15 July 2010
Secretary of the Board
National Energy Board
444 Seventh Avenue S.W.
Calgary, AB T2P 0X8
File OF-EP-Gen-AODR 01
PUBLIC REVIEW OF ARCTIC SAFETY AND ENVIRONMENTAL OFFSHORE DRILLING REQUIREMENTS
Dear Ms. Erickson:
Sierra Club Canada hereby requests that the National Energy Board expand the scope of its proposed public review to include a review of environmental and safety rules relating to other unconventional oil and gas development, as called for by the House of Commons in a motion passed unanimously on June 7, 2010.
The House of Commons motion states as follows: ”That this House notes the horror with which Canadians observe the ecological disaster unfolding in the Gulf of Mexico and their call for action to prevent such an event in Canada, and therefore calls on the government immediately to conduct a thorough review and revision of all relevant federal laws, regulations and policies regarding the development of unconventional sources of oil and gas, including oil sands, deepwater oil and gas recovery, and shale gas, through a transparent process and the broadest possible consultation with all interested stakeholders to ensure Canada has the strongest environmental and safety rules in the world, and to report to the House for appropriate action.”
Sierra Club Canada is of the view that the National Energy Board has the required authority under the National Energy Board Act to expand the scope of its review to examine environmental and safety rules applicable to deepwater oil and gas drilling along Canada’s other marine coasts, as well as oil sands, coal bed methane and shale gas development. Under s. 26.(1) of the National Energy Board Act, the Board is required to ”study and keep under review matters over which Parliament has jurisdiction relating to (a) the exploration for, and the production, recovery, manufacture, processing, transmission, transportation, distribution, sale, purchase, exchange and disposal of, energy and sources of energy in and outside Canada”. This is a broad mandate to study and keep under review virtually all aspects of unconventional energy development in Canada.
Sierra Club Canada believes that the environmental and safety issues are similar in all of these types of unconventional oil and gas development. Short of a public inquiry under the Inquiries Act, the National Energy Board is the federal agency best suited to examine information concerning and federal laws, regulations, policies governing the hazards, risks and mitigation measures associated with drilling activities throughout Canada’s offshore, as well as oil sands and shale gas development, and to identify proposed revisions to laws, regulations, policies and measures to both prevent and
respond to accidents and malfunctions.
Sierra Club Canada takes that view that a Gulf of Mexico-type catastrophe could happen not just in the Arctic but in the Atlantic, the Gulf of St. Lawrence and the Athabasca River—wherever oil and gas development has run ahead of regulatory control. Sierra Club Canada urges the National Energy Board to seize this opportunity, and take the initiative to ensure that environmental and safety rules are sufficiently rigorous and resilient to avoid serious spills throughout the unconventional oil and gas industry.
Sierra Club Canada
Sierra Club Canada's comments on preliminary scope of NEB Arctic offshore review
15 July 2010