Other Locations:

June 8 Millarville
June 8 Vulcan
June 9 Pincher Creek
June 19 Red Deer

June 20 Drayton Valley
June 21 Rocky Mtn. House
June 22 Sundre
June 24 Grande Prairie
June 26 Edson
June 27 Hinton
June 28 Leduc
June 29 Calgary

Summary Aboriginal

Summary Response Forms

Summary Written Forms

Advisory Committee on Public Safety and Sour Gas
Written Submissions Summary

I Summary Format

The Advisory Committee received ten written submissions. The key points of each of the have been summarized and organized into three topic categories, including (1) Prevention, Policy and Jurisdiction; (2) Event Consequence Management; and, (3) Communication and Compensation. These topic categories correspond with the Advisory Committee's three working groups, which have been established to assess and address specific aspects of the issues surrounding public health and safety and sour gas.

II General Discussion

  • Concern about the piecemeal approach of the Advisory Committee and that no chronic effects are being considered.
  • Impressed with the Committee website; informative.
  • Concern about whether anything valuable will come out of this consultation or is it just another process.
  • Believe that the regulatory agency and emergency planning agencies and the industry can be proud of its public safety history. Confident that the level of performance will continue to improve.

III Prevention, Policy and Jurisdiction Working Group

Policy

  • Lack of tangible process in the EUB's policies and procedures to assess and address potential acute and chronic human health effects due to the know and unknown toxics within sour natural gas.
  • EUB has limited in-house expertise in the area of health protection.
  • Long term planning on a provincial scale should be conducted immediately to designate appropriate and inappropriate locations of sour gas facilities; should be based on the existing and statutorily planned patterns of development.
  • Weak air pollution standards were downgraded to guidelines; guidelines are not sufficient instruments for restraining environmental abuses; profit has become motivator.
  • Should be a public vote every time a sour gas well is to be drilled; all people who live in a ten mile radius should be eligible to vote.

Jurisdiction

  • Health sector, especially at the local level, is ready and willing to work with the EUB and industry to formalize a process to better address the concerns of the public and health protection regulators regarding the applications an ongoing maintenance of sour gas operations in the province.
  • No clear means for local Public Health officials to proactively province industry the needed direction on assessing risk.
  • EUB should be the lead agency to encourage a comprehensive and inclusive process of reviewing application or existing facilities and issues; the process should include the appropriate expertise in human health risk assessment; EUB should partner in research and review with academic and government health experts on a regular basis.

Application and Decision Making

  • The current EUB process for application and review of existing facilities has the best potential to incorporate an effective and inclusive process for the assurance of health protection.
  • EUB needs to review and continuously improve the application process for new sour gas operations and the review of existing ones; EUB should formally include the Medical Officer of Health on behalf of the Regional Health Authority to participate in the review of all significant applications.
  • Applications should include and expression of recognition of the project and an understanding of related facilities form each affected party.
  • Two week public notification and consultation is not adequate.

Regulations

  • Voluntary guidelines and regulations related to sour gas are weak.
  • Want policy for making adequate regulation now; want regulations based on the previous studies carried out in the province over the last twenty years.
  • There should be no sour gas facilities within a specified radius of incorporated City limits; determination of the radius should be based on immediate effect of an H2S release, long term effect of flaring and the nature of existing and anticipated urban development; area should be treated as a buffer.
  • Strict standards regulating the location of well sites, the density of sour gas well sites, inspection of pipelines, processing plants, emissions and flaring are required; regulations must be enforced; should be sufficient resources (human, financial) to monitor entire province.
  • Flaring should be eliminated completely; companies should be required to pay royalties on over 2 billion cubic meters of gas burned off each year; motivate change.
  • Wells over level two should not be drilled.

IV Event Consequence Management

Health Effects and Toxicity

  • Concern about the harmful effects of sour gas emissions and air pollution in general; substantial anecdotal and scientific evidence about the negative effects yet the government and industry continue to minimize the serious health problem reported by affected individuals.
  • Concerned about the health effects of sour gas emissions; may people in the Mayerthorpe area have died from cancer or have cancer and she believes that there is a relationship.
  • Has had two experiences where sour gas odor had been strong enough to bring about illness (headache, dizziness, nausea); evidence of diminished animal health among her farm animals.
  • Emissions of toxic and hazardous gases pose health threat to humans, animals and the environment; requires abolition of venting, flaring and glycol dehydrators and the application of state-of-the-art technology.
  • Very concerned about the emissions from sulphur plant; personal health issues within family (asthma, sore eyes) and for farm animals (whit muscle disease in cattle).

