THE OIL SANDS REPORT CARD - Pembina Institutevi UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada Table of Contents List of Figures Figure 1

SIMON DYER • JEREMY MOORHOUSE • KATIE LAUFENBERG • ROB POWELL

January 2008

THE OIL SANDS REPORT CARD

ENVIRONMENTUnder-Mining

the

SANDSFeverOil

S E R I E S

©®

©®

Simon DyerJeremy MoorhouseKatie Laufenberg

Rob Powell

January 2008

Under-Mining the EnvironmentThe Oil Sands Report Card

ii UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

The Oil Sands Report Card

About The Pembina Institute

About WWF-CanadaWorld Wildlife Fund Canada (WWF-Canada) was founded in 1967 and hasbecome one of the country’s leadingconservation organizations, enjoying theactive support of more than 150,000Canadians. As a member of the WWFglobal network, we actively contributeto the achievement of the organization’smission. WWF-Canada employs a rangeof tools to achieve its conservationresults. These include field research,scientific mapping, policy initiatives,

market solutions and public education.WWF-Canada works closely with localcommunities and others who share thecommon goal of protecting the naturalworld. WWF-Canada’s head office islocated in Toronto, with regional officesin British Columbia, Alberta, NovaScotia and the Northwest Territories.More information about WWF-Canadais available at www.wwf.ca .

The Pembina Institute createssustainable energy solutions throughresearch, education, consulting andadvocacy. It promotes environmental,social and economic sustainability in thepublic interest by developing practicalsolutions for communities, individuals,governments and businesses. ThePembina Institute provides policy

research leadership and education onclimate change, energy issues, greeneconomics, energy efficiency andconservation, renewable energy, andenvironmental governance. Moreinformation about the Pembina Instituteis available at www.pembina.org or bycontacting [email protected] .

The Pembina InstituteBox 7558

Drayton Valley, Alberta, T7A 1S7 Phone: 780-542-6272

E-mail: [email protected]

WWF-Canada245 Eglinton Ave. East,

Suite 410Toronto, Ontario M4P 3J1

Phone: 416-489-4567Email: [email protected]

AcknowledgementsWe thank Imperial Oil, Petro-Canada,Suncor, Shell, Albian Sands andSynenco for participating in the survey and for providing corrections and clarifications to the data. Dr. Joule Bergeron of the Institute for Sustainable Energy, Environmentand Economy at the University ofCalgary reviewed the manuscript and suggested improvements.

We also thank our colleagues ChrisSeverson-Baker, Dan Woynillowicz,Jennifer Grant, Ed Whittingham, MattMcCulloch, Rich Wong, MatthewBramley, Nashina Shariff, LorneJohnson, Julia Langer, Arlin Hackman,Gary Kendall, James Leaton andJonathan Loh for assistance inquestionnaire design, methodologydevelopment and review of the finalreport. An anonymous industry revieweralso provided constructive feedback.

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD iii


Simon DyerSimon is a Senior PolicyAnalyst at the PembinaInstitute. Simon is amember of Pembina’sEnergy Watch team,where his researchfocuses on theenvironmentalimplications of oil sandsdevelopment. Simon isa biologist by trainingand has worked on landuse issues in Alberta’sboreal forest since 1999.Simon represents the

Pembina Institute on the SustainableEcosystems Working Group of theCumulative EnvironmentalManagement Association. He is a co-author of the Death by a Thousand Cuts:Impacts of in situ oil sands developmenton Alberta’s boreal forest and Haste MakesWaste: The need for a new oil sands tenureregime. Simon holds a Master of Sciencein Environmental Biology and Ecologyfrom the University of Alberta, and aMaster of Arts in Natural Sciences fromthe University of Cambridge.

Jeremy MoorhouseJeremy is an Eco-Efficiency Analyst withthe Pembina Institute’s CorporateConsulting team. He provides technicalanalysis for life-cycle value assessmentsfor decision making. Jeremy’s otherprojects include conducting researchinto practicesand strategiesfor sustain-ability,evaluating theperformance ofcurrent andproposed oilsands projects,andquantifying therelative benefitsof differentartificial lifttechnologies.Another key focus of Jeremy’s work isassessing and evaluating emergingtechnologies. His technical backgroundincludes experimental miningequipment design and production, aswell as experimental data analysis. Hehas experience and knowledge in energysystems, water management and solid-waste management. Jeremy holds aBachelor’s degree in mechanicalengineering from McGill University.

About the Authors

iv UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

About the Authors

Katie LaufenbergKatie is an eco-efficiency analystwithin the PembinaInstitute’s CorporateConsulting Group.She works with theCanadian corporatesector by offeringsustainable energy services to progressivecompanies. Key components of her work include

research and analyses on a variety ofrelevant issues including carbon offsets,corporate environmental footprint andwaste reduction strategies, climatechange risk and strategy, and voluntary-sector industry-sector collaboration.Katie was also involved in compilinggreenhouse gas inventories andprojections of fugitive emissions fromthe oil and gas sector for several U.S.states. Katie holds a B.Sc. from theUniversity of Wisconsin-Madison.

Rob PowellRob is WWF-Canada’s Director for the Mackenzie River Basin, where he is concerned both with conserving intact ecosystems and protecting theenvironment from the adverse impactsof industrial development. He recentlyjoined WWF-Canada after a 15-yearstint with the Natural ResourcesConservationBoard. Hestudied ecologyand received a PhD fromthe Universityof BritishColumbia.

January 2008 Printed in Canada

Editor: Margaret Chandler Layout: J&W Communications IncCover Photo / Mining Upgrader: David Dodge, CPAWS

Cover Photo / Mining Truck: © Jiri Rezac, WWF-UK

©2008 The Pembina Institute ISBN 1-897390-06-8

The Pembina InstituteBox 7558Drayton Valley, Alberta T7A 1S7 Canada

Phone: 780-542-6272E-mail: [email protected]

Additional copies of this publicationmay be downloaded from our website,www.pembina.org .

Under-Mining the Environment The Oil Sands Report Card

Executive Summary ...................................................................................................vii

Introduction.................................................................................................................1

Audiences for this report ..........................................................................................2

What are the oil sands?.............................................................................................2

The need for this performance survey ......................................................................3

Projects included in the survey .................................................................................5

Transparency and company feedback .......................................................................6

Methodology ............................................................................................................7

Caution and Disclosure ..........................................................................................12

Survey Results............................................................................................................13

General Environmental Management ....................................................................13

Land .......................................................................................................................19

Air Emissions..........................................................................................................25

Water ......................................................................................................................35

Climate Change......................................................................................................45

Summary....................................................................................................................51

Recommendations .....................................................................................................54

Government ...........................................................................................................54

Industry ..................................................................................................................55

Endnotes ....................................................................................................................57

Table of Contents

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD v


vi UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

Table of Contents

List of FiguresFigure 1 Average annual reclamation rate....................................................................22

(predicted after 20 years for non-active mines)

Figure 2 Project comparison of nitrogen oxide emissions on a per barrel basis...........27

Figure 3 Project-specific sulphur dioxide emissions on a per barrel basis ....................30

Figure 4 Project-specific VOC emissions on a per barrel basis ....................................32

Figure 5 Project-specific water consumption on a per barrel basis ..............................37

Figure 6 Project-specific mature fine tailings production on a per barrel basis............40

Figure 7 Project-specific water storage in days ............................................................43

Figure 8 Project-specific greenhouse gas emissions on a per barrel basis .....................47

List of TablesTable 1 Summary of total project scores.....................................................................viii

Table 2 Detailed project scores .....................................................................................xi

Table 3 Companies included in the oil sands performance survey................................5

Table 4 Activities included in air emissions calculations ...............................................7

Table 5 General environmental management scoring summary table.........................13

Table 6 Summary of land scores per project................................................................19

Table 7 Activities included in air emissions calculations .............................................25

Table 8 Summary of air emissions scores per project ..................................................26

Table 9 Summary of scores for the water section ........................................................36

Table 10 Summary of climate change scores per project .............................................46

Table 11 Summary of total project scores ...................................................................51

Table 12 Immediate improvement opportunities........................................................53

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD vii


Citizens of Alberta, the rest of Canada and abroad are waking up to the reality of the environ-

mental impacts of oil sands mining. Theoil sands are the world’s second largestoil reserve, but the hydrocarbonresource is in the form of bitumen – tarmixed with sand, clay and water. Thetechnologies used to mine, extract andupgrade the bitumen to synthetic crudemake the product among the mostenvironmentally costly sources oftransport fuel in the world.

Information about the actual andproposed environmental performance of individual oil sands operations is noteasily accessible. This report representsthe first attempt to compare theenvironmental performance of all ten of Alberta’s operating, approved and applied for oil sands mines.1

The companies were asked to respond to questions in five categories: generalenvironmental management, land, air, water, and climate.

▲ Oil sands mining has a substantial impact on the environment.PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

Executive Summary

viii THE OIL SANDS MINE ENVIRONMENTAL REPORT CARD The Pembina Institute / WWF-Canada

Executive Summary

The leading operation in our survey wasthe Albian Sands Muskeg River Mine,scoring 56%. The weakest operationswere Syncrude and the proposedSynenco Northern Lights Mine with

scores of 18%. The average score among all oil sands projects was 33%,demonstrating substantial room forimprovement across the oil sandsmining sector.

Operation Percentage Score

Albian Existing (Muskeg River Mine) 56

Total E&P 43

Petro-Canada 37

Shell 37

Suncor 34

Imperial Oil 33

Canadian Natural 31

Albian Expansion (Muskeg River Mine Expansion) 26

Syncrude 18

Synenco 18

AVERAGE SCORE 33

▲ Table 1 Summary of total project scores.

Existing Projects Proposed and Approved Projects

The majority of companies lagged inseveral key areas. For example,

❚ While the majority of oil sandsoperations have comprehensiveenvironmental policies in place, onlyAlbian Sands and Imperial Oilprovided evidence of having anindependently accreditedenvironmental management systemsuch as ISO 14001.

❚ With the exception of the existingAlbian Muskeg River Mine, nooperation has voluntary targets tolimit absolute greenhouse gasemissions.

❚ No project or company has publiclyreported water intensity reductiontargets.

