CUMULATIVE ENVIRONMENTAL EFFECTS CRISIS IN NORTHEASTERN BRITISH COLUMBIA'S OIL AND GAS ENERGY ZONES
On November 9, 2010, this site released a report on the environmental crisis facing northeast British Columbia: EnCana's Cabin Not So Homey - Cumulative Environmental Effects - An Unfolding and Emerging Crisis in Northeastern BC's Shale Gas Plays (pdf file, 13.725 megabytes).
One of the main points made was that
government has failed to carefully plan for cumulative environmental
impacts related to
the oil and gas industry's recent 'shale gale' invasion on British
Columbia’s public lands.
Though the petroleum industry (gas and oil) has been active in northeast B.C. since the 1950s, its operations began to significantly boom in the late 1970s. By the 1980s, natural gas exploration and production began to overtake oil, particularly following the privatization of B.C. Gas (a former public corporation) and the deregulation of the industry.
Over time, as described in internal Ministry of Environment 1980s memos and reports, the operations of the petroleum industry cumulatively degraded land, water and air resources to such a degree that staff finally called upon senior government in 1991 to not only implement an integrated cumulative effects land planning strategy for all future petroleum tenures, but to also increase staffing levels to deal with all of the necessary planning and monitoring requirements over an area representing about 15 percent of BC’s land mass.
Though a cumulative effects strategy was eventually proposed in a lengthy March 2003 cumulative environmental effects report for the BC Oil and Gas Commission, the provincial government did not take the matter seriously and has not yet implemented corresponding detailed regional land planning action, while dishing out hundreds of new natural gas tenures.
Late 2003 was about the same period
that natural gas land
tenure sales began to sharply rise, associated with new investment
and technological interests to develop deep shale gas deposits. By 2005
2007, the deep shale gas quickly took on a ‘gold gas rush’ frenzy,
the United States gas frenzy catapulted by deregulation, environmental
exemptions, and new controversial access provisions to U.S. public
reserve lands by the Bush-Cheney administration.
However, some of the special interests
exploit BC's shale gas were quietly driven to provide new cheap energy
sources to fuel the production of Alberta's dirty tar sands, as the
MacKenzie Valley gas pipeline proposal, much of it destined for the tar
sands, was about to be put aside on the shelf.
The following are quotations from the
Introduction and Conclusion
This report raises questions about the cumulative environmental impacts of natural gas companies operating in north-eastern British Columbia’s (BC’s) energy zone. The area in question represents just over 15 percent (or over 140,000 square kilometres) of the total provincial land base. The zone area is larger than the State of New York or the State of Iowa. Other identified petroleum zones in BC (see map on page 6) will also be targeted for energy developments in years to come.
Most of British Columbia’s 4.5 million residents are far-removed from the province’s natural gas zones. But for the relatively small number of residents who live within or on the periphery of such zones, there is an overwhelming evidence of a sharp rise in industry activities, which are having significant impacts on land and water resources. Particularly as the industry’s water-intensive hydraulic fracturing or ‘fracking’ operations expand to stimulate gas production.
Most of the photographs and maps (100 images, maps, photos, etc.) in this report focus on the Horn River Basin (HRB) - one of the five or so petroleum shale ‘plays’, or geologic basins, in northeast BC. The HRB is estimated to be about 1.3 million hectares in size alone. The HRB has received widespread attention in energy industry publications because of the quality and voluminous amount of natural gas estimated to be trapped in its deeply buried shale formations. It is also the most rapidly developing of Canada’s shale basins and part of the so-called “shale gale” that has swept through many US states, including Texas, Colorado, Oklahoma, Pennsylvania and New York.
This report builds on a recent October 13, 2010 report by the author - 24/7 Less Peace in the Peace - which detailed some of the environmental impacts associated with Talisman Energy’s operations near and north of Hudson’s Hope, in the western Montney shale formation.
The following (now modified) questions were asked in the beginning of that report:
1. Can the planet afford to burn British Columbia’s (BC’s) shale gas?
2. Should the citizens of BC allow the shale gas industry to enclose/destroy, impair and fragment the Commons’ lands and waters?
3. If we decide that we can afford to burn BC’s shale gas, what is the public’s “fair share” of industry’s revenues? (I.e., the gas industry, like the Alberta tar sands industry, has a mere 2 percent conditional royalty agreement with the B.C. government!)
