History And Governance As A Blueprint For Future Federal-Provincial Co-operation On Environmental Monitoring In The Alberta Oil Sands Region

Overview

The environmental impacts associated with existing and proposed developments in the Alberta oil sands development region have received unprecedented national, and international, attention. The oil sands represent a strategic resource of importance to Alberta, Canada and indeed to the international energy trading community. The present and future potential magnitude of developments required to extract, upgrade and transport the oil have, for better or worse, vaulted the oil sands region into the realms of international economic, social, environmental and political attention. Accordingly, both the federal and provincial governments have increasingly focussed their attention to creating or expanding environmental monitoring and research programs in the oil sands region of Alberta.

At a time when new approaches to scientific monitoring programs are being reviewed, it may be useful to recall that there is an extensive, and successful, history of scientific and policy co-ordination between Alberta and Canada in regard to oil sands environmental assessment and management programs in the province. Past Federal-Provincial agreements have recognized the overlapping jurisdictional responsibilities and governments responsibly have sought to achieve management and financial efficiencies to harmonize, if not resolve, these overlaps.

Here, past management models and agreements are reviewed, with particular attention paid to the Alberta Oil Sands Environmental Research Program (AOSERP) (1975 to 1980) and the Northern River Basins Study Board (NRBS) (1991 -1996).

New and better integrated management systems need to be devised to bring about efficient, co-operative and sustained monitoring to be implemented by governments and industry. Alberta has increasingly acknowledged its inherently conflicting roles as resource manager and proponent, regulator and regulatory enforcer in the oil sands region. If the key 2011 recommendation of the 2011 Alberta Environmental Monitoring Panel (AEMP) to form “an Alberta Environmental Monitoring Commission to operate at arm’s length from government, regulators and those being regulated“ is to be achieved successfully , it will first require heightened levels of intergovernmental co-ordination and co-operation.

Past models for environmental monitoring and research for in the oil sands region, and perhaps equally as important their respective histories, should be of material interest to senior federal, provincial, territorial and industry decision-makers as they approach future considerations of governance associated with oil sands development. These past governance models should serve to guide potential new research program development and implementation.

 

 

Recent History: 2010 – 2011

As noted in the recent report of the Alberta Environmental Monitoring Panel (2011), the Lower Athabasca and Cold Lake regions contain approximately 81% of Alberta’s bitumen reserves. With current technology, it is estimated that about 175 billion barrels of bitumen, or 10% of the entire estimated Alberta oil sands resource, may be economically recoverable. Future advancements and market conditions could lead to development of the full 1.71 trillion barrels of bitumen (Government of Alberta, 2011b).

Investment in the oil sands has increased dramatically over the past two decades, from $490 million in 1991 to a high of over $20 billion in 2008 prior to the global recession (Government of Alberta, 2011b). The Canadian Energy Research Institute (Millington and Mei, 2011) projects that, over 35 years, total capital investment in oil sands could range from $213 billion to $302 billion. Another CERI report (Honarvar et al., 2011) estimates a total GDP impact of $2.1 trillion for Canada and more than $500 billion for the United States. Employment in Canada (direct, indirect, and induced) as a result of new oil sands investment is predicted to grow from 75,000 jobs in 2010 to 905,000 jobs in 2035.

Notwithstanding strategic and economic implications for North American continental energy supply, development of the oil sands region has been the subject focus of an escalating series of protests in Canada and the USA in 2010 – 2011. These, and other internal US political events, led US President Obama in November 2011 to refer for further review the Keystone XL pipeline application proposed to deliver higher volumes of oil from Canada to the USA. Prior to this highly political US decision, the oil sands had been reviewed by highly-esteemed agencies such as the Royal Society of Canada and special federal and provincial advisory panels composed of some of most distinguished scientists from Canada and the USA. These high-level scientific evaluations were commissioned urgently in the face of mounting public criticisms that encouraged governments to re-assess the nature and degree of environmental impacts associated with oil sands surface and sub-surface (in-situ) mining methodologies. These reviews assessed carefully the adequacy of environmental monitoring systems used in the region (Dowdeswell et al., 2010; Royal Society of Canada, 2010).