❚ Despite over 40 years of oil sandsdevelopment, not a single hectare ofland has been certified as reclaimedunder Government of Albertaguidelines.

❚ No project scored well across all areas.

❚ The proposed expansion of theAlbian Muskeg mine is set to performto lower standards than the existingAlbian Muskeg operation.

Clearly, there is substantial room forimprovement in the environmental per-formance of oil sands mining operations.

One set of questions was designed todetermine which projects demonstrate aprogressive approach to environmentalmanagement through their participationin exemplary management practicessuch as independent performanceverification, mitigation and monitoringefforts, and voluntary performancetargets in the absence of clear regulatoryrequirements. By this measure, there arethree leading operations: the currentAlbian Sands Muskeg River project,Suncor’s current operation and Shell’sJackpine mine. Even these projects didnot realize environmental excellenceoverall. The environmental performanceof the industry as a whole could beimproved dramatically if the progressivemanagement practices of the leaderswere adopted across the board. Giventhe relatively inconsistent application ofvoluntary best practices by the oil sandssector, the Pembina Institute andWWF-Canada recommend thatgovernment play a more active role inensuring the environment is protectedduring oil sands mining.

The lack of ambition and regulatorydrivers is demonstrated by the fact thatthe proposed expansion of the Albianproject scores lower than the existingoperation.

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD ix

Executive Summary

x UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

Executive Summary

Another set of questions was designed toexamine the environmental impacts ofproducing a barrel of bitumen in termsof water use and the production ofemissions and mature fine tailings. We discovered that projects that led inone category were often not the leadersin another. Albian Sands’ existingMuskeg River project and Shell’sJackpine project reported the lowestemissions of NOx, SO2 and VOCs perbarrel of bitumen, Total E&P’s JoslynNorth project reported the lowestmature fine tailings production perbarrel, Petro-Canada Oil Sands FortHills anticipates the lowest water useand Canadian Natural’s Horizon projectreported the lowest greenhouse gasemission intensity. A degree of cautionmust be applied in comparing thenumbers supplied to us by the companiesbecause most are estimates for not-yet-built projects rather than provenmeasured values. Certainly, minor

differences may be more apparent thanreal. Nevertheless, the range of values for some of the environmental impacts issubstantial. We estimate that if all projectsimproved their operations to match theperformance of the current industryleaders, the industry as a whole couldmake significant reductions in pollutionand water use. See chart, Page xii.

Oil sands companies can use this report to compare their environmentalperformance to that of their peers. ThePembina Institute and WWF-Canadahope this comparison will inspire allcompanies to achieve what the currentleading performers have achieved orhave indicated they can achieve basedon existing technologies and bestpractices. Beyond this immediate step,there is a need to improve environ-mental performance in the oil sandsfurther and develop new strategies to limit cumulative impacts on the environment.

The boreal forest ofnorthern Alberta will

be dramaticallyaffected if plans

to exploit oil sands on 140,000 km2

are carried out.PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

▲

EnvironmentalManagement Land Air Emissions Water Climate Change ∑ ÷ Final

Score

Project Policy ManagementSystem

PublicReporting

RegulatoryCompliance

CertifiedLand

ReclamationLiability

ReferenceSite

BioMonitoring

ReductionTargets NOx SO2 VOC Water

Intensity

WaterIntensityTargets

MFTIntensity Withdrawal Water

Storage

GHGAbsoluteReductionTargets

GHGIntensity

Per Barrel

EmissionIntensityTargets

TotalCompany

Score

Total Points

Possible %

Albian Sands Energy Inc– MUSKEG EXISTING 1 1 1 1 N/A 0.5 0 1 0 0.5 1 1 0 0 0 0 0 N/A 1 1 10.00 18 56%

Total E&P Canada – JOSLYN NORTH MINE PHASES 1 & 2 1 0 N/A N/A N/A 1 0 1 0 0.5 1 0.25 1 0 1 0 0.5 0 0 0 7.25 17 43%

Petro-Canada Oil Sands Inc. – FORT HILLS 1 0 N/A N/A N/A 0.5 0 1 0 0.25 0.5 1 1 0 0 0 1 0 0 0 6.25 17 37%

Shell Canada Ltd.– JACKPINE PHASE 1 1 0 N/A N/A N/A 1 0 1 0 1 0.25 1 0.25 0 0.5 0 0 0 0.25 0 6.25 17 37%

Imperial Oil Resources Ventures Ltd. – KEARL P1,2 & 3 1 1 N/A N/A N/A 0.25 1 0 0 0 0.5 0 1 0 1 0 0 0 0 0 5.75 17 34%

Suncor Energy Inc. – CURRENT OPERATIONS

1 0 1 0.5 0 0 1 1 0 N/A N/A N/A N/A 0 0.5 0 0 0 N/A 0 5.00 15 33%

Canadian Natural – HORIZON 0.5 0 N/A N/A N/A 0.25 0 0 0 0 1 0 1 0 1 0 0.5 0 1 0 5.25 17 31%

Albian Sands Energy Inc. – MUSKEG EXPANSION 1 1 N/A N/A N/A 0.5 0 1 0 0 0 1 0 0 0 0 0 0 0 0 4.50 17 26%

Syncrude – CURRENT OPERATIONS 1 0 1 0 0 0.25 0 0 0.5 N/A N/A N/A N/A 0 0 0 0 0 N/A 0 2.75 15 18%

Synenco Energy Inc.– NORTHERN LIGHTS PHASES 1 & 2 0 0 N/A N/A N/A 0.5 0 0 0 0 0.5 0 1 0 1 0 0 0 0 0 3.00 17 18%

Project Scoring Summary Table

▲ Table 2 Detailed project scores

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD xi

Executive Summary

xii UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

Executive Summary

The immediate performance gapThe results of our survey show a broadrange of performance across manyindicators. If all oil sands miningoperations could match the environ-mental performance of the currentindustry leader, there would be substan-tial ecological benefits. Assuming allmines at full production:

❚ If all mines had the same greenhousegas emissions intensity proposed byCanadian Natural Horizon (23.34 kgCO2e (carbon dioxide equivalent) perbarrel of bitumen produced), Albertawould avoid 6,339,662 tonnes CO2eeach year – a savings of 66%. Thisrepresents almost 3% of Alberta’sannual GHG emissions!2

❚ If all mines had the same VolatileOrganic Compound emissionsproposed by Petro-Canada (86 gramsper barrel of bitumen), annualemission rates would be reduced by47% from 96 kt to 50 kt annually.

❚ If all mines had the same NOxintensity proposed by Shell Jackpine(113 grams per barrel of bitumen),

annual emission rates would dropalmost 80%, from 75 kt to 15 ktannually.

❚ If all mines had the same SO2

intensity as Canadian NaturalHorizon (14 grams per barrel ofbitumen), annual emission rateswould be reduced by 47%, from 15 kt to 8 kt annually.

❚ If all oil sands mines adopted the dry tailings technologies proposed by Synenco Northern Lights and Total Joslyn, the environmental hazard of mature fine tailings at the end of a mine’s life would becompletely eliminated.

❚ If all mines had the same waterintensity proposed by Petro-Canada(0.20 m3 of water per barrel ofbitumen produced), oil sands minescould reduce water consumption byalmost 60% annually.

All figures in this best performer sectionassume mines at maximum productionand do not include data from the Suncoror Syncrude mine operations since theydo not report impacts based on barrels of bitumen produced.

Potential annual environmental benefit through oil sands operations meeting performance standards of current industry leaders

15,000 tonnes of NOx8,500 tonnes of SO2

50,000 tonnes VOCs6,000,000 tonnes GHGs

73,500,000 cubic metres of water

The Pembina Institute / WWF-Canada UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD 1


Introduction

WWF-Canada and thePembina Institute havecollaborated to assess the

environmental performance of oil sandscompanies and to provide thisinformation to the public. Theassessment presented in this report isbased on a survey sent to all theproposed and active oil sand miningprojects in northeastern Alberta. Itincludes an examination of thecommitments and activities undertakenby oil sands companies to minimize thecumulative effects of mining projectdevelopments on land, air, water andclimate through emissions of greenhousegases. We also examined the actual andanticipated environmental costs of

producing a barrel of bitumen for builtand proposed projects respectively.

A survey was sent to all the proposedand active oil sands mining projects innortheastern Alberta. The PembinaInstitute and WWF-Canada intend torepeat the survey in the future with thehope of charting progress toward moreresponsible oil sands development.

The Pembina Institute and WWF-Canada researchers completed thesurvey with as much detail as possiblefrom publicly available sources such asEnvironmental Impact Assessments,Corporate Social Responsibility andSustainability reports and other publicdocuments. It should be noted thatproject plans are constantly being updated.

▲ Toxic tailings ponds filled with liquid mine wastes already cover more than 50 square kilometresPHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

2 UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada

Introduction

The information we collected couldbecome outdated, and not reflect on-the-ground improvements in environ-mental performance. In order to accountfor this, we provided completed copiesof the surveys to all the companiesassessed in this report in June andrequested that the information bechecked and updated if necessary. After updating the results, we provideda summary of all the results to all oilsands companies in September andprovided a second opportunity tocomment on the results. In total, six out of nine oil sands companiesparticipated in the survey.

Audiences for this reportKey audiences for this report include theinvestment community, particularlysocially responsible investmentcompanies. All Albertans and Canadianswho could be impacted by oil sandsoperations may have an interest in theseresults, as well as First Nations andMétis communities in the vicinity ofand downstream from the FortMcMurray region. These findingsshould be of interest to governmentdepartments charged with monitoringoil sands environmental performance.Other interested individuals may be theemployees of oil sands companies andconsumers, who may wish to makeinformed decisions about the upstreamsource of their petroleum products, suchas gasoline.

The survey may also be of use toindividual companies for stewardshipreporting and benchmarking purposes,and for providing quantifiable objectives

and performance measures that are of interest to external stakeholders. We hope that this report will promptdialogue about what constitutes anacceptable level of environmentalperformance for oil sands companies.Improvements in environmentalperformance are badly needed across theoil sands mining industry.