In the following pages of this report, not only will details on the cumulative impacts to lands and waters in the Horn River Basin be discussed, but questions raised about what plans - if any - the provincial and federal governments have to address such impacts.
addition, the report will present data that refutes
oft-repeated claims by government regulators, energy companies and
industry associations that natural gas is a clean, or green fossil
fact, natural gas produced from shale formations may be among the
fossil fuels on the planet.
The gallop to own, develop, distribute and market deep shale gas over a vast public territory in northeast British Columbia is in its infancy.
These resource-intensive developments have been allowed to proceed virtually unchecked and un-scoped. In this sense, given the backdrop of evermore lax and non-existent legislation and regulations, these developments can be understood as distinct social and political failures.
Juxtaposing these failures alongside the recent implementation of TILMA (Trade, Investment and Labour Mobility Agreement) - an in-house deregulatory accord signed by the three western Canadian Premiers - the outcomes could become evermore frightening. TILMA grants (energy) corporations legal powers (in a standstill clause) preventing new provincial regulations that in any way impede “trade, investment or labour mobility”. In hindsight, is the logical musing that the grand scale developments affecting controversial public resources like BC and Alberta gas and oil shales may be one of the obvious, significant factors behind TILMA. (The Council of Canadians are deeply troubled by TILMA, http://www.canadians.org/DI/issues/TILMA/factsheet.html, and made hydraulic fracturing one of their campaign issues.)
Many of BC’s environmental and regulatory problems on the subject were recently and summarily revealed in a paper by Ben Parfitt entitled, Fracture Lines: Will Canada’s Water be Protected in the Rush to Develop Shale Gas?, that he presented at the first Canadian public forum on fracking hosted by the Munk School of Global Affairs. Ben Parfitt raised a number of significant concerns, i.e.:
Even supporters of the unconventional resource now admit that “water has emerged as the highest visibility environmental issue” associated with shale gas production. In fact wherever the shale industry has invaded rural communities, controversy about water use, groundwater contamination and the regulation of the industry has doggedly followed. “The largest challenges lie in the area of water management, particularly the effective disposal of fracture fluids,” notes a 2010 MIT report on natural gas. ... Intensive drilling in northern British Columbia has resulted in unprecedented water withdrawals and even a bombing campaign directed against the Encana Corporation to protest the pace of development.
Given the economic importance of the resource and growing concerns about industry’s use of and impact on water, this report examines the implications of shale gas production on Canada’s water supplies. In addition to reviewing the technological drivers of the shale gas revolution, the report also looks at the state of groundwater mapping in shale-rich regions. Lastly, it reviews the adequacy of existing regulatory frameworks to protect water resources, landowners and rural communities.
Unlike the United States where the US Congress and state regulators are fully engaged in public policy debates, neither the National Energy Board nor Environment Canada have yet raised any substantive questions about ‘the shale gale’ or its impact on water resources. The pace of the shale gas revolution demands greater scrutiny before more fracture lines appear across the country.
That there are cumulative impacts associated with fracking is clear. Yet even in Canadian jurisdictions such as British Columbia, where conventional natural gas production has occurred for decades and fracking is ramping up, regulators appear ill equipped to address and mitigate such impacts. As the province’s Auditor General recently observed of British Columbia’s Oil and Gas Commission:
OGC’s mandate includes an expectation that it fosters a healthy environment. We found that, while the OGC has supported the development of some tools and methodologies to assess cumulative effects, no formal provincial program is yet in place to help manage the environmental effects of developments on the land base.
Against this backdrop, the OGC and the BC’s Ministry of Environment are faced with increasing pressure from industry to develop shale gas wells. Similar pressures are soon likely to be felt by regulators in other Canadian provinces, as the industry pushes to develop a resource that it maintains provides both energy security and an environmentally friendly bridge to a low-carbon economy.
Northeast British Columbia’s shale gas race will undoubtedly become and remain one of the most significant environmental and public planning issues facing First Nations, the Province, Regional Districts, regulators, communities and residents alike.
(A copy of Parfitt’s conference paper can be found on the BC Tap Water Alliance’s website, www.bctwa.org/FrackingBC.html, at the link on the right column, Toronto’s Munk School of Global Affairs Public Forum on Fracking.)
BC Ministry of Environment Concerns: 1991
Since at least 1991, staff with the Ministry of Environment have requested a cumulative effects strategy to be effectively implemented in the northeast energy zones. However, it took another twelve years before a cumulative effects proposal strategy was even developed for the new Oil and Gas Commission in 2003 (see below). And, and as reported by the Association of BC Forest Professionals (see below), nothing has apparently been accomplished since to implement such a strategy.