In the fall of 2010, the Federal Commissioner of the Environment and Sustainable Development reported that Environment Canada had recognized polycyclic aromatic hydrocarbons (PAHs) as a threat to water quality on the Athabasca River as early as 2001. Moreover, it was noted that Environment Canada had insufficient data to ‘monitor threats related to population growth and economic development in the region as well as insufficient data to monitor the oil sands.’ It was noted that as of June 2010, the federal government ‘did not have the capability to monitor many of the toxic pollutants associated with oil sands production.’

 

In 2010, Alberta formed another panel, the Alberta Water Monitoring Review Data Committee (Dillon et al., 2011) to examine water quality data collected by several parties, including RAMP, Alberta Environment and Dr. David Schindler’s research group at the University of Alberta, with the overall the aim of understanding the differences in the various results. The report issued on March 7, 2011 concluded that the sampling and analytical methods used by the RAMP program were inadequate. The Alberta Water Monitoring Data Review Committee also highlighted failures of monitoring for trends in contaminants in the Athabasca River downstream of the oil sands. It reported that current monitoring ‘was not intended to assess impacts of the oil sands on the river’ that ‘it appears the laboratories Alberta Environment used do not have the capability of measuring the low concentrations of PAC found in the water. The Committee believes that there were deficiencies in the sampling design and methodology for this study”. It was also noted that RAMP suffered from low sampling frequency.

The committee also concurred with findings Kelly et al. (2009, 2010) in the Proceedings of the National Academy of Sciences that indicatedpolycyclic aromatic hydrocarbons and trace metals were ‘being introduced into the environment by oil sands operations.’ As with other reports, it called for new monitoring programs that ‘are conducted with scientific rigor and oversight.’ Another external review of RAMP, led by the Alberta Research Council (February 2011) confirmed that concerns voiced about RAMP by Dillon et al. (2011) and by a 2004 review of RAMP (Ayles et al. 2005) had indeed not been adequately addressed. Other reports (Munk School, 2011) have drawn attention to the need for a more inclusive and comprehensive examinations of the impacts resulting from oil sands developments.

In late2010, the Royal Society of Canada comprehensively documented and confirmed insufficient monitoring in the oil sands region. In particular, they concluded that: ‘The environmental regulatory capacity of the Alberta and Canadian Governments does not appear to have kept pace with the rapid growth of the oil sands industry over the past decade. The EIA process relied upon by decision-makers to determine whether proposed oil sands projects are in the public interest has serious deficiencies in relation to international best practice. Environmental data access for cumulative impact assessment needs to improve.’

 

The federally appointed Oil Sands Advisory Panel (Dowdeswell et al. 2010) was also tasked with examining the state of monitoring in the oil sands. They too found that the level of industrial activity dwarfed the scale of monitoring – as well as basic scientific research. In addition, baseline ecological data were considered to be poor and the panel determined that the ad hoc groups operating monitoring systems within the oil sands region lacked ‘a coherent data management framework where information could be uploaded, shared or organized.’ They concluded that until such time as these shortcomings are addressed ‘the debate on the environmental performance in the oil sands will continue to revolve around the adequacy of the data collected and not, as it should be, on data interpretation and implications.’

 

In response to the Federal Oil Sands Advisory Panel Report, Environment Canada Minister Kent released Environment Canada’s plan for a new Lower Athabasca Water Quality Monitoring Program (2011). In a press release announcing the release of phase 1 of the monitoring plan dated March 24, 2011, Minister Kent noted that: ‘The development of the plan was led by Environment Canada in collaboration with Alberta Environment. We have both committed to improve efforts in our respective areas of jurisdiction and we will continue to work to deliver improved environmental outcomes in the oil sands.’ In comments that received national and international attention Minister Kent noted that: ‘…the new plan, which will cost C$20 million a year to run, paid for by the oil industry, will include more frequent and widespread sampling, and form part of a broader system that will also monitor air quality and the impact of development on the region’s wildlife.’ (Reuters, 2011).

