WHEREAS Alberta Environment has drafted policies relating to the process for authorizing the issuance of reclamation certificates during the period of April 1, 2003 to March 31, 2004, which do not require an inspection of the site by a soil specialist;AND WHEREAS the Alberta Government is responsible for protecting all lands within the province from degradation, and it is their responsibility to not put Albertans at risk of being responsible for the clean up requirements of contaminated sites;AND WHEREAS there already are instances in which reclamation certificates have been requested for well sites, where detrimental impacts would have resulted had there not been site inspections prior to the issuance of the certificates;
THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties urge Alberta Environment to amend the proposed reclamation program, to ensure that the reclamation certification process for all well sites, pipelines and batteries requires a site inspection conducted by an independent qualified specialist prior to issuance of a reclamation certificate, and that the costs for the inspection are paid by the applicant.
A resolution was submitted to the 2002 AAMDC Fall Conference requesting the provincial government to continue inspection of well sites by Alberta Environment staff, to keep an unbiased perspective on the reclamation process. We have since learned that a draft policy has been prepared by Alberta Environment that would see the oil and gas industry become responsible for the inspection of their own well sites. Through discussions with Alberta Environment staff, it has been noted that there are some 30,000 well sites requiring inspection for reclamation purposes, and that the department does not have sufficient staff to conduct these inspections. It has been suggested that in order to get reclamation certificates issued for this backlog of sites, that during the period of April 1, 2003 to March 31, 2004 applicants need merely apply for a certificate and one will be issued. There will not be a requirement that a soil specialist provide a congruent report that supports issuance of a certificate of reclamation. Although Alberta Environment may not have sufficient staff to conduct the necessary soil investigations on all the sites where reclamation certificates are being requested, there are sufficient private soil specialists throughout the province who could be retained by the companies applying for the certificate. The Alberta government needs to be prudent in protection of the environment and must not merely sign off on all well sites that are requesting a reclamation certificate. They must not assume that all companies have been prudent in following proper procedures for reclamation of lands. Many of these sites are on public lands, and any contaminations will fall back on Albertans to clean up these sites should future investigations determine that there are problems.Further, Albertans who have permitted drilling of well sites on their lands are also at risk of having their lands left with reduced productivity should there not be a proper assessment of the condition of the site at the time the reclamation certificate is issued. Within the past year there have been cases where lands have had major productivity loss due to insufficient topsoils being replaced on the original site. Excess amounts of clay to surface disturbances have been witnessed upon site inspections. Under the current criteria, 80% of what soil was there prior to the oil or gas activity is to be replaced and in several instances there were major discrepancies. The provincial government needs to be accountable and protect all Albertans from any environmental issues that will arise from sites that have been improperly reclaimed. By issuing the Reclamation Certificates, the company responsible for the contamination may be released from their obligations to provide a clean and properly reclaimed site.
Delegates to the Fall 2002 Convention endorsed Resolution 13-02F, calling on the province to continue providing reclamation inspections through provincial staff.The AAMDC board met with Alberta Environment staff in January 2003, and the AAMDC Environment Committee met with departmental staff in February 2003, to discuss this issue further. Following those discussions, the AAMDC board wrote to Environment Minister Lorne Taylor to strongly encourage the minister to maintain the current system of carrying out reclamation inspections through provincial employees.