Here are a few more excerpts from the
old, October 1991 Ministry of Environment report, Environmental
Gas Field Development Activity in Northeastern
British Columbia: Issues and Recommendations:
The most pressing issue to be addressed is the cumulative impact of all petroleum industry initiatives on environmental resources.
Five Programs of Ministry of Environment have defined roles involved in overseeing petroleum industry developments, the Fisheries Branch, the Wildlife Branch, the Water Management Branch, the Waste Management Branch and the Conservation Officer Service.
Without appropriate mechanisms to control land and resource development, it will be increasingly difficult to protect sensitive environmental areas or to minimize the potential environmental impacts of gas field development. Lacking is an integrated approach to include all agencies responsible for resource management as equal participants in provincial initiatives that influence petroleum industry operations or gas field developments.
Environmental resource planning requires good baseline information and data base management. BCE’s Northeastern operations are currently deficient in both areas.
Generally lacking is a comprehensive project tracking program that includes compliance monitoring, environmental monitoring on-site, and verification through project supervision, surveillance and auditing.
The Province should work toward developing a coordinated, integrated resource management mandate for Northeastern B.C. BCE [Environment] and MoF [Ministry of Forests] should take the lead in establishing a task force to address environmental resource concerns in the area and investigate means for providing a more comprehensive approach to environmental resource and land use management. The produce of such a study could be a “State of the Environment Report for Northeastern British Columbia.”
Preserving and protecting water, fisheries and wildlife is a priority for BCE and will result in important changes in environmental programs and legislation. Efforts to protect environmental resources in the Northeast and minimize the environmental impact associated with gas field development is an important goal for BCE.
The degree to which petroleum industry operations adversely affect environmental resources is not fully known. However, the impact of gas field development on fish and wildlife habitat and populations, as well as infractions of existing regulations by petroleum companies (including local contractors), are being reported at an increasing rate by government field staff, conservation officers, local residents, trappers and guide outfitters, and Native groups. Photographs and data obtained by BCE staff in Fort St. John provide some evidence of the type and extent of environmental impact caused by gas field development. Well documented studies in Northwestern States and Alberta provide further evidence that the environmental impact of petroleum industry operations, particularly in sensitive wildlife areas, is significant.
Environmental impact assessments are not, however, formally required for gas field development activity (with the exception of regulated energy projects). In fact, very few environmental assessment reports have been prepared for non-regulated petroleum industry operations in the Region.
Hundreds of kilometers of pipeline, seismic line and access road are laid every year with no environmental screening, or environmentally acceptable guidelines for construction and operation.
The Science and Community Environmental Knowledge Fund (SCEK)
The May 2003, two-volume cumulative effects report, A Cumulative Effects Assessment and Management Framework (CEAMF) for Northeast British Columbia, was released and presented at a BC Oil and Gas Commission (OGC) conference in Fort St. John held on May 29-30, 2003. It was the first annual forum and workshop of the OGC’s Science and Community Environmental Knowledge (SCEK) Fund.
(Note: The two-volume document was not found on the OGC’s website, and only volume one of the report was found on a few other websites. However, a specific word pattern in a web word search engine did discover that the document is with the OGC’s website, but that it is restricted to internal or password use only: e.g., try keying in the following address on your web browser: http://www.ogc.gov.bc.ca/documents/scek.)
The OGC manages five-year blocks of committed funding for SCEK (first and second five-year blocks of $5 million each) from the Canadian Association of Petroleum Producers (CAPP) and the Small Explorers and Producers Association of Canada (SEPAC).
The special funding was first announced in an OGC information letter of November 29, 1999, Environmental Fund Announced.
The purpose of the fund is to financially support and facilitate research, technological innovations and demonstrations of findings on environmental issues relating to oil and gas exploration and development in British Columbia. The establishment of the fund fulfills one of industry’s commitments to the Oil and Gas Initiative in 1998. The Oil and Gas Commission will administer the fund.
Revenues for the fund will be collected from oil and natural gas producers and applicants for well authorizations, in accordance with the agreement, as follows:
Approximately 55% of the fund will be collected through the petroleum and natural gas levies charged under the Oil and Gas Commission Levy Regulation. Effective December 1, 1999, the marketable gas levy rate will be increased by $0.02 per 1000 cubic metres from $0.21 to $0.23 per 1000 cubic metres. The petroleum levy rate will be increased by $0.04 per cubic metre from $0.42 to $0.46 per cubic metre. The amendment to the Oil and Gas Commission Levy Regulation is shown in the attachment.