While the Environment Canada Phase 1 report focused on the issues of hydrology and water quality, a subsequent report issued on July 21, 2011 recognized that there was a need to expand and integrate air and biodiversity monitoring, as well as broader water quality monitoring and effects assessment for the oil sands region (Environment Canada, 2011).

On June 30, 2011 the Alberta Environmental Monitoring Panel (AEMP) submitted its final report to Alberta Minister Renner. The report made recommendations for the establishment of a world class environmental monitoring, evaluation and reporting system for Alberta. A key recommendation was for the creation of an independent Alberta Environmental Monitoring Commission to operate at arm’s length from government, regulators and those being regulated. The Commission would be responsible for the strategic direction, scientific focus and on-going operation of the proposed environmental monitoring system.

Clearly, if the recommendations from the several panels are to be implemented properly, a heightened level of scientific and policy co-ordination will have to be reached between Canada and Alberta. Here, it is suggested that governance models from past programs could guide Federal and Alberta decision-makers in their design and establishment of joint environmental monitoring programs, perhaps also to include certain university and private sector participants. It is further argued that, if successful, such co-operative efforts and programs would offer decision-makers enhanced levels of fiscal and scientific efficiencies at a time of growing international concern over government deficit expenditures. Properly structured co-operative efforts could result in less duplicative and enhanced scientific programs that would profit from the collaboration of widespread agencies and laboratories with unique, or highly-specialized, analytical and assessment capabilities.

Not to achieve such co-operation between federal and provincial agencies could result in inefficient, ineffective, duplicative and perhaps discordant efforts to effectively regulate and monitor oil sands project developments that are in the national interest. Good governance, with appropriate adequately-funded program designs, will be essential to achieving implementation of all the recommended scientific protocols required to achieve enhanced environmental assessments in the oil sands region.

 

 

Past Provincial – Federal and Territorial Co-Operation

Alberta and Canada co-operated actively with the Federal Oil Sands Advisory Panel in the formulation of the federal water quality monitoring program released on March 24, 2011. This co-operative tone between the governments is consistent with past efforts between federal and provincial agencies in the oil sands region. These co-operative signals may give rise to optimism that continued extended co-operation will occur in future monitoring programs in the oil sands region, especially following the work of the Alberta Panel (AEMP) (June 2011).

Although large-scale, or regional, watershed assessments have been done for the oil sands region (Paetz, 1984; Wallace and McCart, 1984) these studies did not represent formal co-operative, interjurisdictional efforts. They were, at best, ‘snapshots’ of the state of the aquatic resources and, unfortunately, were not further supported with comprehensive regional field research. This need for substantive, integrated, ‘baseline’ assessments was made more certain by expanding, accelerating oil sands developments. Interestingly, in some cases, these ongoing gaps in research have tended to be filled increasingly by university researchers who have tended to expand the technological limits for monitoring to extend and include parameters of interest well beyond the methodologies employed by regulatory agencies or industry.

Notwithstanding the deficiencies noted by the various federal and provincial review panels, there has been a history of co-operative, interjurisdictional environmental monitoring programs undertaken across western Canada and particularly in the Alberta oil sands region. These co-operative efforts may be categorized broadly as:

1. Environmental assessments
2. Monitoring (or ‘baseline’) studies

The former category (a: environmental assessments in the oil sands region), has included major studies associated with oil sands development applications such as the OSLO Project, Kearl Lake and other projects. These and other development assessment application reviews in northern Alberta, such as occurred with the Alberta Pacific Pulp Mill Project, required broader co-operative federal-provincial reviews. Notably, federal requirements for major project development assessments (consistent with federal legislation under the Canadian Environmental Assessment Act (CEAA)) grew to involve Alberta to also address requirements under parallel provincial environmental assessment legislation.

