the geophysical industry must be aware of, that pertains to the environment, is the federal Canadian Environmental Protection Act or CEPA.
The CEPA and the AEPEA cover most of the environmental rules and regulations that geophysical operators must and should follow when operating field programs in the province of Alberta. Other provinces have to adhere to the federal Act as well as their own, or soon to be their own, Acts that govern activities involving the environment in their particular province.
After almost three years of meetings, discussions, comments from industry and the public, reports, panels and task forces by joint government, industry and public groups, proposed environmental legislation known as Bill 23, was given third reading in the Alberta Legislature and Royal Assent on June 26, 1992. The Act, now known as AEPEA, was proclaimed and came into force on September 1, 1993.
This Act replaced the following eight former Acts, they were the: Clean Air Act; Clean Water Act; Land Surface Conservation and Reclamation Act; Hazardous Chemicals Act; Ground Water Development Act; Litter Act; Agricultural Chemicals Act and the Beverage Container Act.
AEPEA stresses several main features: Firstly - Public Involvement in things like the "Environmental Review Process", the "Approval Process", "Access to Environmental Information" and "Involvement in Enforcement" of the Act. Secondly - Shared Responsibility between the government, industry, scientific experts and ordinary citizens in environmental matters and cooperation between various levels of government. Thirdly - Sustainable Development is a principle and goal to ensure that what is done today to our environment does not affect future generations in any negative way. Fourthly - Polluters Pay is a precept that helps prevent environmental infractions by having polluters pay for any and all damages they may have caused.
These principles can all affect the way we organize, apply for, and run geophysical programs and reclaim sites after the exploration is over.
In Alberta, the government department charged with administering the AEPEA is the Department of Environmental Protection. As of November, 1994, the organisational structure of the Department was as follows:
* E.A.B. = Environmental Appeal Board N.R.C.B. = Natural Resources Conservation Board T.R.M.B. = Tire Recycling Management Board # ADM = Assistant Deputy Minister
Under the Environmental Regulatory Section of Environmental Protection are several agencies that are involved in helping geophysical personnel and contractors in keeping up to environmental standards when applying for field work, doing the actual field programmes and cleaning up or in reclamation of sites. These are the:
ENVIRONMENTAL REGULATORY SERVICES
- ADM's Office
- Finance, Administration and Information Management
POLLUTION CONTROL DIVISION
LAND RECLAMATION DIVISION
- Conservation and Reclamation Review
- Issues Management
- Operations Management
- Field Services
AIR AND WATER APPROVALS DIVISION
- Air Emissions
- Municipal Water and Waste Water
- Industrial Waste Water
ENVIRONMENTAL ASSESSMENT DIVISION
- Environmental Criteria
- EIA Review
- Land Use
- Source Standards
- Regulatory Approvals Centre
CHEMICALS ASSESSMENT & MANAGEMENT DIVISION
- Air Issues and Monitoring
- Contaminated Sites and Decommissioning
- Industrial Wastes
- Ground Water Protection
- Pesticide Management
- Soil Protection
Aside from the Act itself, there are various regulations that govern and spell out the specifics of the Act in more detail. They include the following Regulations that could affect geophysical activities in the oil and gas industry:
ACTIVITIES DESIGNATION REGULATION A. R. 110/93
ENVIRONMENTAL ASSESSMENT (MANDATORY AND EXEMPTED ACTIVITIES) REGULATION - A.R. 111/93
CONSERVATION AND RECLAMATION REGULATION - A.R. 115/93
INDUSTRIAL PLANTS REGULATION - A.R. 121/93 and the
POTABLE WATER REGULATION - A.R. 122/93 In 1994, the AEPEA was amended by the ENVIRONMENTAL PROTECTION AND ENHANCEMENT AMENDMENT ACT. 1994 (Assented to June 1, 1994). This amendment concerns various word changes. administrative details and additions and repeals of wording, some of which pertain to the oil & gas industry in general and exploration in particular.
The Act and it's Regulations and Guidelines are quite specific in their wording and are made such as to avoid or mitigate misunderstanding between the provincial authorities, industry and the public. Of course, this is not always the case in reality. The Act is also constructed so as to be an evolving guide to how government, industry and the public can maintain and protect a quality environment.
If there is any question as to just what can or should be done when planning seismic exploration, drilling, oilfield construction or pipeline laying, the Act and it's Regulations should be reviewed and its relevant sections followed. This will avoid problems later on that could cause, at best, inconvenience, but at worst, result in fines and expenses in redoing work or cleaning any damage done.
As time passes, the AEPEA will change to address areas that may not be a problem today or may be too stringent or onerous on the industry or the public. The idea behind AEPEA is for government to take a leading role in directing other concerned stakeholders in the most efficient and effective methods when dealing with Alberta's environment in order to protect it for future generations, while not having "horse-blinders" on when dealing with the present activities. From looking at the Act's evolution and ideas on changes, there appears to be a trend in modifying the AEPEA to insure it is a better document by making it more definitive, concise and more suitable to the meet the needs of those who are affected by it.
An interesting question arises on the usefulness and need of the AEPEA: Are we better off today with it, or without it as we were a few years ago when there may have been more latitude in how a geophysical program operates in the field? This writer feels that we are far better off today in knowing what the rules are and the consequences of not following them. Dealing with individual landowners, governments and the public in general on matters covered by the AEPEA is, I contend, a better process today than in the past. ("'Better the Devil you know, then the Devil you don't").
The AEPEA Regulations sited above can, like the Act, be purchased from any Alberta Government Publications outlet and are even w011h a review by non-environmental company personnel.