The remaining 45% of the fund will be collected from an increase in the fee for applications for well authorizations. The fee for an application for a well authorization will be increased by $600 per application to $8,400 (from $7,800) effective April 1, 2000 through March 31, 2005. The amendment to the Petroleum and Natural Gas General Regulation is shown in the attachment.
A Scientific Technical Screening Committee will be established to solicit and screen research proposals and make recommendations on proposals to be considered for funding to the Oil and Gas Commission Advisory Committee. The Commission, with the advice of the Advisory Committee, will make final decisions regarding projects.
The 2003 SCEK forum heard results from “17 research projects and studies supported by the Fund”, which included the 2003 cumulative effects report.
In 2002, CAPP and SEPAC pledged their on-going support to the Fund with another $5 million commitment over five years. Additionally that year, the focus of the Fund was changed to encompass not only science-based research, but also community environmental knowledge. Thus, a new name was developed - the ‘Science and Community Environmental Knowledge Fund’. While the current research and funding envelopes will continue, studies of community-based environmental concerns, values and traditional knowledge will be encouraged as well. As before, wherever possible, the results of research projects will be incorporated into: OGC regulatory decision-making; government land use and resource planning; as well as, environmental practices by industry.
At the time of the Forum and Workshop, the Fund was comprised of four knowledge envelopes covering the environmental issues relevant to oil and gas development as follows:
The early focus of Fund research concerned linear disturbance, cumulative effects, air emissions soil and groundwater remediation and reclamation. From the perspective of CAPP and SEPAC, projects on these topics have proven successful in their convergence on a BC focus, broad applicability and immediate deliverables. Moreover, many projects have lowered costs through co-funding while yielding high benefits. Also notable has been the range of those engaged in research including: governments; industry; consulting and contracting companies; universities and colleges; environmental and community groups;and, First Nations. (Highlights of the First Annual Forum and Workshop of the Science and Community Environmental Knowledge Fund. May 29-30, 2003, pages 2-4.)
The following are quotes summarizing AXYS Environmental Consulting Ltd.’s 2003 cumulative effects report to the OGC:
Cumulative impacts in Northeast BC have occurred due to the rapid expansion and relatively high concentration of resource-based industries on the land base, combined with a wide range of other land uses (e.g., recreational use, hunting). Given the high wilderness and traditional use values in the region, concerns have arisen about the capability of the landscape to sustain all of these different land uses during the same time period. A ‘regional’ approach is critical to provide a coherent framework within which management actions can be related to: resource values and uses; other proposals; and, individual decisions.
Such an approach can provide the basis for a sustainable resource management strategy, consistent with BC Government policy directions; however, it is recognized that the above elements are insufficiently developed for this purpose and that further work is necessary to fill information and knowledge gaps. Examples include: the assembly of a regional database; and, refining and testing of indicators, thresholds and screening procedures especially in respect of single project applications to the OGC. In addition, the implementation of this approach will have implications for government ministries, industry, First Nations and other stakeholders and will require extensive consultation.
The Association of BC Forest Professionals' Forestry Oil & Gas Task Force Report
Identified in a Final Draft (5.0) report, Forest Stewardship in Areas with Forestry and Oil & Gas Development in Northeast BC - The Forest Professionals’ Perspective, the Association of BC Forest Professionals (ABCFP) Council directed its Forestry/Oil and Gas Task Force to “examine the apparent issues surrounding impacts of the oil and gas industry on forestry (primarily in northeast BC).” The issue was first presented to the ABCFP’s membership in the May/April 2005 edition of its bi-monthly magazine:
A group of members wrote to the ABCFP expressing concern about planning and practices under authority of the Oil and Gas Commission and how this affects the practice of forestry under the Foresters Act and forest stewardship. Concern was also raised regarding what appears to be a lack of coordinated planning processes with licensees, stakeholders, the Ministry of Forests and the public.... Council directed that a task force be created to investigate the issues raised in the letter and bring forward recommendations to council later this year.
Apparently, it took the Association’s newly appointed Task Force almost two years to produce the final draft 29-page report following a delegated initiative in January 2005:
The purpose of this paper is to encourage an informed and constructive dialogue about how to ensure this happens in areas where expansion of forestry and oil and gas development are sharing, and sometimes competing for the same land base. The primary focus for discussion is northeastern British Columbia ... The Association of BC Forest Professionals (ABCFP) has become aware of increasing concern by several of its members, as well as from local forest-dependent communities, First Nations and others, that the cumulative impacts of industrial development may compromise good forest stewardship in some areas where high timber and oil and gas values exist.