There are fewer examples of the latter (b: formal federal-provincial joint studies for monitoring or ‘baseline’ studies). Clear exceptions to this general rule were the Northern River Basins Study Board (NRBS) (1991 – 1996) and the earlier Alberta Oil Sands Environmental Research Program (AOSERP) that was initiated between Canada and Alberta in 1975.

 

 

The Alberta Oil Sands Environmental Research Program

The Alberta Oil Sands Environmental Research Program (AOSERP) (1975-1980) grew out of national concerns voiced even then about the potential magnitude of rapidly-expanding oil sands developments with their attendant and potential environmental and social impacts. The Agreement that brought the AOSERP Program into being was signed between Canada and Alberta in February, 1975 (subsequently amended in September 1977).

Signed at a time of heightened jurisdictional tensions between Alberta and Canada, the 1975 AOSERP program was, for its time, unique in scope and degree. Initially conceived as a $20 million joint research program the Agreement stated:

“Whereas Canada and Alberta have agreed to identify, undertake or encourage and assist research into environmental aspects of the renewable resources involved in the development of oil sands……and wish by this agreement to provide a general framework for the co-ordinated planning, funding and implementation of such research…Whereas the results of an intensive study of the area will be useful in predicting the effects of any proposed development, as a basis for considering future development proposals, and whereas the results of the study program will be utilized by Alberta in the approval process for future developments and in the environmental design of any project which might be implemented; whereas Canada and Alberta are agreed on the objectives, general strategy and procedures which would govern the identification and selection of such research and the methods of encouragement and assistance;…”

After five years, $17,324,000 had been spent to publish approximately 200 peer-reviewed research reports (AOSERP Summary Report, 1981). During its active research phase, the program received material financial support and seconded personnel from the federal government (Fisheries and Oceans Canada and Environment Canada, and departmental representatives of several Alberta agencies and university researchers). AOSERP was uniquely managed by a collective series of committees chaired by two federal and six Alberta representatives. They ultimately reported through an Alberta Program Manager and jointly to the respective Ministers of Alberta Environment and Environment Canada. The program received international attention for its unique, co-operative and integrated approach to regional baseline monitoring and environmental research.

However, by 1977 the AOSERP program was substantially reorganized, enough so that a new negotiated Agreement was required. These events, and other administrative and fiscal tensions, may have led the federal government subsequently unilaterally, and somewhat acrimoniously, to withdraw from the program. The 1981 Final Report was submitted solely to Alberta Environment and the AOSERP program was disbanded.

Nonetheless, the 1975 AOSERP Agreement between Canada and Alberta may constitute a precedent and a formal basis that may deserve careful consideration for future potential joint ‘baseline’ or joint monitoring programs undertaken in the oil sands region between the federal and provincial governments.

Interestingly, even at the relatively early date in 1981, the AOSERP Summary report noted that:

“The systems approach used by AOSERP is only the first step toward any in-depth assessment of ecosystems and social impacts – an administrative convenience for organizing a complex series of investigations. In order to assess with any degree of exactitude what long-term impacts of oil sands development might be, extensive research will be required to develop a predictive capability which does not now exist.”

 

The Northern River Basins Study (NRBS)

The subsequent Northern River Basins Study (NRBS) (1991-1996) was an interjurisdictional study that that took into consideration the Peace, Athabasca and Slave River basins. It was launched co-operatively between the federal, provincial and territorial governments initially in response to widespread concerns voiced by northern residents about the present and future state of regional river systems following the approval of the Alberta Pacific Pulp Mill at Athabasca, Alberta. The Study Board was made up of representatives from the governments of Canada, Alberta and the Northwest Territories, including local communities and aboriginal representatives.

An October 1989 Intergovernmental Steering Committee meeting between federal, provincial and territorial agencies with interests in the basins recognized that there was an urgent need to deal with recommendations from the AlPac EIA Report (March 1990) with further technical studies. The Steering Committee and its Task Force outlined the initial framework for the Northern Rivers Basins Study and developed a draft federal-provincial-territorial agreement. The study, initially prosed as approximately three years in duration, was to be funded under the Canada Water Act, the Alberta Water Resources Act, and the Department of Indian Affairs’ Northern Development Program. Following the guidance of the Intergovernmental Steering Committee that acknowledged widespread public concerns, the Task Force proposed a research program to address information and research gaps. Budgeted at $12.3 million the research program was directed at topics in hydrology-hydraulics, water use, water quality, fisheries and wildlife.

