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Other Locations:
June
8 Millarville
June
8 Vulcan
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9 Pincher Creek
June 19 Red Deer
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20 Drayton Valley
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21 Rocky Mtn. House
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22 Sundre
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24 Grande Prairie
June
26 Edson
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27 Hinton
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28 Leduc
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29 Calgary
Summary
Aboriginal
Summary
Response Forms
Summary
Written Forms
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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.
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