WHEREAS it appears unlikely that an aquifer will become compromised due to geothermal activity, the potential exists especially with the lack of regulatory coordination in Alberta, and it would be worthwhile to regulate the industry in advance rather than attempt to deal with the ramifications of groundwater contamination.  This is especially relevant when viewed through the cumulative effects lens.

WHEREAS rural municipalities do not want to stifle the development of renewable energy and are also committed to green construction.  In addition, all industrial development should be considered in light of the long-term environmental consequences.

WHEREAS the geothermal industry should be provided with up-to-date, relevant, and holistic standards, regulations and codes.  This will protect industry, consumers, and the environment as this technology becomes more popular in Alberta.

THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties urge the Government of Alberta to conduct more research, provide more education and, where appropriate, introduce regulation (legislation) to ensure geothermal activity is not at the expense of other environmental considerations.

The issue of an unregulated geothermal industry in Alberta has recently been raised to some municipal representatives.  This background information outlines the potential concerns. 

What is geothermal?
The American Environmental Protection Agency (EPA) has stated that “geoexchange” (or geothermal) is the most energy efficient, environmentally clean, and cost-effective space conditioning system available.  Unlike wind and solar resources, geothermal resources are available 24 hours a day, 7 days a week.  There are four main types of ground-heat exchangers:
1. Closed loop – heat exchanged conductively with the Earth from pipes arranged in a closed circuit with a continuously circulating antifreeze solution.
2. Open loop – heat exchanged with water (groundwater, surface water or ocean water) pumped from the Earth to a heat exchanger or heat pump, then returned to a different disposal point.
3. Waste-heat coupling – heat exchanged conductively with a man-made fluid stream (e.g. treated sewage effluent) to a heat exchanger, typically with a secondary loop conveying heat to a load.
4. Hybrid coupling – heat exchanged in combination with another heating or cooling source, or as a crossover between open and closed loop configurations. 
Please note that the last two types are less common than the first two. 

What is the Alberta geothermal context?
The Utilities Consumer Advocate notes that, “any alternative to conventional natural gas space heating in Alberta needs to be assessed on a case-by-case basis.”  This is indicative of the lack of regulation and coordination in the Alberta geothermal context.

Low-temperature, shallow geothermal heating and cooling systems have become increasingly popular for installation in residential and commercial buildings. However, data on the number and kind of installations in Alberta are not available, since the industry is unregulated.  In 2008, there were between 30 and 50 geoexchange installers active in Alberta.  Still, the number of geothermal installations is growing quickly. 

In Alberta, most geoexchange applications are closed-loop systems installed in trenches or shallow boreholes (usually less than 50m deep).  There is the potential for suitable applications of deep vertical borehole systems (greater than 50m deep) for industrial, commercial and larger district residential complexes, or for other specific reasons.

The Government of Alberta references geothermal activity in the Provincial Energy Strategy by noting that Alberta will:
§ Not only support renewable energy development, but promote a market for its consumption.
§ Explore and capitalize on synergies available through innovative integration of energy sources, e.g. geothermal or hydropower in the oil sands.
§ Continue to carefully manage our environmental footprint by respecting limits determined by a cumulative effects approach.
Further, the Provincial Energy Strategy notes that it is in Alberta’s interests to be an aggressive early adoptee of renewable energy to improve the reliability and security of our overall energy supply. 

Likewise, the Energy Resources Conservation Board’s 2009-2012 Business Plan outlines that the ERCB should make an investment into the geological mapping of the geology of geothermal energy.  In an effort to meet its mission, the ERCB also sets out to minimize the potential for environmental damage from energy resource developments and to work with Alberta Environment to protect groundwater. 

However, despite the good intentions of both the ERCB and the Provincial Energy Strategy, very little coordinated work appears to have been done regarding the regulation of the geothermal industry.  The ERCB’s mission is to “ensure that the discovery, development and delivery of Alberta’s energy resources take place in a manner that is fair, responsible and in the public interest.”  If this is to be attained, geothermal development must be addressed in a responsible manner.  The potential environmental issues are addressed below.

What are the potential environmental issues?
Seismic
§ All geothermal operations involve changes in fluid pressure at depth in the earth.  Any such changes in fluid pressure can potentially alter the natural equilibrium of stresses within the uppermost crust to the point where small movements might be triggered along existing fractures.  Exactly the same phenomenon is observed worldwide in other extractive industries (e.g. oil and gas).   The Australian geothermal community (government, academia and industry) has been actively engaged in producing a set of protocols for minimizing seismic risk.  The protocols outline best practice for seismic risk mitigation, and recommend such things as studies to determine the location and orientation of faults prior to any development activities, controlling the water injection rates, and aiming to produce smaller fracture lengths and thus smaller microseismic events.  There was no comparable information found regarding the Alberta geothermal community.