The initial tripartite agreement between Canada, Alberta and the NWT was signed 27 September 1991 and brought into being the “Peace-Athabasca-Slave River Basin Study”. The Agreement was subsequently amended on 15 September 1995 to be an Agreement for a “Northern River Basins Study”. The program was directed by the NRBS Study Board thatreported annually to the Ministers of Environment Canada, Indian and Northern Affairs Canada, Alberta Environmental Protection and Northwest Territories Renewable Resources. Importantly, under the scientific leadership of the internationally respected Dr. Peter Larkin, a scientific advisory panel was established to direct, and advise upon, the studies funded. This innovative program involved unprecedented participation and involvement of the public, aboriginal and environmental communities. Co-chaired by senior representatives of Environment Canada and Alberta Environmental Protection, the Board completed 150 projects that required extensive community consultations. For instance, the Board met every second month in different communities within the basins allowing them to gain a personal sense of the culture, geography and interests of communities located throughout the basins.

The Study Board subsequently made comprehensive, numerous recommendations for possible future interjurisdictional successor organizations. The success of NRBS in building public trust and scientific credibility among key stakeholders throughout the river basins led the board to recommend that the exercise be continued in some form such that future programs be charged with a ‘mandate to monitor and power to research, monitor and regulate the environmental health of the aquatic ecosystems of the northern river basins’ (NRBS Report to the Ministers, 1996).

Regrettably, the NRBS was subsequently disbanded and, while the subsequent Northern River Ecosystem initiative produced some excellent research, the importance of maintaining science-based, and publicly-interactive, programs such as NRBS passed from the public, and political, consciousness.

 

 

A Further Basis for Potential Co-operative Federal-Provincial Association in Oil Sands Monitoring

In January 1998, Canada and most provincial governments (Quebec was not a party to the Agreement) signed a ‘Canada-Wide Accord on Environmental Harmonization’. The purpose of the Accord was to:

• To provide a framework and mechanisms to achieve the vision and to guide the development of sub-agreements pursuant to the Accord.

The Accord stated that the objective of such ‘harmonization’ was to:

• enhance environmental protection;
• promote sustainable development; and
• achieve greater effectiveness, efficiency, accountability, predictability and clarity of environmental management for issues of Canada-wide interest, by:

1. Using a cooperative approach, to develop and implement consistent environmental measures in all jurisdictions, including policies, standards, objectives, legislation and regulations;
2. Delineating the respective roles and responsibilities of the Federal, Provincial and Territorial governments within an environmental management partnership by ensuring that specific roles and responsibilities will generally be undertaken by one order of government only;
3. Reviewing and adjusting Canada’s environmental management regimes to accommodate environmental needs, innovation, expertise and capacities, and addressing gaps and weaknesses in environmental management; and
4. Preventing overlapping activities and inter-jurisdictional disputes.

While the Canada-Wide Accord may not provide a specific basis upon which to predicate future joint federal-provincial monitoring programs, it constitutes a ‘point of departure’ for the formulation of future co-operation, especially if other jurisdictions, such as the Northwest Territories and Saskatchewan, choose to consider joining.

The magnitude and challenge in monitoring and assessing the full extent of future oil sands mining and development projects may yet entail, or may even require, co-operative research that extends much more widely from the oil sands mining areas.

 

Conclusions

Many would agree that, given the recent series of highly-regarded expert reviews undertaken from 2010 – 2011, many of the concerns noted in the AOSERP and NRBS programs exist today in the oil sands region. Remarkably, these concerns remain in spite of material expenditures undertaken by government and industry to monitor and understand the environmental consequences of oil sands production ever since those early studies.

