Note: This month's column is titled the "Tyranny of Small Decisions", a term coined by Eugene Odum in consideration of the incremental effects of development on the environment.
How do we go about evaluating the effects of development on the environment? Do we only consider the impacts a single project may have, or should we also consider the combined effects of all other developments? We only have to look around us and see the cumulative effects humans are having on the planet in the form of thinning ozone, global warming and melting polar ice caps, declining fish stocks, pesticide buildup and, as of yet, unknown future ecological disasters.
It was with increasing global environmental awareness at the beginning of the 1970' s that we developed the process of environmental impact assess men t as a means to evaluate the consequences of development projects on the natural and human environment. As our understanding of the natural environment and our ability to alter it through our technology has also grown exponentially in the past 20 years, (although some would argue our ability to destroy the environment far exceeds both our capacity and commitment to save it) we are now faced with the problem of evaluating the complex interactions of our single project decisions.
We are beginning to realize that not only must we evaluate decisions about a particular project, we now must also evaluate all other projects and activities it may be associated with. Not only that, but we also have to consider the effects of past and potentially future projects. Our world continues to grow smaller as our influence grows over it.
I want to focus this month's column on the cumulative effects of oil and gas development in our Province. Table 1 shows the direct extent of oil and gas activity in the province. What I mean by direct is actual surface land disturbance. The total impact of oil and gas activity may be many times greater if cumulative effects are considered.
All in all, the surface disturbance ascribed to the oil and gas industry is small. Detractors of oil and gas development however point to the incremental effects of development. When you add in the effects of increased roads and access, legal and illegal hunting, increased recreational activity, increases in other land uses such as grazing, logging and mining you end up with the sum far exceeding the total of its parts. The result is what is known as cumulative effects, or what has been called the "tyranny of small decisions". 1
It was biologist Eugene Odum that coined this term with respect to environmental degradation, based on the market economic studies of Alfred E. Kahn. Writing in 1982 he said "much of the current confusion and distress surrounding environmental issues can be traced to decisions that were never consciously made, but simply resulted from a series of small decisions".
As witnessed by recent hearings by both the NRCB and ERCB and emerging federal legislation, we see a need to address cumulative effects, but no one is really sure how to go about it. In order to address this need, the Alberta Society of Professional Biologists held a national conference in 1994 on the topic of cumulative effects. Many of the papers at the conference dealt with the oil and gas industry as somewhat ironically many of Alberta's professional biologists are directly or indirectly employed through the business of hydrocarbon extraction.
So what exactly is meant by cumulative effects? In his opening address to the conference, Dr. William Ross of the Faculty of Environmental Design at the University of Calgary referred to it "as an impact on the environment that results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time".2
How do we assess the sum total of all our activities? Where do we draw the line and can we really ascribe actual effects, let alone predict the consequences of their outcomes? How can oil and gas operators assess the impacts of their competitors projects (which may be proprietary), let alone the consequences of all other development? How can this be done given the general lack of environmental information that exists for the province?
Everywhere across the world, where development ventures into wilderness areas, the "first cut is the deepest". Despite our technology to mitigate the effects of oil and gas development, we open up the land base to other developments. Recent hearings into the export of natural gas have seen environmental advocates calling for upstream environmental assessments of the cumulative effects. Yet there have been no suggestions from either government, industry or environmental proponents as to how such an assessment would be done.
In previous columns, I have argued one of the first ways in doing this is to set aside lands free from development (see May 1995, CSEG Recorder). This was the original focus of Special Places 2000 for the Canadian Association of Petroleum Producers. Now the most recent land sale in southern Alberta opens up another 73,000 ha of land to oil and gas exploration and development and its associated effects.
Under existing legislation of the Environmental Protection and Enhancement Act in Alberta, the drilling, construction, operation or reclamation of an oil and gas well is exempt from the requirement of environmental assessment as dictated by the Act. However, it has been argued that the access road associated with the well may well in fact be so.3 In order to clarify this issue in the Eastern Slopes, the ERCB issued Information Letter 93-9 which served to notify oil and gas proponents about the requirements of environmental assessment, including cumulative effects. However, in the Moose Mountain Decision 94-2 (March 12, 1994), the ERCB stated that the methodology and standards for cumulative assessment remain poorly defined and that such an assessment would be premature. The Board wanted to ensure that IL 93-9 was in fact consistent with the Alberta Environmental Protection and Enhancement Act and recognized merit in completing cumulative effects assessments but at the same time recognized the inherent difficulty in who should do them and how they should be conducted.4
The Whaleback Decision didn't shed any further light on the subject of cumulative effects, so oil and gas proponents are no further ahead on what to do regarding cumulative effects and how they should assess other activities in light of their own project. In other words, it is up to the proponent to decide and this decision should be made in the context of surrounding development.