Health and Policy Making

  • Sour gas related issues (Lodgepole), changes in demographics and urban sprawl in areas with sour gas development has heightened the public's concern about sour gas and public health; conflicts with the boom economy in the oil patch.
  • Because there is no formal process for assessing the risk of sour gas exposure, there is no effective way of Pubic Health officials at the local level to assure that reasonable health protection has been considered during the EUB application or review processes.
  • No specific EUB policy to assure the appropriate and realistic assessment of human health &emdash; appears that this is left to industry.
  • Regulation for the oil and gas industry need to be stricter; better enforcement; industry should be forced to take more responsibility for public safety and the environment.
  • Questions the notion of 'acceptable standards' &emdash; acceptable to whom?; no democratic process; compromises individual's health and safety.

Quantitative Risk Assessment, Hazard Assessment and Decision Making

  • No formal process that the information and conclusions from an appropriate human health risk assessment related to a particular sour gas operation is utilized as the foundation for developing a reasonable risk management plan.
  • Industry is encouraged to interview local residents to generate personal health information related to potential sensitivities, however this information does not remain confidential; individuals taking information are not adequately trained.
  • Risk management strategies must go beyond the application process and attend to existing facilities on a regular basis.
  • Concern about aging and potentially high maintenance infrastructure of sour gas operations as a whole; risk management strategies tend to currently consider facilities, wells and pipelines as separate and there are limited examples of integrated approaches to emergency planning and response among operations in a given region.
  • Regional risk management strategies such as those promoted by regional operator groups could be expanded to include other sectors and more geography.

Emergency Response Plans

  • Current process for developing ERPs does not appear to be linked to recommendations from a preceding human health risk assessment specific to the application.
  • No apparent systems approach to the development of an overall ERP that affects the public at large; roles and responsibilities of the various players (particularly Health Authorities and MD) is unclear; no appropriate by industry with appropriate government agencies.
  • Suggest that ERPs become better integrated into an industrial planning zone similar to industry in cities and towns.
  • ERPs for significant sour gas operations should not be completed until an appropriate and validated human health risk assessment is completed to the satisfaction of the publicly accountable experts.
  • EUB, in conjunction with Alberta Disaster Services and Regional Health Authorities needs to promote a more comprehensive approach to ERPs for industrial sour gas operations.
  • The procedure for collecting personal health information by industry during the creation of the ERP should cease.
  • EUB should ensure that ERPs are created for all significant sour facilities, pipelines and wells in current operation to ensure that unanticipated events can be operationalized in a similar systematic manner.
  • Common misunderstanding among certain public agencies (health authority), the public and industry of the role and responsibilities of the MD for Disaster Services; industry continues to think that the MD is the primary emergency response agency; recommend that more be done to educate all players involved in ERPs about roles and responsibilities.
  • Public concern about how small operators can meet their emergency response obligations; insufficient resources.

Long Term Research

  • Proper research about the negative impacts on animal health resulting from sour gas emissions.
  • Studies that have been conducted have biased terms of reference and merely delay action and solutions; meanwhile, environmental degradation from sour gas continues.
  • A series of studies that provide evidence of the relationship between negative consequences to human, animal and environmental health resulting from sour gas have been cited in the submission; these suggest the need for action.
  • Money spent on lawyers and hearings should be spent on developing alternative energy sources.

V Communication and Compensation

Public Consultation

  • Strongly encourage the establishment of groups such as SPOG in other sour gas areas; very beneficial.
  • Has been concerned about levels of emission, noise, fumes and flares for may years and her complaints have been largely over looked; Environmental Protection advised her to 'try and get along'; condescending.
  • Response to odor incident was not satisfactory; no monitoring equipment; dismissed.
  • Put on hold on the Emergency Response line for 15 minutes; no number for the EUB.

Public Knowledge and Awareness

  • In spite of good efforts, the EUB needs to find a way to become more credible in the eyes of the public; appears that the Board is to cozy with industry; this perception does not instill confidence in the public.
  • Tried to get information about the relationship between cancer and sour gas and the number of deaths in Mayerthorpe from Cross Cancer but was unable to get results.

Risk Communication

  • Does not perceive there to be a formal and effective system for assessing, managing communicating the risks related to the acute or chronic exposure to industrial sour gas on effected populations in Alberta.
  • No evidence that the current approaches used by industry and the EUB have produced effective communication of risk to address the public's risk related to sour gas activity.
  • The current process of risk communication by the industry and/or the EUB is not effective in reducing public concern; problems with credibility; current messages have lost credibility with the public; no reliable research from which to base risk assessment.
  • EUB should consider significant external evaluation of its capacity to effectively communicate risk to the public and identify other agencies that may help to appropriately address health concerns.
  • Has not received results of air and soil quality testing on land, even when requested.