The Task Force started by reviewing the information that led to this matter coming to the Association’s attention, including a letter to the ABCFP General Counsel and Registrar on January 11, 2005. Through a series of conference calls and draft documents, the Task Force identified an initial list of issues. From the initial list a number of “perceptions” about the impact of oil and gas industry operations on forestry were identified, and the Task Force then proceeded to gather information about each perception. The results were organized according to the unique interests of the ABCFP.
According to a summary paragraph, the Task Force reviewed a number of unidentified documents (there is no reference section in the report) and interviewed unidentified government and peer sources. In the same summary, and in two other sections, were comments on a lack of government data on the area impacts of the petroleum industry in northeast BC:
In the process of identifying issues, perceptions and information the Task Force members consulted with peers, and the Association staff person and consultants talked to several people within the government regulatory agencies and both industries. The consulting team also reviewed a number of public and some unpublished documents to determine what activity has been, or is being taken relative to the issues and perceptions identified. Several attempts were made to access current quantitative information on the land-based impact of forestry and oil and gas activities in northeast BC however, as observed later in this report, there are some shortcomings with information management that prevented this. As an alternative, the Task Force found that the most recent Allowable Annual Cut Rationales provided the most credible and readily available information on forest impacts.
One of the perceptions expressed to the task force relates to the impacts of oil and gas development on the productive timber harvesting land base. It is unclear whether this perception arises as a result of the actual physical disturbance, or tangentially as a result of the different planning and regulatory requirements imposed on the two industries by government. The task force was unable to find a current source of detailed information that quantifies area disturbed and productivity impacts of development.
The Task Force found that government departments collect the information they need to carry out their own mandates, but there is no readily available, common, up-to-date data base for managers and practitioners.
Portrayed in polite polemics, the Task Force described the operational and political differences between the forest and petroleum industries, as regulated through separate provincial agencies:
As has been mentioned previously in this paper, surface activities undertaken by oil and gas companies are not as core to their business as for forest companies who manage an area for a sustainable supply of timber – the businesses are very different. Many of the individuals working in the oil and gas sector may not have a historical connection to the forest, and may not be familiar with the expectations and requirements for good forest stewardship. Much of the operational planning and field work for the oil and gas industry is overseen by individuals who reside outside the province and are not forest professionals. This does not necessarily reflect on the quality of work, however it may contribute to the communications challenges discussed previously.
Objectives for an area may be set under the Land Use Objectives Regulation or under the Forest Planning and Practices Regulation respecting management of Crown land and resources (or private land in a Tree Farm License). The Forest Stewardship Plans that govern forest company operations must specify the intended results and strategies that will be carried out to be consistent with the objectives. Clearing for oil and gas development is not legally required to be governed by such plans.
An oil and gas company that has purchased tenure can have exploration and development rights over the same forest area as is covered by the forest company’s plan without any formal linkage between the two. Not only are the tenures held by forest companies and oil and gas companies very different in nature, they are issued and overseen by different government departments. These circumstances create a need for good inter-departmental and inter-industry coordination. While neither is unreasonable to expect, the inter-industry coordination challenge is compounded when, as is often the case, more than one forest company has a license over the same area. This creates a situation where an oil and gas company may have to seek out several forest companies as well as the Ministry of Forests and Range if it wishes to know what forest stewardship plans exist (complete or draft) for an area.
One of the challenges often identified in relation to coordinated development is that responsibility for promoting economic use of resources, licensing (tenure sales), and regulation of industries is divided amongst several different government agencies (e.g., licenses for timber harvesting by the Ministry of Forests and Range, oil and gas tenures by the Ministry of Energy, Mines and Petroleum Resources, permits for oil and gas development activities by the Oil and Gas Commission, licenses for guiding by the Ministry of Environment, etc.). In other words, the legal, financial and institutional relationships between companies and the government are organized by sector, whereas good forest stewardship requires integration at the landscape level.
The Task Force also provided some specific examples of the cross purposes and environmental conflicts between the two industries concerning the placement of seismic lines and access roads:
On the matter of good stewardship, the Task Force heard general perceptions and concerns about the impact of oil and gas industry seismic and drilling programs on forest management.... Many of the issues arise because of systemic weaknesses in planning and communication when more than one industry (and sometimes several companies) are operating on the same land base.