What are the oil sands?Oil sands are composed of sand, silt,clay, water and about 10-12% bitumen,a tar-like substance that can beupgraded into synthetic crude oil.Upgrading occurs either in FortMcMurray, in the Fort Saskatchewanregion of central Alberta or outsideAlberta. In order to consistentlycompare the impacts and environmentalmanagement systems of oil sandsmining companies, the scoring in thisassessment compares the mining andextraction of oil sands only.

Oil sands underlie more than 140,000km2 of the province of Alberta – an area greater than the size of Florida.3

Currently 54,000 km2 of lands inAlberta have been leased for oil sands development,4 with more landsleased in government “land sales” every two weeks.5

The Alberta oil sands include 173billion barrels of recoverable bitumen.6

Where oil sands are close to the surface(< 100 m), they are strip-mined fromopen pits. Most of Alberta’s oil sands aredeeper and must be heated so thebitumen can flow to a well and bepumped to the surface. This is called insitu (Latin for “in place”) extraction.


Introduction

The majority of Alberta’s oil sandsproduction currently comes from oilsands mining, but in situ productionwill become the dominant extractionmethod in the coming decades. ThePembina Institute and WWF-Canadahave plans for a future survey that willassess the environmental performance of in situ oil sands operations.

A typical oil sands mine project inAlberta involves billions of dollars ofcapital investment,7 has an operationsworkforce of over a thousand people8

and a lifespan of over 50 years.9 As easily accessible conventional sources of oil are depleted worldwide, there is an increasing focus on unconventionalsources of oil. This analysis considered10 oil sands mining projects, proposedand operated by nine companies,together representing a potentialmaximum production of approximatelytwo million barrels of bitumen per day.

The need for this performance surveyCitizens of Alberta, the rest of Canadaand abroad are waking up to the realityof the environmental impacts of oilsands mining. Some examples includethe following:

❚ In over 40 years of oil sands miningoperations not a single hectare of landhas been certified as reclaimed by theGovernment of Alberta. Nonetheless,3,000 km2 of boreal forest has beenleased for oil sands mining.

❚ Roughly 500 square kilometres ofland surrounding current oil sands

operations are at risk from acidifyingemissions from current and approvedprojects. This will increase to 1,000km2 if all planned projects go forward.10

❚ Oil sands mining operations arelicensed to divert 349 million m3 ofwater per year from the AthabascaRiver, twice the amount of water used by the City of Calgary.

❚ Currently Syncrude’s and Suncor’smining operations are the 3rd and6th largest emitters of greenhousegases in all of Canada.11

Mining and extracting bitumenproduces a host of environmentalproblems that contribute to thecumulative environmental degradationof the oil sands region. A full descriptionof the environmental impacts associatedwith oil sands extraction can be foundin the Pembina Institute Report, Oil Sands Fever: The EnvironmentalImplications of Canada’s Oil Sand Rush,available at www.pembina.org/pub/203.The challenge of managing thecumulative effects of the industry hasnot been helped by the weak regulatoryenvironment in Alberta, whichemphasizes voluntary efforts on the partof industry over regulatoryrequirements. Companies that haveadopted voluntary measures deservecredit for their progressive approaches.Nevertheless, even the more responsiblecompanies may be contributing toirreversible damage to Alberta’s naturalcapital. A summary of the PembinaInstitute’s perspective on the appropriatemanagement of the cumulativeenvironmental and social impacts


Introduction

of oil sands development is presented in A Blueprint for Responsible Oil Sands Development, available atwww.pembina.org/pub/1404.

Other resource industries haveimplemented mechanisms to enablesignificant third-party scrutiny andvalidation of environmental performance.There are currently no third-partymechanisms in place to monitor orvalidate environmental performance in the oil sands industry. The operatorsemploy a range of strategies withvarying environmental consequences.

Despite these concerns, reliableinformation about the environmentalimpacts of the oil sands industry isdifficult to find. There is little compar-

ative information about the actual andproposed environmental performance of individual oil sands operations andfar too little discussion of best practicesavailable to oil sands developers.

The Canadian Association of PetroleumProducers (CAPP) produces an annualstewardship report that compiles anumber of industry-wide social andenvironmental indicators.12 This is not a comprehensive set of environ-mental indicators and does not reporton a project-specific basis. Our reportprovides a reasonably comprehensiveassessment of project-specific approachesto environmental management andenvironmental performance measures.

▲ The oil sands are Canada’s fastest growing source of greenhouse gas emissionsPHOTO: DAVID DODGE, THE PEMBINA INSTITUTE


Introduction

Projects included in the surveyOil sands projects that were operating,approved or seeking approval in January2007 were included in this survey. Table 3 summarizes the projects.

The Suncor Voyageur South, ShellJackpine Expansion and Pierre RiverMines announced after this survey was begun are not included in the 2007assessment but will be included insubsequent surveys.

▼ Table 3 Companies included in the oil sands performance survey.

Company Project Startup Date Status Production

(bitumen bbl/d)Participated insurvey (Y/N)

Albian Sands Energy Inc 13

Muskeg River Existing 2002 Operating 150,000Yes

Muskeg Expansion 2010 Approved 120,000

Canadian NaturalHorizon – Phase 1 2008 Construction 135,000

NoPhase 2 & 3 2011 Approved 135,000

Imperial Oil Resources Ventures Ltd. 14

Kearl Lake Phase 1 2010 Approved 100,000

Yes Phase 2 2012 Approved 100,000

Phase 3 2018 Approved 100,000

Petro-Canada Oil Sands Inc. 15

Fort Hills Phase 1 & 2 2011 Approved 100,000 Yes

Fort Hills Phase 3 & 4 2014 Approved 90,000

Shell Canada Ltd. 16Jackpine Phase 1A 2010 Construction 100,000

Yes Jackpine Phase 1B 2012 Approved 100,000

Suncor Energy Inc. Current 1987 Operating 260,000 17 Yes

Syncrude Canada Ltd. 18 Current 1978 Operating 214,000 17 No

Synenco Energy Inc. 19Northern Lights Phase 1 2010 Application 57,250

Yes Phase 2 2012 Application 57,250

Total E&P Canada 20Joslyn Mine Phase 1 2013 Application 50,000

No Phase 2 2016 Application 50,000

TOTAL PRODUCTION 1,918,500


Introduction

Transparency and company feedbackThe Pembina Institute providedcompleted copies of the survey to allcompanies in June 2007. Afterproviding the results to all the oil sandsmining companies, staff of the PembinaInstitute contacted all companies by

telephone and by electronic mail tosolicit feedback on the accuracy of thedata presented. Canadian Naturalcontacted the Pembina Institute andraised concerns about omissions fromthe report, which were addressed. Petro-Canada Oil Sands Inc., Albian SandsEnergy Inc., Shell Canada Ltd., SuncorEnergy Inc, Synenco Energy Inc andImperial Oil Ltd. all verified theinformation in the survey and providedadditional information about theiroperations. Syncrude Canada Ltd. andTotal E&P Canada did not respond torequests to participate in the survey.After incorporating changes andcontacting the Government of Albertafor further information, the companieswere ranked according to themethodology described below in themethodology section. A number of

questions were dropped from the finalassessment due to the poor quality ofinformation. A draft copy of theassessment results, including all the rawdata used in the assessment, wasprovided to companies in September2007 to provide a second opportunityto clarify company commitments orprovide updated information onenvironmental performance.

As a condition of oil sands approvals,companies submit annual summaries oftheir environmental performance to theAlberta government. Unfortunately, thegovernment does not make thisinformation readily available to thepublic. The Government of Alberta doesnot provide an online summary of oilsands project environmentalperformance, and it is difficult for thepublic to obtain this information. Staffof the Pembina Institute visited theAlberta Environment library inEdmonton to view some of the publiclyavailable information. The very limitedsummary information about oil sandsenvironmental performance that ispresented by government is often out ofdate. For example, the Oil SandsReclamation graph on AlbertaEnvironment’s State of the Environmentwebsite is complete to only December2003 – almost four years out of date.21

Information on Alberta governmentenvironmental enforcement actions,which formed part of our assessment, canbe obtained for a fee from the Environ-mental Law Centre.22 The Governmentof Alberta was unable to providesummaries of ambient air exceedances for the oil sands region. This informationwas obtained from companies directly or from their annual reports.

▲

Oil sandscompanies

must remove 4 tonnes

of material to produce

a single barrel of oil.PHOTO:

© JIRI REZAC, WWF-UK


1

Introduction

2

3

Oil Sands Operations Emission Sources

Mine Fleet Mine Face Fugitive Emissions

Processing Plants Electricity Production (on or offsite) Offsite Natural Gas Production

Tailings Ponds Facility Heating

▲

Table 4Activities

included inair emissionscalculations.

MethodologySURVEY DEVELOPMENTWe hoped to receive feedback from each of the companies included in thissurvey. Nonetheless, the survey wasdesigned so it could be completed in theevent that the companies were unable orunwilling to provide feedback. With thisconstraint in mind, the survey is brokendown into five broadly recognized areasof environmental performance andmanagement: general environmentalmanagement, land management, airpollution, water management andclimate change:

General Environmental Management

This section concerns principles ofenvironmental management that arevalid for any natural resource-basedcompany or project. These includedevelopment of an effective environ-mental policy, a strong legal compliancerecord with respect to environmentalissues, a third-party validated environ-mental management system and trans-parent public reporting of environ-mental aspects associated with a project.

Land Management

The oil sands are overlain by Alberta’sboreal forest. The boreal forest is amixture of deciduous and coniferoustrees on upland sites and wetlands. The Mineable Oil Sands Area (MOSA)23

defined by the Alberta government is approximately 3,000 km2, an areaapproximately four times the surfacearea of the city of Calgary. To mine the bitumen in the oil sands, rivers must be diverted, wetlands drained and all vegetation and non-oil-bearingoverburden removed. This sectioncontains indicators relating to reclamationstrategies and performance, monitoringof impacts on biodiversity and companyleadership in supporting establishmentof protected areas in the boreal forest.

Air Emissions

Oil sands projects are major emitters ofmany chemical pollutants. Air emissionsof particular importance in the oil sandsinclude nitrogen oxides (NOx), sulphurdioxide (SO2) and volatile organiccompounds (VOCs). All three emissionstypes contribute to smog, have potentialhuman health impacts and in the case of NOx and SO2 are contributors toacid rain. This section reports on projectemission levels and voluntary companytargets to reduce air pollution.