This evidence would suggest that a ‘world-class’ monitoring system for the oil sands region will require a significant, carefully-crafted, long-term , co-operative, integrated effort by many levels of governments in Canada. At very least, enhanced co-operation will be required to address and understand the consequences of the ‘world-class’ investments, and the resultant industrial production, extant in, or rapidly developing throughout, the oil sands region. Unquestionably, these concerns attracted the attention of the AEMP Panel (2011) and led them to recommend a new Commission to be managed by ‘Albertans for Alberta’. The key AEMP recommendation that called for the creation of an Alberta Environmental Monitoring Commission was to allow it to “to operate at arm’s length from government, regulators and those being regulated. The Commission would be responsible for the strategic direction, scientific focus and on-going operation of the proposed environmental monitoring system. It is concluded that not to achieve enlightened co-operation between federal and provincial agencies could result in inefficient, ineffective, duplicative – and perhaps discordant – efforts to more effectively regulate and monitor oil sands project development projects that are in the national interest.“

Given the high level of public distrust, and controversy, surrounding oil sands environmental issues, it is essential that the creation of subsequent institutions achieve, and be seen to achieve, a science-based and ‘arms-length’ agenda. This is all the more so in light of the very material national international public and scientific scrutiny currently focussed upon the oil sands mining region. Notwithstanding this imperative, there exists the potential for an over-enthusiastic, over-reaction by a series of regulators all of whom, while reflecting their valid mandates for the responsible regulation and monitoring within and outside of, the region, may miss opportunities to implement joint efficiencies that would enhance their mutual interests in the discharge of their mandates. Industry, particularly oil sands operators, tend to thrive in an environment that provides regulatory and investment certainty.

Here, it is argued that much could be gained from co-operative approaches that involve all levels of governments, industry and the university research communities across Canada. Given the very public recent commitments and actions demonstrated by Canadian federal and provincial political leaders, one could conclude that shared, material political interests should be followed by co-ordinated strategic investments by governments, and presumably also industry, to enhance environmental monitoring and assessment systems in the oil sands region.

Accordingly, some past management models employed to accomplish these aims are presented. Those models, although they did not long survive jurisdictional rivalries, and changing fiscal priorities, nonetheless indicate that such major intergovernmental program agreements can be achieved, both in terms of legal design and co-operative scientific field operations – if there is a sustained political and social will to accomplish these ends.

Canada should take careful notice of the recommendations of the Royal Society that noted ‘the environmental regulatory capacity of the Alberta and Canadian Governments does not appear to have kept pace with the rapid growth of the oil sands industry over the past decade’. One could argue that, if Alberta and Canada are indeed to achieve international best practices, we shall need to implement improved scientific and management practices that provide for better access to data and also for enhanced regional cumulative impact assessments. If Canada is to achieve these ends, new and better integrated management systems will surely need to be devised to bring about efficient, co-operative and sustained monitoring for governments and industry. If the key 2011 recommendation of the AEMP Panel to form “an Alberta Environmental Monitoring Commission to operate at arm’s length from government, regulators and those being regulated“ is to be delivered and achieved successfully , it will require renewed levels of intergovernmental co-ordination and co-operation.

Past models for environmental monitoring and research for in the oil sands region and, perhaps equally as important their respective histories, should be of high interest to senior federal, provincial, territorial and industry decision-makers as they approach future considerations of governance associated with oil sands development.

 

 

Dr. Ron Wallace holds a PhD in aquatic ecology and worked actively as a research scientist and manager in the 1975 AOSERP Program. He was appointed (1991) as a Board Member of the NRBS was subsequently (2011) appointed as a Panel Member to the Alberta Environmental Monitoring Panel (AEMP). He was honored with the 1996 Alberta Emerald Award for his work in Russia as consultant-manager to the World Bank associated with the Kharaga – Usinsk oil pipeline spill. He was subsequently recognized in 2004 as ‘Entrepreneur of the Year – Alberta Region’ in manufacturing technologies. In 2005 he retired as the Chief Executive Officer of a publicly-traded international corporation and was appointed (2010) as a Fellow of the Canadian Defense and Foreign Affairs Institute. He has published widely and has maintained a keen interest in environmental, economic, military and community affairs, including the visual arts and implementation of federal-provincial policies in Canada.

