A summary of the recommendations, and the status and lead agency for each are outlined below.
Recommendation 17: Establish an air-quality task force to oversee implementation of the recommendations in the report.
The Fort McKay Air Quality and Odours Advisory Committee was established in December 2016. The committee is chaired by the AER, Alberta Health, and the Fort McKay First Nation and Métis community, and includes representatives from Alberta Environment and Parks (AEP), Environment and Climate Change Canada, and industry.
Recommendation 8: Clarify who is accountable for supporting the complaint response and notification when ambient air monitoring identifies ground-level concentration exceedances, and ensure that this is captured in the odour response protocol described in recommendation 4.
The Wood Buffalo Environmental Association (WBEA) has been confirmed as the agency responsible for reporting to stakeholders, the AER, and the Government of Alberta (GoA) ground-level concentrations that exceed the Alberta Ambient Air Quality Objectives (AAAQO). WBEA has been responsible for reporting exceedances in the past, but this has now been formalized in the airshed operational contract with AEP.
Recommendation 7: Provide all parties with access to real-time air monitoring data collected by Environment and Climate Change Canada in the Fort McKay community.
Air-quality data from the Oski-ôtin research station is now on the Government of Canada open data portal. Data is available at weekly intervals, typically one week after the data has been collected. Since this information is publicly available, a data-sharing agreement was not required.
Lead: Environment and Climate Change Canada
Recommendation 3: Share oil sands operators’ emergency response plans (ERPs)—or relevant sections—with the community of Fort McKay through a regulatory mechanism.
Industry has provided the relevant information from ERPs to the Fort McKay community. Information was shared without the need of a regulatory mechanism.
Recommendation 1: Monitor ambient air quality for acute concentrations of H2S and SO2 for emergency response in the Fort McKay community. Monitoring should be done by AEP and be funded by industry, and acute thresholds for H2S and SO2 concentrations should be approved by Alberta Health in discussion with Fort McKay.
Work to review the Waskōw ohci Pimâtisiwin air-monitoring station, including the need for additional parameters, is began in November and is being led by Alberta Health and AEP. To support the discussion, the review will begin with the focal parameters list from the Recurrent Human Health Complaints Technical Synthesis to determine which contaminants have an immediate health impact (i.e., are of acute human-health concern).
Recommendation 2: Provide policy guidance on the appropriateness of odour thresholds for emergency response purposes in the community of Fort McKay.
Alberta Health will be conducting a jurisdictional review on the use of odour thresholds during emergencies. Work will begin in early 2018, and the results will be shared with the Fort McKay AQOAC to help determine next steps.
Recommendation 4: Develop an odour response protocol that is specific to the Fort McKay community and consistent with the odour management policy of the GoA.
A draft odour response protocol has been developed and is being tested through a pilot project, which began on November 1, 2017. Joint AER-industry sessions on the protocol were held in October to ensure that oil sands operators understand the procedures and expectations if an odour complaint is received. Testing of the protocol will continue for about six months. Once testing is complete and the protocol has been finalized, the AER and industry will develop an implementation plan.
Recommendation 5: Develop a checklist of operating conditions that an operator is to complete when an odour complaint is received by the AER and the operator is contacted by the AER.
A draft checklist has been developed as part of the odour response protocol (recommendation 4), which is being tested through a pilot project that began on November 1, 2017. See recommendation 4 for more details.
Recommendation 9: Assess fixed- and fugitive-emission sources, focusing on the parameters in the air quality focal parameter list (section 6.6.4 of the report) and on polycyclic aromatic hydrocarbons in order to develop a roadmap for a systematic process for examining the dominant emission sources of the parameters in the focal parameter list.
The subcommittee has reviewed current emission studies and existing monitoring results and measurements to better understand potential emission and odour sources. The next step is to assess and prioritize information gaps to examine dominant emission sources of the parameters in the focal parameter list.
Recommendation 13: Assess the health implications on the Fort McKay community based on the ambient monitoring results, specifically the parameters in the air quality and odorant focal parameter lists (section 6.6.4 of the report) that were in concentrations greater than standards, limits, objectives, and thresholds. The assessment must consider limitations in the data, how applicable the thresholds are to human health, and what it means to the community when parameters are exceeded.
Alberta Health continues to engage with Fort McKay to determine the scope of this recommendation.
Lead: Alberta Health
Recommendation 14: Establish an integrated, consistent approach to air quality monitoring from source (industry emissions) to fenceline (Mildred Lake – AMS02, Mannix – AMS05, Lower Camp – AMS11) to ambient monitoring stations (AMS01 and Oski-ôtin). Changes to monitoring should consider contaminants on the air quality focal parameter list (section 6.6.4). Consider polycyclic aromatic hydrocarbons in future monitoring plans.
AER and AEP will co-chair a subcommittee to address recommendations 14 and 15. Work will include reviewing the way contaminants are monitored at air-monitoring stations in and around Fort McKay. The first subcommittee meeting is expected to be held in January.
Recommendation 15: Improve the consistency in monitoring H2S and total reduced sulphur, including examining individual sulphur compounds under the oil sands’ ambient air monitoring network.
See recommendation 14.
Recommendation 16: Develop and apply ambient air quality policy for parameters that do not have AAAQOs in the areas of odour, ecology, and human health.
Fort McKay AQOAC members are gathering feedback from their respective organizations on potential policy options for managing contaminants identified in the Fort McKay Recurrent Human Health Complaints Technical Synthesis. The feedback will be discussed by the Fort McKay AQOAC in January 2018.
The following recommendations are expected to be implemented starting 2018 because they depend on the implementation of other recommendations.
Recommendation 6: Provide policy guidance on the use and application of odour thresholds in the Fort McKay community, and clarify how the AER uses environmental protection orders under the Environmental Protection and Enhancement Act (EPEA)to address offensive odours.
Recommendation 10: Conduct a targeted examination of emissions control based on the findings from recommendation 9, and implement the controls through a multiyear continuous improvement program.
Recommendation 11: Consider odours generated by project activities when modelling air dispersion for EPEA applications and environmental impact assessments, and review the Air Quality Model Guideline to improve the consistency, among operators, of air dispersion modelling for odours.
Recommendation 12: Review reporting requirements for oil sands EPEA approvals in order to improve the consistency of monthly and annual reporting, units of measurements, and quality assurance and quality control; to include additional parameters with AAAQOs; and to consider transparency and public access to the industry reports.