4


Introduction

One of the goals of this survey was to quantify NOx, SO2 and VOCemissions for each project in order tohighlight best practices. For this analysisto be meaningful the data collected for each project had to be comparable. This proved to be more challengingthan expected for several reasons.

One challenge is that all operations aredesigned slightly differently and do notcontain the same facilities onsite. Forexample, the Albian Muskeg River MineExpansion will obtain electricity fromthe Alberta electrical grid, unlike thecurrent Albian Muskeg River Mine,which has an onsite cogeneration facilityto produce electricity and process heat.If we had included only onsite emissionsources, the expansion project wouldlook significantly better, but this wouldobscure the fact that air pollution isbeing emitted elsewhere to supply theexpansion project. To address thisconcern, we developed a list of emissionsources associated with activities that allmines have in common. Taking thisapproach ensures that the air emissionvalues we calculated are comparablebetween projects. Table 4 contains thelist of activities considered.

Secondly, both Suncor and Syncrudeoperate not only oil sands mines but also upgraders and in the case of Suncor in situ operations as well. The companies report these emissions as a single number making it impossibleto determine air emissions for just their mining operations. Suncor’s andSyncrude’s air emissions are thereforenot comparable with the other projectshere and have not been scored relativeto the other projects on NOx, SO2

and VOC emissions.

Water Management

Oil sands operations are large users offresh water. It takes 2-4.5 barrels ofwater to extract and upgrade a singlebarrel of oil from an oil sands mine.24

Approved oil sands mining operationsare licensed to divert 349 million cubic metres of fresh water from the Athabasca River per year; this is expected to increase to more than 500 million cubic metres per year ifproposed projects are also approved.25

Winter flows in the Athabasca Riverhave declined in recent decades and aresometimes low enough to impact fishhabitat and fish populations,26 yet oilsands companies are currently allowedto withdraw water even when river levels are dangerously low. Current and proposed projects would beresponsible for withdrawing up to15.7% of the river flow during low flow periods.27 This section concerns oil sands company water use, manage-ment strategies in place to protect the Athabasca River during periods of low flow and management of liquidmine wastes, known as mature finetailings (MFT).

▲

The number of operatingmines in the Fort McMurrayregion is set toincrease rapidlyover the nextseveral years.PHOTO: © JIRI REZAC, WWF-UK

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Climate Change

Extracting bitumen from the oil sands is very energy intensive; and, as a result,oil sands mine operations are majoremitters of greenhouse gases (GHGs).Syncrude’s and Suncor’s oil sandsmining operations are Canada’s 3rd and 6th largest emitters of GHGsrespectively.28 Syncrude emitted 10.3 million tonnes of GHGs in 2005, equivalent to the emissions of 2.7 million personal vehicles.29

The data used for this section of the reportare derived in the same manner as thatdiscussed in the air emissions section.

Disciplinary specialists in emissions,water, land management and industrialwaste at the Pembina Institute createdrepresentative questions addressingenvironmental performance and

commitments to continually minimizeenvironmental effects. Although thesurvey does not address all aspects of environmental performance, thePembina Institute and WWF-Canadaare confident that the indicators selectedare representative of the environmentalmanagement challenges facing the oilsands and comprehensive enough tomeaningfully rank oil sands companycommitments and environmentalperformance. The Global ReportingInitiative (GRI) seeks to improveconsistency in company reporting on sustainability performance.30

Many of the indicators in this survey are consistent with GRI performance,while other indicators are related tospecific oil sands mine-relatedenvironmental management issues.With each question, we describewhether this is a measurement alsorecommended by GRI.

▲ Air quality problems are increasing around the oil sands. PHOTO: © JIRI REZAC, WWF-UK


Introduction

Project Names For ease of reading, from now on in thereport the operations will be referred toas abbreviations of their lead companyname (e.g., Imperial, for Imperial OilResources Ventures Limited). AlbianSands Energy Inc. has two projects thatwill be referred to as Albian Existingand Albian Expansion, Petro-CanadaOil Sands Inc. Fort Hills project will bereferred to as Petro-Canada, Shell CanadaLtd. – Jackpine will be referred to asShell, Syncrude Canada Ltd. will be referred to as Syncrude, SuncorEnergy Inc. will be referred to as Suncor,Synenco Energy Inc. – Northern Lightswill be referred to as Synenco and Total E&P Canada – Joslyn Mine will be referred to as Total E&P.

ScoringFor each environmental indicator weidentify leaders and laggards and scorethe projects accordingly. For yes/noquestions, a project receives either 1 or 0 points. In limited circumstances we provide 0.5 points for partiallyachieving an indicator. The appendicesprovide a summary of the data includedin the survey. For more information on the quantitative data included in this report, please contact the PembinaInstitute at http://www.pembina.org.

For continuous indicators, such asGHG emissions per barrel of bitumen,projects were ranked in quartiles fromhighest to lowest performer. Projectswithin 25% of the top performer weregranted full points for that question.

▲ In total more than 3,000 square kilometres of forests and wetlands are projected to bemined to extract bitumen from the oil sands. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE


Introduction

Projects performing within 25-50% ofthe top performer were granted 0.5points, projects performing within 50-75% of the top performer were awarded0.25 points and projects in the bottomquartile were awarded zero points. Usingthis relative scale clearly distinguishesthe leaders and laggards among projects,but it does not indicate whether the bestperformer is truly a leader in an absolutesense. For example, the lowest green-house gas intensity project is awardedfull marks under this methodology.However, this does not mean the topproject cannot improve further; it issimply the best relative to its peers.

Our intention was to have five questionsin each of the five sections: generalenvironmental management, land, air,water and climate. However, datalimitations and technical difficultiesinherent in comparing existing projectswith proposed projects forced us toabandon some questions. There are now20 questions with 3 to 5 per section.

One set of yes/no questions wasdesigned to determine which projectsand companies demonstrate aprogressive approach to environmentalmanagement by participating inexemplary management practices such as independent performanceverification, mitigation and monitoringefforts, and voluntary performancetargets in the absence of clear regulatoryrequirements. An operation that hasadopted a number of these managementpractices is clearly making an effort toaddress its environmental impacts.

The remaining questions consider theenvironmental impact associated withthe production of a barrel of bitumenfrom each operation, in terms of water

use, air emissions, land impacts andGHG emissions.

We aggregated the scores from theindividual questions to facilitate overallcomparisons among projects and amongcompanies. We calculated an overallproject score for each project as thepercentage of the possible total for allquestions. Where a project was scored as not applicable (N/A) on any question,that question was not included in thecalculation. This was particularlyrelevant to proposed projects that have not demonstrated a legalcompliance record.

Syncrude and Suncor are integratedprojects that do not segregate theemissions and impacts of their miningoperations from their upgradingoperations in their company reports.Suncor’s and Syncrude’s data for GHGproduction, water use and air emissionsare presented as intensities per barrel ofsynthetic crude oil (SCO) for miningand upgrading. Suncor’s data alsoincludes emissions from its in situoperation, Firebag. This made itdifficult to compare these operationswith other active and proposed minesfor some of our questions. Suncor andSyncrude were not penalized for thissince these questions were not includedin the calculation of their final scores.However, their scores are based on farfewer questions than the other projects.

We believe Suncor and Syncrude shoulddisaggregate their data and report theimpacts associated with mining operationsseparately. In order for a company to manage its impacts effectively andidentify areas needing improvement, it must be able to distinguish betweenthe different aspects of its operation.


Introduction

Caution and DisclosureOil sands development in Alberta is in a state of rapid expansion. Of thecompanies assessed in this report,Albian, Suncor and Syncrude haveactive mining operations, other miningcompanies have project approvals andare at the construction phase, andfurther companies have applicationsseeking regulatory approval.

We believe that this report represents the most comprehensive and rigorousassessment of comparative environ-mental performance of oil sands miningoperations that is publicly available. This report focuses on the projected andcurrent environmental performance ofoil sands mine operations only. It doesnot consider corporate governance issues,the health and safety of employees, orthe performance in consultation andaccommodation of aboriginal interestsby oil sands companies. For information

about other indicators, readers areencouraged to examine other sourcessuch as Jantzi Research31 or InnovestStrategic Value Advisors.32 The survey isbased on a broad assessment of potentialenvironmental impacts and companymitigation strategies.

This report should be considered a snap-shot of environmental performance,based on data that was available duringour analysis period. Companies updatetheir performance regularly. For example,Syncrude released a new SustainabilityReport in late 2007, after our analysisfor this survey was completed.

In addition to its research and advocacyrole, the Pembina Institute providescorporate consulting services to industry,government and First Nations. Since2006, Pembina Corporate Consultinghas provided work for Suncor EnergyLtd. and Shell Canada Ltd. This hasneither influenced the development nor the results of this survey.

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This section concerns principles ofenvironmental management thatare valid for any natural resource-

based company or project. Theseinclude development of an effectiveenvironmental policy (question 1); a third-party validated environmentalmanagement system (2); a strong legalcompliance record with respect to envir-onmental issues (3); and transparentpublic reporting of environmentalaspects associated with a project (4).Mines currently operating are scored

based on all four questions. Proposedand approved (but not operating) minesare scored on questions 1 and 2 only.

General EnvironmentalManagement SummaryTable 5 summarizes the score per project per indicator and provides thetotal per project score for this section.Only active projects were scored on all four questions.

eneral Environmental Management G

▼ Table 5 General environmental management scoring summary table.

Project EnvironmentalPolicy

Environmental MS

Public Reporting

RegulatoryCompliance

Albian Existing 1 1 1 1

Albian Expansion 1 1 N/A N/A

Canadian Natural 0.5 0 N/A N/A

Imperial 1 1 N/A N/A

Petro-Canada 1 0 N/A N/A

Shell 1 0 N/A N/A

Suncor 1 0 1 0.5

Syncrude 1 0 1 0

Synenco 0 0 N/A N/A

Total E&P 1 0 N/A N/A


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The Oil Sands Report Card S U R V E Y R E S U L T S

RATIONALEThe environmental policy is thefoundation of a company’s environ-mental management system and itsconstruction.33 A key aspect of anenvironmental policy compliant with ISO 14001 is that it includes a commitment to continuousimprovement in environmentalperformance.34

✪ LEADERS

Albian, Imperial, Petro-Canada, Shell, Suncor, Syncrude, Total E&P The majority of oil sands companieshad comprehensive environmentalpolicies that made an explicitcommitment to continuousimprovement in environmentalperformance.