 

Citations and References

Alberta Environmental Monitoring Panel Report. June 2011. A World Class Environmental Monitoring, Evaluation and Reporting System for Alberta. 84 p. ISBN: 978-0-7785-9530-4 (Printed) ISBN: 978-0-7785-9531-1 (On-line).

Alberta Environment. 2010. Provincial Environmental Monitoring Panel for Monitoring, Evaluation & Reporting for the Lower Athabasca River: Available at: http://environment.alberta.ca/03289.html

Alberta Oil Sands Environmental Research Program. 1981. Summary Report: 1975 – 1980. 170 p.

Ayles, G. B. et al. 2005. Oil Sands Regional Aquatic Monitoring Program (RAMP) Scientific Peer Review of the Five Year Report (1997–2001). Fisheries and Oceans Canada, Winnipeg, 2004); available at: go.nature.com/tdsuag

Dillon, P., G. Dixon, C. Driscoll, J. Giesy, S. Hurlbert, and J. Nriagu. 2011. Water Quality Data Review Committee Final Report, Prepared for Government of Alberta, March 7, 2011. Available at

http://environment.alberta.ca/03380.html.

Dowdeswell, E. (Chair), Dillon, P., Ghoshal, S., Miall, A. D., Rasmussen, J., and Smol, J. P. Oil Sands Science Advisory Panel: “A foundation for the future: Building an environmental monitoring system for the oil sands.” A report submitted to the Minister of Environment; Environment Canada, 49 p., December 2010.

Environment Canada Press Release. 2011. Canada’s Environment Minister Responds to Oil Sands Recommendations with Water Monitoring Plan. Ottawa, March 24, 2011. Canadian News Wire.

Environment Canada, 2011. Lower Athabasca Water Quality Monitoring Program. Environment Canada, Ottawa.

Environment Canada. 2011. An Integrated Oil Sands Environmental Monitoring Plan. Environment Canada, Ottawa. 31 p. ISBN 978-1-100-18939-0

Kelly, E. N. et al. 2009. Proc. Natl. Acad. Sci. USA 106, 22346–22351.

Kelly, E. N. et al. 2010. Proc. Natl. Acad. Sci. USA 107, 16178–16183.

Munk School of Global Affairs. 2011. The Oil Sands Environmental Footprint: Measuring Pollutants and Managing Their Impact: Notes For Discussion. Prepared for the Monk School Forum: “Under New Management? Oil Sands Development as if the Environment Mattered.” April 8, 2011. D. Schindler, A. Miall and A. Hurley. Program on Water Issues: Munk School of Global Affairs. University of Toronto.

Northern Rivers Basins Study. 1996. Report to the Ministers. Key Findings and Recommendations. 287 p. ISBN 0-662-24356-0. Cat. No. R71-49/1996E. 287p.

Paetz, M. J. 1984. The Fish and Fisheries of the Peace River Basin: Their Status and Environmental Requirements. Alberta Environment: Planning Division and Alberta Energy and Natural Resources: Fish and Wildlife Division. Ms. Report. 240 p.

Reuters, 2011. Canada Revamps Water Monitoring in Oil Sands. Energy and Oil. March 24, 2011.

Royal Society of Canada Expert Panel Report: “Environmental and Health Impacts of Canada’s Oil Sands Industry,” by Gosselin, P., Hrudey, S. E. (Chair), Naeth, M. A., Plourde, A., Therrien, R., van der Kraak, G., and Zhenghe Xu. 414 p., December 2010.

Wallace, Ron R. and Peter J. McCart. 1984. The Fish and Fisheries of the Athabasca River Basin: Their Status and Environmental Requirements. Alberta Environment: Planning Division. Ms. Report. 316 p.