Radon
§ Some recent media reports have reflected community concern over uncontrolled radon gas emissions from geothermal fluids brought to the earth’s surface.  However, radon levels in an unlikely leak from geothermal activity are to be expected to remain lower than acceptable workplace levels.

Water
§ Open loop system – water is taken from a lake or a well, circulated through the heat pump where the temperature is reduced slightly, and then discharged into the same source to complete a cycle.  Industry sources claim that there is no indication that a minor temperature change has any adverse effects on the environment.
§ Closed loop system – the pipe used is a high-density polyethylene plastic that has no environmental impact on the surrounding ground.  It is virtually impossible to destroy a ground loop under normal conditions.  If any fluid does leak before system shutdown, the anti-freeze is (usually) ethanol diluted to 20% of volume, and would have a minimal impact on the surrounding ecosystem.   Further, closed systems do not consume any water.  Geothermal water is injected back into the geothermal reservoir, and separated from groundwater by thickly encased pipes (in the American context – casings are not necessarily required in Alberta), making the facility virtually free of water pollutants. Most geothermal reservoirs are found deep underground, well below groundwater reservoirs.  As a result, these deep reservoirs pose almost no negative impact on water quality and use.
§ Australia – The response to water concerns has been an implementation of both state and federal legislative and regulatory requirements to ensure water resources are used and protected from pollution in an ecologically sustainable manner.  No geothermal project will be allowed to proceed unless it implements the most stringent of protection measures for groundwater aquifers currently relied upon for agricultural or other purposes.
§ United States – No contamination of groundwater has occurred to date as a result of geothermal activity.  A well casing in the US is composed of thick specialized pipe surrounded by cement in order to prevent any contamination as the geothermal fluids are put back into the reservoir.  Certain geothermal activities, such as injection, are regulated by the US Environmental Protection Agency to coincide with the Underground Injection Control Program requirements and the US Bureau of Land Management (BLM) and state well construction requirements.  These federal regulations were instituted with the specific intent of protecting groundwater resources.  BLM Geothermal Resources Operational Order No. 2 and state regulations set guidelines for maintaining wells to prevent blowouts and mandate proper well casing and drilling techniques. 

Based on this research, it appears that the initial concerns regarding Alberta’s groundwater were justified.  While it may be unlikely that groundwater will be contaminated, the chance is there.  Australia has stringent protection measures, and the United States apparently requires the pipe to be surrounded by cement to prevent contamination.  No similar regulatory information was found regarding Alberta.

What is the geothermal industry saying in Canada as a whole?
CSA Standard C448 is a 2-part standard that covers both residential and commercial installations.  The Canadian Geoexchange Coalition (CGC) has implemented standardized designer and installer training and certification programs, and a registry for recording system installations.  The CGC held 7 workshops across Canada in 2009 to discuss weaknesses, anomalies and omissions from current standards related to geothermal.  Some of the comments received include:

§ Additional research is required regarding determination of the impacts that would enable an exhaustive identification of the fluids that have both a low environmental impact and performance properties adapted to geothermal systems.
§ Some consider the issues relating to the risks of contamination are not genuine, while others maintain that protection of groundwater will be an important factor to consider for the future of the geothermal industry.
§ Participants clearly indicated that all substances that circulate within the ground should be regulated (they are not currently, as C448 is vague in this regard).
§ Many participants were in favour of a universal ban of methanol at the national level.  Its toxicity and inflammability and the contamination of groundwater and soil were some reasons cited. 
§ It is of primary importance to establish clear, precise directives on the limits of each party’s responsibility, stating when each one’s responsibility begins and ends.  Some saw a role for municipal inspectors in this matter.
§ The C448 standard is obsolete.  It frequently contradicts other codes, standards or regulations.
§ Supervision is essential to the industry.  In addition, the education of professionals, property owners, etc. is crucial.
§ The drilling footprint is also a major issue.  Environmental protection should outweigh additional costs.
§ Protection of groundwater seems clearly to be a major issue with regard to drilling and with regard to geothermal systems as a whole.  A multitude of questions exist, essentially with regard to cross-contamination of aquifers and control on the surface during drilling.  Several participants pointed out that regulations on protection of groundwater exist in each province, and that industry standards should be harmonized with this regulation.
§ There is a great deal of confusion within the industry with regard to knowledge of the environmental laws appropriate to geothermal systems.