✦ MIDDLE

Canadian Natural Canadian Natural has a CorporateStatement of Environmental Protection,but it does not address continuousimprovement in environmentalperformance.

✤ LAGGARDS

SynencoSynenco states that it is still in theprocess of developing a comprehensiveCorporate Responsibility Policy.35

1 ENVIRONMENTAL POLICYDoes your company have an environmentalpolicy that commits to continuous improvementin environmental performance?

▲ Oil sands companies acknowledgethat many wetland habitats cannotbe restored after mining.PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE



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RATIONALEISO 14001 is an internationallyrecognized standard for an environ-mental management system. It has clear requirements for establishing anenvironmental policy, determiningenvironmental risks and setting goals to reduce environmental impacts. Thirdparty validation of an environmentalmanagement system provides externalevidence of the rigour of the environ-mental management system. AlthoughISO 14001 does not provide standardsfor environmental performance, it doesprovide a globally recognized frameworkfor developing an environmentalmanagement system.

✪ LEADERS

Albian, Imperial Albian has the only project-specific oilsands mine environmental managementsystem that appears to be independentlyaccredited to the ISO 14001 standard.Imperial’s Corporate OperationsIntegrity Management System is alsoISO 14001 accredited.

✦ MIDDLENone

✤ LAGGARDSNo other company provided evidencethat they have independently accreditedenvironmental management systems.Shell does, however, have a commitmentto have all major plants certified to ISO 14001 or similar.36

2 ISO 14001 CERTIFICATIONDoes your oil sands operation have an environ-mental management system that has beenaccredited by an independent third-party, suchas ISO 14001 or equivalent?

Most oil sands mining operations donot have independently accreditedenvironmental management systemsthat would help minimize impacts tothe environment.PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

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RATIONALEPublic reporting in this sense meansmaking project-specific environmentalparameters directly available to thepublic through company websites andannual sustainability reports. Publicreporting by companies is importantbecause they have an obligation to betransparent. Only active projects areincluded in this indicator.

✪ LEADERS

Albian Existing, Suncor, Syncrude All the active oil sands mine companiesproduce sustainability reports thatsummarize environmental impacts.However, because of operationaldifferences between projects, it remainsdifficult to compare the data fromdifferent companies. Suncor andSyncrude, for example, do not break outenvironmental indicators for individualmining operations. However, they doreport on environmental indicators fortheir entire oil sands operations.

✦ MIDDLENone

✤ LAGGARDSNone

3 PROJECT-SPECIFIC INDICATORSDo you publicly report annual project-specificenvironmental indicators, e.g. greenhousegases, nitrogen oxides, sulphur dioxide, volatileorganic compounds and water use?

▲ Lack of consistency in reporting between oilsands operators and a shortage of comparativeinformation provided by Government makes itchallenging to compare the environmentalperformance of oil sands mines.

PHOTO: © JIRI REZAC, WWF-UK



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RATIONALEMeeting all applicable environmentallaws is a key component of environ-mental management for any oil sandscompany. This is a recognized metricand is included in the global reporting

initiative guidelines.37 Only active minesare considered in this indicator. We usedthe period 2005-2006 for reporting ofthis indicator because this correspondswith recent available data during theanalysis period.

4 REGULATORY COMPLIANCEPlease summarize all ambient air exceedancesand all environmental enforcement actions(including warning letters, prosecutions, fines,etc.) in 2005-2006 for this oil sands operation.

▲ Oil sands operations remove rivers, forests and wetlands in order to access the oil sandsbeneath. PHOTO: © JIRI REZAC, WWF-UK


✪ LEADERS

Albian Existing Albian had no environmental regulatoryenforcement actions in 2005/2006 andreported no ambient air exceedances.

✦ MIDDLE

Suncor Suncor received one warning in 2005.Suncor received this warning letter inresponse to a low free-chlorine residualfound in treated water in the clearwell.This contravened its approval.38

In 2005 Suncor reported 30 air qualityexceedences and showed an increasingtrend of 240 air quality exceedences in 2006.39

✤ LAGGARDS

Syncrude Syncrude had two regulatory enforcementactions in 2005/2006, including anEnvironmental Protection Order to halt operations from a Flue Gas Desul-phurization Unit due to an uncontrolledrelease of ammonia. The company alsoreceived a warning letter for late reportingof NH3 and SO2 releases. In 2005, thelast year for which data was availableduring our data collection period, thecompany also reported 46 ambient airexceedances for H2S and 1 ambient airexceedance for SO2.40

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4 REGULATORY COMPLIANCE

▲ Meeting all applicable laws is a key component of environmental management.PHOTO: THE PEMBINA INSTITUTE

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The oil sands are overlain byAlberta’s boreal forest. The borealforest is a mixture of deciduous

and coniferous trees on upland sites and wetlands. The Mineable Oil SandsArea (MOSA)41 defined by the Albertagovernment is approximately 3,000km2, an area approximately four timesthe surface area of the city of Calgary.To mine the bitumen in the oil sands,rivers must be diverted, wetlandsdrained and all vegetation and

non-oil-bearing overburden removed. This section contains indicators relatingto reclamation strategies and perform-ance, policy leadership in supportingestablishment of protected areas onpublic lands and monitoring of impactson biodiversity.

Land SummaryTable 6 summarizes the results perproject for the Land section.

Project Certified Reclamation

Reclamation Rate

Support forProtection

BiodiversityMonitoring

Albian Existing N/A 0.5 0 1

Albian Expansion N/A 0.5 0 1

Canadian Natural N/A 0.25 0 0

Imperial N/A 0.25 1 0

Petro-Canada N/A 0.5 0 1

Shell N/A 1 0 1

Suncor 0 0 1 1

Syncrude 0 0.25 0 0

Synenco N/A 0.5 0 0

Total E&P N/A 1 0 1


▼ Table 6: Summary of land scores per project.


The Oil Sands Report Card S U R V E Y R E S U L T SLa

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RATIONALE Reclamation is presented as a significantelement in mitigating the land impacts of oil sands development. The Govern-ment of Alberta requires miningoperations to reclaim disturbed land to an “equivalent land capability.”Reclaimed land that complies with that standard is certified ‘reclaimed’ by the government and returned toAlbertans. The Government of Alberta is responsible for certifying that landshave been reclaimed. This indicatorapplies only to Suncor and Syncrudebecause their operations are the onlyprojects that have beenin operation longenough to have landscertified as reclaimed.

Under the GRIguideline, companiesare required to reporton whether theirreclaimed lands meet third partycertification. In this case, theAlberta government is the third party.

✪ LEADERSNone

✦ MIDDLENone

✤ LAGGARDS

Suncor, Syncrude Despite operating for 40 years and 29 years respectively, none of the landdisturbed by Suncor and Syncrude has been certified as reclaimed by theGovernment of Alberta.

5 CERTIFIED RECLAMATION What is the current ratio of total minedisturbance to certified reclamation?

▲ Although companies are attempting to reclaim landscapes afterdisturbance, no lands have been certified as reclaimed by the AlbertaGovernment in 40 years of oil sands mining.

PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE



Land

RATIONALEThis indicator was developed by thePembina Institute and WWF-Canadaand is not an established metric under theGRI or other environmental reportingguidelines. However, the balance betweenthe rate of land disturbance and reclam-ation is a key indicator of companyenvironmental performance. Forcompanies that have not commencedmining operations, mine reclamationschedules provide evidence of theexpected rate of reclamation. For com-panies active more than 20 years, theactual average annual rate of reclamationis presented. For projects that have notcommenced mining, or have been inoperation for a very short period, such asthe Albian Muskeg River Mine, proposedaverage annual reclamation standardizedafter 20 years of activity is presented.

Companies report reclamation based on their own definitions. Although not as rigorous an indicator as certifiedreclamation, it provides an indicator of what companies consider to bereclaimed.

However we still believe that companiesshould be aiming for certified reclam-ation, rather than trying to redefine the goals.

Reclamation schedules provide a usefulindicator of the focus on progressivereclamation that a company may make.Since the vast majority of oil sandsapprovals do not regulate acceptablereclamation rates,42 or tie futuredisturbance to adequate reclamationperformance, companies are free to set their own reclamation schedules.

6 RECLAMATION RATEWhat is the current ratio of total minedisturbance to reclamation according to your operation’s definition of reclamation?


Land


RESULTSFigure 1 presents the actual andexpected annual rate of reclamation forthe projects considered in this report.

✪ LEADERS

Total E&PTotal has projected the most progressivereclamation schedule for its project. Itsproposed use of dry tailings technologiessubstantially increases the rate at whichland can be reclaimed. Total’s projectedreclamation rate is 13 times faster thanthe slowest recorded reclamation rateand approximately 75% faster than theaverage proposed reclamation rate.

✦ MIDDLE

Albian Existing andExpansion, CanadianNatural, Imperial, Petro-Canada, Shell,Syncrude, Synenco

Albian, Shell, Petro-Canada andSynenco’s operations are expecting tohave slightly higher than the average(1.36%) reclamation rate after 20 years.Imperial’s operations on the other handare expecting to have slightly lower thanaverage reclamation rates after 20 years.Syncrude and Canadian Natural haveannual reclamation rates of 0.78% and0.81% respectively.

✤ LAGGARDS

Suncor Suncor, the company with the longestlegacy in the oil sands region, has actualreclamation rates far slower than thoseproposed by other companies, just0.18%. In 40 years of oil sandsdevelopment, Suncor has disturbed13,093 ha of lands and reclaimed only949 ha.43 Suncor’s 2007 SustainabilityReport claims that the “rate of reclam-ation will accelerate significantly overthe next several years.”

▼ Figure 1 Average annual reclamation rate (predicted after 20 years for non-active mines).