So where does that leave us? I think that upcoming ERCB hearings will have to address cumulative effects particularly where exploratory wells are involved. It is clear that technology can mitigate the direct impacts associated with oil and gas drilling. It is the associated activities that result from increased access, coupled with the pace of industrial, recreational and agricultural development outside of the oil and gas industry that have a much larger impact. Should the oil and gas industry bear the brunt of this when other activities are not subject to a similar process of evaluation?
Here are some suggestions I have as to how we should go about addressing the issue of cumulative effects:
- We need to plan resource development on a truly regional basis that allows for both protected areas and areas for development. This should include establishment of social thresholds for acceptable limits of development. This should be communicated in advance to oil and gas companies. Oil and gas proponents should undertake regional evaluations in concert with other resource interests.
- Protected areas should be off limits to development. We cannot continue the multiple use mentality and maintain ecological integrity in the province. CAPP has been a clear supporter of this process in relation to Special Places. Clearly now is the time to ensure that oil and gas development won't occur in areas currently under legislated protection such as the Willmore Wilderness Area.
- We need a regional information base for assessing cumulative effects. With declining government budgets, this has also to be supported by the private sector.
- Other developments such as forestry, agriculture and recreation must also consider cumulative effects and have similar environmental assessment procedures as those guiding the oil and gas industry. There must be less discretion from the Ministry of Environmental Protection as to when and when not an EIA is required.
- Oil and gas development should be viewed as a temporary intrusion on the environment, which after 40 years will be removed. Proponents must consider life cycle management in this regard.
- Oil and gas proponents should be allowed to maintain access controls in all cases. This is important in limiting cumulative effects associated with access.
- We need to develop models for the assessment of cumulative effects that are practical and of use to decision makers.
Today in 1995, the words of Odum still ring true. "Few politicians, planners, or scientists have been trained with, or have developed a truly holistic perspective. Considering all of the pressures and short term rewards that guide society towards simple solutions, it seems safe to assume that the tyranny of small decisions will be an integral part of environmental policy for a long time to come".
|Table 1: Oil and Gas Activity in Alberta|
|Source: ERCB 1995 File Data: Alberta Environmental Protection: Alberta State of the Environment Comprehensive Report|
|Producing Gas Wells||33,620|
|Producing Oil Wells||32,745|
|Suspended Oil and Gas Wells||13.945|
|TOTAL OIL AND GAS WELLS||80,310 – may be up to 120,000|
|Total Land Disturbance of Oil and Gas Wells||120,000 ha – bases on an average of 1 ha per wellsite|
|Access roads||40,000 km + (based on conservative average of 0.5 km per well)|
|Multi Well Oil Batteries||1,835|
|Gas Plants||698 (436 sweet; 265 sour)|
|Seismic Lines (1986-1992)||300,000 km|
I thank Roger Creasey of the Energy Resources Conservation Board for his thoughts on this column.
1See W.E. Odum. Environmental Degradation and the Tyranny of Small Decisions. Bioscience Vol. 32. No.9. pp 728-729. 1982.
2See W.A. Ross. Assessing Cumulative Environmental Effects: Both Impossible and Essential. pp 3-9. In AJ. Kennedy Editor: Cumulative Effects Assessment in Canada: From Concept to Practice. Paper from the Fifteenth Symposium held by the Alberta Society of Professional Biologists, Calgary, 1994. Interested readers can obtain a copy from the ASPB office in Edmonton by calling (403)434-5765. A cumulative effects home page can also be found on the internet at http://www.rr.ualberta.caUmorgant/index.html.
3 See H. Locke. Assessing the Public Interest: Environmental Impact Assessments, Cumulative Effects Assessments and Regulatory Decision-Making. pp. 303-317. In AJ. Kennedy Editor: Cumulative Effects Assessment in Canada: From Concept to Practice. Paper from the Fifteenth Symposium held by the Alberta Society of Professional Biologists, Calgary, 1994.