In the past, concerns have often arisen based on the perception that oil and gas exploration and development was impacting the landscape and forest stewardship to a greater degree than was really necessary. For example, extensive seismic programs have been a concern for forest stewardship because of the impact of cut lines made by heavy equipment. Intensive “3D” seismic programs in some areas increased these concerns. Similarly issues arise when several kilometers of road are constructed into a remote area to drill a well; drilling occurs in an area with special forest values; or pipelines disturb key forest values.
Oil and gas companies talk about building a road only to discover that a forest company was planning to build in a similar location in the future and had already done much of the engineering work. Forest companies describe months of consultations and planning to identify and protect key wildlife habitat areas only to have them bisected by seismic lines.
Access roads are often the first major physical disturbance on a landscape, and in some areas introduce significant environmental risk and disruption to non-industrial resource values (e.g. wilderness tourism, wildlife management).... Across BC there are approximately 650,000 kilometers of resource roads - over 14 times the 45,000 km of public roads and this number is expected to increase by up to 30,000 km per year over the next 5-10 years.he ABCFP Task Force presented arguments to facilitate reconciling the provincial government’s failure to institute a “cumulative effects” strategy and program for northeast BC:
The concern that has given rise to this paper involves the combined impact of oil and gas and timber operations on forests in northeast BC. From an ABCFP perspective the underlying issues are the cumulative effects of development on good forest stewardship, and the role of its members. The fact that the issue involves these two industries does not make it significantly different than if the concern involved other sectors, or perhaps only a single industry. What may be unique are some of the underlying causes and circumstances that arise from these two very different industries sharing a common land base.
There is currently no broadly applied mechanism for establishing and reconciling an integrated set of resource development targets or impact thresholds for a given geographic area. Allowable Annual Cuts (AAC’s), formally provide a maximum timber harvest level based on principles of sustainability, and are a de-facto target, but are set for a very large area and are not specific to individual landscapes. There is no similar target or ceiling for oil and gas development. Some work has also been done to help understand the long-term ecological effects of development and suggest management thresholds for cumulative effects in Northeast BC – for example the May 2003 summary report: Approaching Cumulative Impact Management in Northeastern British Columbia, but it is not in general use.
Monitoring the cumulative impacts of development and assessing them against pre-established stewardship objectives is in its infancy, and needs to be better developed and implemented, particularly on landscapes where the intensity of development is, or is expected to be significant. This need exists regardless of the specific industry (ies) or region of the province.
“Cumulative Effects” Strategy in Stagnation
The Association of BC Forest Professional's four-year old report states on page eleven that the Task Force had reviewed the BC Oil and Gas Commission’s March 2003 two-volume methodology proposal report about cumulative effects, A Cumulative Effects Assessment and Management Framework (CEAMF) for Northeast British Columbia. To repeat the statement by the Task Force cited above:
There is currently no broadly applied mechanism for establishing and reconciling an integrated set of resource development targets or impact thresholds for a given geographic area.... There is no target or ceiling for oil and gas development. Some work has also been done to help understand the long-term ecological effects of development and suggest management thresholds for cumulative effects in Northeast BC ... but it is not in general use.
Following this quotation, the Task Force goes on in its report to elaborate and define the legislative and regulatory mechanisms that might actually trigger cumulative effects “targets” and “thresholds”, and concludes that land “clearing for oil and gas development”, as one component of the petroleum industry’s footprint, “is not legally required to be governed by such plans.”
In other words, though there has been a lot of ‘talk’ about taking appropriate cumulative land framework planning ‘action’ since 2003, the Task Force concluded that nothing has been done by the provincial government because it can’t or does not want it (no will) to be done. In a series of five recommendations, the Task Force, limited to its own resource interests, suggests that the provincial government finally ought to do something.
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BC Government. Memorandum of Understanding (MOU) Respecting Operational Land Use Planning for Oil and Gas Activity in Northeast British Columbia. August 14, 1996.
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BC Ministry of Energy, Mines and Petroleum Resources. Conventional Natural Gas Play Atlas - Northeast British Columbia. Petroleum Geology Publication, 2006-01.
BC Ministry of Environment, Lands and Parks. Environmental Guidelines for Seismic and Drilling Operations in Northeast British Columbia (Interim). November, 1994.
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Ritchie, Chris. A Report on the Requirements of the Ministry of Environment for Management of Petroleum Activity in Northeast British Columbia. March, 1986.
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