Imperial Oil

Canadian Natural

Total E&P

Suncor

Synenco

Albian - Muskeg Expansion

Albian - Muskeg Existing

Petro-Canada

Shell

Syncrude

% recovered/year

2.50%1.00%0.00%

Reclamation Rates

Proposed Operations

Current Operations

0.50% 1.50% 2.00%

6 RECLAMATION RATE



Land

RATIONALE Currently only 13.2% of Alberta’s BorealForest Natural Region has been legallyprotected from industrial activity.44 Fifty-seven percent of Albertans believe thattoo much of Alberta’s boreal forest isopen to industrial development,45 andthere is strong public support for theestablishment of protected areas inAlberta. Companies can demonstratecorporate leadership by activelysupporting conservation proposals toprotect portions of Alberta. This metricwas developed specifically for this survey.

✪ LEADERS

Suncor, Imperial Suncor is a member of the BorealLeadership Council46 and a signatory tothe Boreal Conservation Framework,which supports a goal of protecting 50%of Canada’s boreal forest from industrial

activity.47 Suncor provided furtherevidence of support for the establish-ment of protected areas in northeasternAlberta. Imperial provided writtensupport for the establishment of specificprotected areas in the application forapproval of the Kearl Oil Sands Project.

✦ MIDDLENone

✤ LAGGARDS

Synenco, Shell, AlbianExisting and Expansion,Petro-Canada, CanadianNatural, Total E&P, Syncrude No other projects or companies havedemonstrated public support forestablishment of protected areas innortheastern Alberta.

7 SUPPORT FOR PROTECTIONDoes your company publicly support the protectionof some areas of unallocated forest in north-eastern Alberta, to keep as reference sites forcomparison to landscapes disturbed by oil sandsprojects? Documentation would include evidenceof public support, CEO quote to the media, etc.


Land


8 BIODIVERSITY MONITORINGDoes your company provide support (financial or other) to the Alberta Biodiversity Monitoring Program in order to providemeaningful, longterm information aboutchanges in biodiversity in the oil sands region? If so, please describe this support.

RATIONALEEffective monitoring for changes inwildlife species is an essential componentof oil sands management. The AlbertaBiodiversity Monitoring Institute(ABMI) delivers one of the world’s most advanced biodiversity monitoringprograms.48 It is capable of providingstatistically rigorous information aboutregional-level changes in biodiversityand has protocols that can be adapted to determine site-specific changes at the level of a single oil sands mine. The Pembina Institute representsAlberta’s environmental community on the board of the ABMI. The ABMIis supported by both government andvoluntary industry funding. Support for the ABMI is a key indicator of theoil sands companies’ commitment tomeaningful biodiversity monitoring.

✪ LEADERS

Shell, Albian, Total E&PPetro-Canada, Suncor These companies are all financialsupporters of the Alberta BiodiversityMonitoring Institute.

✦ MIDDLENone

✤ LAGGARDS

Imperial, Synenco, Syncrude, Canadian NaturalThese companies are not publicsupporters of the Alberta BiodiversityMonitoring Institute.

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Oil sands projects are major emitters of many chemical

pollutants. Air emissions ofparticular importance in the oil sandsinclude nitrogen oxides (NOx), sulphurdioxide (SO2) and volatile organiccompounds (VOCs). All threeemissions types contribute to smog,have potential human health impactsand in the case of NOx and SO2 arecontributors to acid rain. This sectionreports on project emission levels andvoluntary company targets to reduce air pollution.

One of the goals of this survey was to quantify NOx, SO2 and VOCemissions for each project in order to

highlight best practices. For this analysisto be meaningful, the data collected foreach project must be comparable, that iswe must be comparing apples to apples.This proved to be more challengingthan expected for several reasons.

For one, all operations are designedslightly differently and do not containthe same facilities onsite. For example,the Albian Muskeg River MineExpansion will obtain electricity fromthe Alberta grid, unlike the currentAlbian Muskeg River Mine, which hasan onsite cogeneration facility toproduce electricity and process heat. If we had included only onsite emissionsources, the expansion project wouldlook like a significantly better performer,but this would obscure the fact that airpollution is being emitted elsewhere tosupply the expansion project withenergy. In order to address this concern,we developed a list of emission sourcesassociated with activities that all mineshave in common. Taking this approachensures that the air emission valuescalculated are comparable betweenprojects. Table 7 contains the list ofactivities considered.

Second, both Suncor and Syncrudeoperate not only oil sands mines butalso upgraders and, in the case of

Oil Sands Operations Emission Sources

Mine Fleet Mine Face Fugitive Emissions

Processing Plants Electricity Production (on or offsite) Offsite Natural Gas Production

Tailings Ponds Facility Heating

▲ Table 7 Activities included in air emissions calculations.

Oil sandsprojects are

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s Suncor, in situ operations as well. Air emissions for these operations areintegrated into a single number makingit impossible to determine air emissionsfor just their mining operations.Suncor’s and Syncrude’s air emissionsare therefore not comparable with theother projects here and have not beenscored relative to the other projects onNOx, SO2 and VOC emissions.

The final three scores below compareeach company based on their NOx,SO2 and VOC emission intensities. The first score compares each company’sreduction targets.

Air Emissions SummaryTable 8 summarizes the scores for eachproject for the air emissions section.

❚ If all mines had the same VolatileOrganic Compound emissionsproposed by Petro-Canada (86 gramsper barrel of bitumen), annualemission rates would be reduced by47% from 96 kt to 50 kt annually.

❚ If all mines had the same NOxintensity proposed by Shell Jackpine(113 grams per barrel of bitumen),annual emission rates would dropalmost 80%, from 75 kt to 15 ktannually.

❚ If all mines had the same SO2

intensity as Canadian NaturalHorizon (14 grams per barrel ofbitumen), annual emission rateswould be reduced by 47%, from 15 kt to 8 kt annually.

▲ Table 8 Summary of air emission scores per project.

Project ReductionTargets

NOx SO2 VOC

Albian Existing 0 0.5 1 1

Albian Expansion 0 0 0 1

Canadian Natural 0 0 1 0

Imperial 0 0 0.5 0

Petro-Canada 0 0.25 0.5 1

Shell 0 1 0.25 1

Suncor 0 N/A N/A N/A

Syncrude 0.5 N/A N/A N/A

Synenco 0 0 0.5 0

Total E&P 0 0.5 1 0.25


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9 NITROGEN OXIDE EMISSIONSWhat are your overall project-specific nitrogenoxide (NOx) emissions? 49

Nitrogen Oxide Emissions Intensity

0

g/bbl

Synenco

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Petro-Canada

Shell

Canadian Natural

Total E&P

Suncor*

Syncrude*

Proposed Operations

Current Operations

* Suncor and Syncrude’s values are based on their mining, upgrading, and for Suncor, its in-situ operations. They can therefore not be compared directly with the other operations in this graph. Additionally the values are reported per barrel of synthetic crude oil (SCO) and not per barrel of bitumen.

0 50 100 150 200 250 300

Figure 2 Project

comparisonof nitrogen

oxideemissionson a per

barrelbasis.

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RATIONALENitrogen oxides (NOx) are emitted in large volumes by oil sands miningoperations from the combustion of fossil fuels including natural gas, diesel, gasoline and, in some instances,petroleum coke for oil sands operations.In 2005, active operations in the oilsands released 70,000 tonnes of NOx;this is projected to increase to 196,000tonnes by 2015.50 Nitrogen oxides canhave adverse impacts on human healthand the environment. NOx can causerespiratory problems and may combinewith VOCs and sunlight to formground level ozone. NOx is a contribu-tor to smog and is a major componentof acid rain. Acid rain can result inchanges in soil and water chemistry,impacting forests, vegetation, lakes and fish populations.

The reporting of NOx emissions is also required under the GRI guideline;

however we adapted this metric andreported it on an intensity basis as opposedto annual or daily emissions to facilitatecomparison among the mining operations.

NO2 emissions from approved andexisting oil sands projects are alreadyexpected to exceed Alberta’s Air QualityObjectives over a 24-hour period.Additional projects will go further over this guideline.51

RESULTSThe results presented in Figure 2 includeemissions from the mine fleet, processingequipment, electricity generation (whetheron or offsite) as well as upstream naturalgas production on a per barrel basis.Offsite emissions have been included in order to compare all operationsequivalently. Please refer to appendicesdocuments for a more detailed explanationof sources and assumptions.


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✪ LEADERS

Shell The approved Shell mine has the lowestNOx intensity of all the projects at 113 grams per barrel of bitumen(g/bbl). There is no clear indication asto why this project has the lowest NOxintensity of all the projects considered.One possible explanation is that Shellstates that its mine fleets will meet U.S. Environmental Protection Agency(EPA) Tier 1, Tier 2, Tier 3 and Tier 4emission standards at some date in the future.52 Tier 4 NOx emissionsstandards are approximately 38% lowerthan Tier 3 emission standards and notall projects have committed to meetingTier 4 standards. As the mine fleet

is the primary source of onsite NOxemissions, this commitment may resultin reduced intensities. However, to date there is no regulated approach toestimating emissions from mine fleetvehicles.53 Without a single approach, itis difficult to determine whether a lowerreported emissions intensity is a result of an innovative approach to reducingNOx emissions or simply a reflection of a different calculation methodology.

✦ MIDDLE

Albian Existing, Total E&P, Petro-CanadaThese projects have projected NOxintensities ranging from 128 g/bbl to139 g/bbl.

▲ Acid rain caused by oil sands emissions is projected to impact soils and vegetation in theBoreal Forest. PHOTO: THE PEMBINA INSTITUTE

9 NITROGEN OXIDE EMISSIONS



Air Em

ission

s

✤ LAGGARDS

Synenco, Canadian Natural,Imperial, Albian Expansion Synenco, Canadian Natural, Imperial and Albian Expansion are project to emitthe most NOx per barrel of bitumenproduced with intensities ranging from154 g/bbl to 160 g/bbl. There is no clearindication as to why these projects havehigher emission intensities. One reasonmay be the way in which NOx emissionsare calculated. For example, in comparisonto Albian, Imperial states that their minefleet NOx emissions are based on Tier 2EPA emission standards. Imperial alsoassumed a more conservative (higher) loadfactor or average operating horsepower ofits mine fleet in comparison with Albianand Shell. The load factor has “the mostsignificant effect on NOx and carbon

monoxide emissions.”54 It is thereforenot clear if Imperial’s reported emission value reflects a prediction of relativelypoor performance or a more conservativeestimate in comparison with other projects.