Conclusions:
§ It appears unlikely that an aquifer will become compromised due to geothermal activity.  However, the potential exists especially with the lack of regulatory coordination in Alberta, and it would be worthwhile to regulate the industry in advance rather than attempt to deal with the ramifications of groundwater contamination.  This is especially relevant when viewed through the cumulative effects lens.
§ Rural municipalities do not want to stifle the development of renewable energy.  However, all industrial development should be considered in light of the long-term environmental consequences. 
§ The geothermal industry should be provided with up-to-date, relevant, and holistic standards, regulations and codes.  This will protect industry, consumers, and the environment as this technology becomes more popular in Alberta. 

DOCUMENTS/INFORMATION SOURCES:

Alberta Geothermal Energy Association.  What is Geothermal? Accessed from www.agea.ca.

Canadian GeoExchange Coalition (2010). Codes, Standards and Regulations in the Canadian GeoExchange Industry: Report of a National Consultation Conducted by the Canadian GeoExchange Coalition (Summary). Accessed from www.geo-exchange.ca.

Canadian GeoExchange Coalition.  Environmental Questions.  Accessed from www.geo-exchange.ca.

Driscoll, J. Unearthing the Facts – Geothermal Energy and the Environment.  EcoGeneration May/June 2010. Accessed from http://ecogeneration.com.au/news/unearthing_the_facts_geothermal_energy_and_the_environment/040579/.

Energy Resources Conservation Board. Business Plan 2009-2012. Accessed from http://www.ercb.ca/docs/eubinfo/BusinessPlan_2009-12.pdf.

Energy Resources Conservation Board (2009). Importance of Geoscience Information in the Implementation of Closed-Loop Ground-Source Heat-Pump Systems (Geoexchange) in Alberta.  Accessed from http://www.ags.gov.ab.ca/publications/OFR/PDF/OFR_2009_09.PDF.

Government of Alberta. Provincial Energy Strategy. Accessed from http://www.energy.alberta.ca/Initiatives/strategy.asp.

Grobe, M. & Bechtel, D. Geothermal Energy in Alberta – Opportunities and Challenges.  Accessed from www.geocanada2010.ca/uploads/abstracts_new/view.php?item_id=925.

Kagel, A., Bates, D., & Gawell, K. (2007). A Guide to Geothermal Energy and the Environment.  Accessed from www.eco-energy.org/reports/Environmental Guide.pdf.

Utilities Consumer Advocate. Geothermal. Accessed from http://www.ucahelps.gov.ab.ca/225.html.

The AAMDC has no active resolutions directly related to this issue.

Environment (responding on behalf of both Environment and Energy):
Alberta Environment has developed a response to Resolution 17-10F after consultation with Alberta Energy.  Both Alberta Environment and Alberta Energy support the objective of this resolution to conduct more research, provide more education, and, where appropriate, introduce legislation to ensure geothermal activity is not at the expense of other environmental considerations.
Alberta Environment Policy RS-02-04, revised May 7, 2007, outlines regulatory requirements for geothermal systems using the open loop system.  An approval
and rigorous evaluation of the design of the system is required under the Water Act, and projects must be supervised by a professional engineer or geologist.  The water wells must be drilled by a certified journeyman driller and constructed in accordance with the Water (Ministerial) Regulation.  However, there is no current policy or regulation in Alberta that covers the installation of closed loop systems.  Depending on the size of the project, a very large number of deep vertical boreholes could be drilled that may encounter groundwater aquifers, and because this activity is not regulated, the risk of contamination to groundwater resources is high.

In responding to this resolution, the Government of Alberta agreed with the intent, especially as it relates to the commonly-used closed loop geothermal systems. The response indicated that the number of deep vertical boreholes in closed loop systems presents a high risk for groundwater contamination.  Alberta Environment and Sustainable Resource Development (ESRD) hosted “water conversations” in February and March 2013 which included focused discussions on various water use issues. It is anticipated that the Government will share a “What We Heard” document highlighting issues discussed during those consultations. At a previous meeting with the Minister of ESRD, the AAMDC was informed that the ministry was working with industry in policy development regarding this issue. The AAMDC will continue to monitor policy developments from ESRD and advise members on progress moving forward.