This demonstrates the need for acommon reporting framework, whichshould be required by the governmentand adopted by industry.

Suncor’s and Syncrude’s operations aremajor emitters of NOx, but since thesevalues include upgrading, in addition tomining operations, and, in the case ofSuncor, also in situ operations, they arenot directly comparable with the otherprojects. They have therefore not beenscored for this indicator. In the future,we hope that Suncor and Syncrude willdisaggregate this information so theiroperations can be compared with othermining operations.

▲ Oil sands mine truck fleets are a major source of NOx emissions.PHOTO: THE PEMBINA INSTITUTE

9 NITROGEN OXIDE EMISSIONS

Air Em

ission

sThe Oil Sands Report Card S U R V E Y R E S U L T S


10 SULPHUR DIOXIDE EMISSIONSWhat are your overall project-specific sulphur dioxide (SO2) emissions in tonnes per calendar day? 55

Proposed Operations

Current Operations


0 200 400 600 800 1000 1200

Sulphur Dioxide Emissions Intensity

g/bbl

Synenco

Imperial Oil



Petro-Canada

Shell

Canadian Natural

Total E&P

Suncor*

Syncrude*

▲ Figure 3 Project-specific sulphur dioxide emissions on a per barrel basis.

RATIONALESulphur dioxide (SO2) is a majorcomponent of acid rain and cancontribute to the formation of smogand haze. Environment Canada statesthat in 2005 oil sands operationsemitted 147,000 tonnes of SO2. SO2 emissions are expected to increaseto 166,000 tonnes a year by 2015. This amount of SO2 pollution willexceed 24-hour Alberta Air QualityObjectives and those established by the World Health Organization.56

As with NOx emissions, the reportingof SO2 emissions is a recognized metric under the GRI guideline.

SO2 intensity is used here to compareprojects more effectively.

RESULTSEmissions sources incorporated in thevalues presented in Figure 3 includethose from the mine fleet, processingequipment, electricity generation(whether on or offsite) as well asupstream natural gas production on a per barrel basis. Offsite emissions have been included in order to compareall operations equivalently. Please referto appendices documents for a more-detailed explanation of sources andassumptions.

Air Em

ission

s



✪ LEADERS

Canadian Natural, Total E&P, Albian Existing Oil sands companies have substantiallyreduced onsite SO2 emissions per barrelof bitumen produced in the oil sands.However, SO2 emissions are primarily a result of offsite upstream natural gasproduction as well as offsite electricityproduction. Those projects with onsitepower production have lower natural gasintensity and relatively low onsite SO2

emissions; therefore they have the lowestSO2 emissions intensity. CanadianNatural’s Horizon meets all of thesecriteria resulting in the lowest SO2

intensity of all the projects at 14 gSO2/bbl. The Albian Existing and Total mines are both below the averageof 31 g/bbl with SO2 intensities of 22 g/bbl and 24 g/bbl respectively.

✦ MIDDLE

Petro-Canada, Imperial,Synenco, Shell Petro-Canada’s SO2 intensity is justbelow average at 27 g/bbl, while bothImperial and Synenco match theindustry average intensity of 31 g/bbl.The Shell Jackpine Mine has a slightlyhigher SO2 intensity of 37 g/bbl. This isprimarily a result of the mine’s relativelyhigh natural gas intensity.

✤ LAGGARDS

Albian Expansion For bitumen extraction projects only,the projected emissions of the AlbianMuskeg River Expansion Project are the highest. This is largely a result ofoffsite power production requirementsthat result in higher system SO2

emissions of 60 g/bbl.

The integrated Suncor and Syncrudeprojects are major sources of SO2

pollution but were not included in theranking analysis because they includeemissions from upgrading processes aswell. Refer to the beginning of thissection for a complete description of this problem.

▲ Very few oil sands operationshave voluntary targets to reduceair pollution.PHOTO: THE PEMBINA INSTITUTE

10 SULPHUR OXIDE EMISSIONS

Air Em

ission

sThe Oil Sands Report Card S U R V E Y R E S U L T S



0 50 100 150 200 250 300

Volatile Organic Compound Emissions Intensity

g/bbl

Synenco

Imperial Oil



Petro-Canada

Shell

Canadian Natural

Total E&P

Suncor*

Syncrude*

Proposed Operations

Current Operations

▲ Figure 4 Project-specific VOC emissions on a per barrel basis.

RATIONALEVolatile organic compounds (VOCs) are a large group of chemicals that parti-cipate in atmospheric photochemicalreactions.57 Individual VOCs may betoxic to humans and may combine with NOx in the presence of sunlight toform ground level ozone.58 In addition,Environment Canada projects thatVOC emissions from the oil sands will increase by more than 500% from 59,000 tonnes in 2005 levels to300,000 tonnes per year in 2015.59

As with NOx and SO2 emissions, VOCemissions are a recognized metric underthe GRI guideline. VOC intensity is usedas opposed to total emissions in order tocompare projects more effectively.

RESULTSThe results presented in Figure 4include emissions from the tailingsponds (the primary emissions source),the mine fleet, processing operations,mine face, electricity production (on or offsite) as well as offsite natural gasproduction. During the analysis of thisdata, the Pembina Institute researchersfound significant variations between themethodologies used by the companies tocalculate their project VOC emissions.An attempt has been made to correct for these differences; the method isoutlined in the VOC section ofAppendix 3 – Air Emissions.

11 VOLATILE ORGANIC COMPOUNDSWhat are your overall project-specific volatileorganic compound (VOC) emissions in tonnesper calendar day?



Air Em

ission

s

✪ LEADERS

Albian Existing and Expansion,Petro-Canada, Shell Albian’s existing and expandedoperations as well as Petro-Canada’s andShell’s operations all produce significant-ly less VOCs per barrel than the otheroil sands projects. The VOC intensityfor these projects is 86 g/bbl, 99 g/bbl,102 g/bbl and 116 g/bbl for Petro-Canada, Albian’s existing project, Shell’s Jackpine and Albian’s expansionproject respectively.

✦ MIDDLE

Total E&PThe Joslyn North Mine is projected to have a VOC intensity of 218 g/bbl,which is slightly higher than the averageof 186 g/bbl.

✤ LAGGARDS

Canadian Natural, Synenco, Imperial The Canadian Natural, Synenco andImperial mines are projected to emitVOCs at 276 g/bbl, 270 g/bbl and 233 g/bbl respectively. These values are significantly higher than the otherprojects. Other than Albian’s existingoperations, only the VOC intensities of Suncor and Syncrude are based onactual emission values. Suncor andSyncrude have emission intensities of 275 g/bbl of synthetic crude oil(SCO) and 137 g/bbl SCO respectively,but these are not scored because ofdifferences in reporting.

▼ Bitumen from the oil sands must beupgraded to produce synthetic crude oil.PHOTO: © JIRI REZAC, WWF-UK

11 VOLATILE ORGANIC COMPOUNDS


Air Em

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RATIONALEThe compounds have been identified by Environment Canada as criteria aircontaminants that affect human health.The Pembina Institute and WWF-Canada encourage companies to take aleadership role and commit to voluntaryreduction targets because these targetsresult in real emissions reductions. Thismetric is not included under the GRIguideline; however, setting internaltargets is considered to be an essentialcomponent of an environmentalmanagement plan.60

✪ LEADERSNo projects have publicly stated voluntaryair emission reduction targets for the rangeof emissions identified in this survey.

✦ MIDDLE

Syncrude The Syncrude Emissions ReductionProject (SERP) involves the retrofit of a flue gas scrubbing system into theoperation of Syncrude’s two originalcokers. In combination with scrubbingtechnology also incorporated into a newcoker built as part of Syncrude’s upgraderexpansion project, it will reduce stackemissions of sulphur compounds by 60% from current approved levels of 245tonnes per day. It is important to notethat Syncrude’s SO2 emissions intensity is currently greater than the combinedemissions of all the other mines includedin this survey (see Figure 3).

✤ LAGGARDS

Synenco, Imperial, Shell,Albian, Petro-Canada,Canadian Natural, Total E&P, Suncor None of these companies has publiclyavailable voluntary emission reductiontargets.

12 VOLUNTARY TARGETSDo you have voluntary targets to reduce or offset NOx, SO2 or VOCs? If so, what are your targets?

aterW


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Oil sands operations are large users of fresh water. It takes

2-4.5 barrels of water to extractand upgrade a single barrel of oil froman oil sands mine. Approved oil sandsmining operations are licensed to divert349 million cubic metres of fresh waterfrom the Athabasca River per year; thisis expected to increase to more than 500 million cubic metres per year ifproposed projects are also approved.During some winter periods, flow in the Athabasca River is low enough toimpact fish habitat and fish populations.

Oil sands companies are currentlyallowed to withdraw water even when river levels are dangerously low.Current and proposed projects would be responsible for withdrawing up to 15.7% of the river flow during low flow periods. This section concerns oil sands company water use, management of liquid mine wastes, known as mature fine tailings,and management strategies in place to protect the Athabasca River duringperiods of low flow.

▲ Oil sands operations pose a serious risk to the Athabasca River.PHOTO: DAN WOYNILLOWICZ, THE PEMBINA INSTITUTE

Water



Water SummaryTable 9 summarizes the results for thewater section.

❚ If all oil sands mines adopted the drytailings technologies proposed bySynenco Northern Lights and TotalJoslyn, the environmental problem of mature fine tailings at the end of

a mine’s life would be completelyeliminated.

❚ If all mines had the same waterintensity proposed by Petro-Canada(0.20 m3 of water per barrel ofbitumen produced), oil sands minescould reduce water consumption byalmost 60% annually.

▼ Table 9 Summary of scores for the water section.

Project WaterIntensity

Water IntensityTargets

MFT Intensity

WithdrawalCommitment

WaterStorage

Albian Existing 0 0 0 0 0

Albian Expansion 0 0 0 0 0

Canadian Natural 1 0 1 0 0.5

Imperial 1 0 1 0 0

Petro-Canada 1 0 0 0 1

Shell 0.25 0 0.5 0 0

Suncor N/A 0 0.5 0 0

Syncrude N/A 0 0 0 0

Synenco 1 0 1 0 0

Total E&P 1 0 1 0 0.5


Water



Proposed Operations

Current Operations

* Suncor and Syncrude’s values are based on their mining, upgrading, and for Suncor, its in-situ operations. They can therefore not be compared directly with the otheroperations in this graph. Additionally the values are reported per barrel of synthetic crude oil (SCO) and not per barrel of bitumen.

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8

Synenco

Imperial Oil



Petro-Canada

Shell

Canadian Natural

Total E&P

Suncor*

Syncrude*

Water Intensity

m3/bbl

▲ Figure 5 Project-specific water consumption on a per barrel basis.

RATIONALEOil sands mines are major consumers offreshwater from the Athabasca River.There are growing concerns that oilsands water use from the AthabascaRiver is unsustainable. Given theseconstraints, it is essential that oil sandsmines minimize their fresh waterconsumption per barrel of bitumenproduced. In addition, total waterwithdrawal is a recognized metricrequired by the GRI guideline.

Water intensity is used here in order tocompare operations effectively.

RESULTSActual water use intensities varyconsiderably over a given project’s life.In order to compare projects on anequivalent basis, the results presented in Figure 5 are based on onsite makeupwater use intensity during steady state or typical operational periods only.

13 FRESHWATER CONSUMPTIONWhat is your average freshwater consumptionper barrel of bitumen produced (m3/bbl)? We are looking for long-term withdrawal rates during steady state operations (i.e., once operations have commenced).

Water



✪ LEADERS

Imperial and Petro-Canada Petro-Canada Fort Hills and ImperialKearl mines are projected to be the leastwater intensive of all the mines withwater intensities of 0.20 cubic metres ofwater per barrel of bitumen produced(m3/bbl) and 0.22 m3/bbl respectively.

✦ MIDDLE

Synenco, Total E&P, Canadian Natural The Northern Lights, Joslyn andHorizon mines are expected to havewater intensities slightly below the 0.36 m3/bbl average at 0.31 m3/bbl,0.27 m3/bbl and 0.31 m3/bblrespectively.

✤ LAGGARDS

Albian Existing andExpansion, ShellThe most water intensive projects arethe current Muskeg River, Muskeg RiverExpansion and Jackpine mines withwater intensities of 0.54 m3/bbl, 0.65 m3/bbl and 0.46 m3/bbl.

Suncor and Syncrude’s values alsoinclude their upgrader water require-ments and, in the case of Suncor, in situoperations as well. They are thereforenot comparable with the other projectslisted here. However, based on the factthat their water intensity values arelower than some of the other projects,we can assume that their waterintensities for just mining operationswill be lower than these projects.

▲ Oil sands mines use substantial amounts of freshwater to extract bitumen from the oil sands.PHOTO: DAVID DODGE, THE CANADIAN PARKS AND WILDERNESS SOCIETY

13 FRESHWATER CONSUMPTION

Water



RATIONALEGiven that water use by oil sandscompanies is considered one of the most urgent environmental issues in the oil sands region, formal targets toreduce water use provide evidence of a commitment to reduce impacts onaquatic ecosystems. As discussed in theair emissions section, targets also serveto drive innovation within a company to reduce water use and can lead to real reductions in water use. ISO 14001 recognizes internal waterreduction targets as a key component of a complete environmental manage-ment system65.

✪ LEADERSNone

✦ MIDDLENone

✤ LAGGARDS

Synenco, Imperial, Shell,Albian Existing andExpansion, Petro-Canada,Canadian Natural, Total E&P,Suncor, Syncrude With the exception of Syncrude, nocompany publicly reports water intensitytargets. Syncrude does report waterintensity and absolute water use targets;however, they are projected to increaseby 5% and 70% respectively. Syncrudehas therefore not been awarded a pointfor these increasing targets.62

14 FRESHWATER CONSUMPTIONDo you have targets to reduce water intensityand consumption in your operations? If so, whatare your targets?

Water



RATIONALEManagement of liquid mine wastes fromconventional oil sands extraction processesis one of the most significant liabilitiesfacing the oil sands industry. The NationalEnergy Board describes the problem of tailings management as a dauntingchallenge.63 Mature Fine Tailings (MFT)are the suspended fine particles of sedimentcreated by most oil sands extractionprocesses; they end up in the massive wastelagoons seen north of Fort McMurray.MFT that can be consolidated will beincorporated into the terrestrial landscape.The plan for the long-term disposal of theremaining MFT is to place them in EndPit Lakes. Given the uncertainty aroundMFT management, extraction processes

that prevent or minimize the creation of MFT and strategies to reduce the long-term persistence of MFT areconsidered preferable from an environ-mental perspective.

The long-term impact and uncertaintysurrounding residual MFT necessitatedthe creation of a customized metric forthis report. No other environmentalguidelines require reporting on this metric.

RESULTSThe Pembina Institute derived thevalues presented in Figure 6 by dividingthe total MFT expected at closure bythe total bitumen production over thelife of the respective project.

Synenco

Total E&P

0.00 0.05 0.10 0.15 0.20

Proposed Operations

Current Operations



Suncor

Shell

Imperial Oil

Canadian Natural

Syncrude N/A

Petro-Canada N/A

cubic metres water per barrel

Mature Fine Tailings

▲ Figure 6 Project-specific mature fine tailings production on a per barrel basis.

15 MATURE FINE TAILINGSWhat is the average volume (m3) of maturefine tailings (MFT) produced per barrel of bitumen?

Water



✪ LEADERS

Synenco, Total E&P, Imperial,Canadian Natural Both Synenco and Total propose using afiltered tailings technology known as theBITMIN64 process. The BITMINprocess produces a dry tailings andthickened tailings stream. The drytailings stream can be transported offsiteby truck or conveyor belt and used forreclamation or backfill. The remainingthickened tailings are placed in tailingsponds but do not result in the creationof MFT. 65, 66 BITMIN Resources Inc.successfully demonstrated this tech-nology in 2005 at the Fort HillsDemonstration Plant; however, it has yet to be proven commercially for oil sands application.

Both Imperial and Canadian Naturalhave projected very low, relative to theaverage, MFT intensities of 0.0048

m3/bbl and 0.0034 m3/bbl respectively.

✦ MIDDLE

Shell, Suncor The Jackpine mine is projected to havean MFT intensity of 0.057 m3/bbl, just below the average. Suncor’s currentMFT intensity is 0.0785 m3/bbl, slightlyabove the average. However, this isbased on actual data unlike the majorityof other projects.

✤ LAGGARDS

Albian Existing andExpansion, Petro-Canada,Syncrude The current Albian Muskeg River Mineand Muskeg River Mine Expansionproject both have projected MFTintensities of 0.17 m3/bbl. This intensityis significantly higher than any otherproject. Petro-Canada did not providethis information in its original EIA, and stated that MFT volumes will beconfirmed during the operation of theFort Hills Mine. We were unable tolocate any publicly available informationon MFT intensities for Syncrude.

15 MATURE FINE TAILINGS

▲ Management of tailings wasteis a major liability for the oilsands industry. PHOTO: THE PEMBINA INSTITUTE

Water



RATIONALEThe current government managementframework governing oil sands waterwithdrawals from the Athabasca Riverdoes not require companies to haltwater withdrawals during low flowperiods, even when fish and fish habitatmay be impacted.67 It is alreadyanticipated that the current planneddevelopment case (i.e., all projectsexisting, approved, in the applicationstage and planned) will require averageannual withdrawal rates of 16.7 m3/s 68

from the Athabasca River. This value is10% higher than the suggested 15 m3/swinter maximum cumulativewithdrawal rate stated in the watermanagement framework.69 Thisindicator reports on whether oil sandscompanies have voluntary strategies in place to halt water flows to reduceimpacts on the Athabasca River duringcritical periods.

This metric was designed specifically for this report in order to identify thosecompanies that have addressed thisconcern by committing to voluntarilyhalt fresh water withdrawals from theAthabasca River.

✪ LEADERSNo oil sands company has made avoluntary commitment to halt waterwithdrawals during low flow periods onthe Athabasca River, even if fish and fishhabitat are being damaged. Without thiscommitment, oil sands production willbe given precedence over protection ofthe aquatic habitat of the AthabascaRiver during periods of low water flow.

✦ MIDDLENone

✤ LAGGARDS

Synenco, Imperial, Shell,Albian, Petro-Canada,Canadian Natural, Total,Suncor and Syncrude All the companies are consideredlaggards for this indicator.

16 HALT WATER WITHDRAWALSDo you commit to voluntarily halting waterwithdrawals during low flow periods on theAthabasca River?



Water

▲ Figure 7 Project-specific water storage in days.

17 DAYS OF WATER STORAGEHow many days of water storage do you have (on-site or off-site) associated with your oil sands project?

RATIONALEAs discussed in question 16, theAthabasca River has varied flowsthroughout the year and is at its lowestduring the winter months. Curtailingwithdrawals during low flow periods is necessary to protect fish and fishhabitat. Sufficient on-site water storageat oil sands operations is essential toprovide process water when withdrawalsfrom the Athabasca are not possible.The greater the number of days of waterstorage engineered into project design,

the better able a company is to preventpotentially damaging withdrawalsduring low flow periods. This metricwas also custom designed for thisproject in order to highlight thosecompanies that have designed theiroperations to operate temporarilywithout water from the Athabasca River.

RESULTSThe values reported in Figure 7 arebased on water storage capability foreach facility.

SynencoProposed Operations

Current Operations

Total E&P

Suncor

Imperial Oil

Canadian Natural


Petro-Canada

0 1 2 20 25 30 35 40 45

Water Storage (days)

Water Storage

Shell


Syncrude N/A


Water


✪ LEADERS

Petro-Canada The Petro-Canada Fort Hills project hasthe most flexibility with respect to waterwithdrawals because it was designed foron-site storage of 45 days. This wouldenable Petro-Canada Oil Sands Inc. topotentially avoid withdrawals for thelongest amount of time during low flowperiods on the Athabasca River.

✦ MIDDLE

Canadian Natural, Total E&PCanadian Natural and Total E&P havesome flexibility to deal with low flows in the Athabasca River, with projectscapable of storing water for 25 and 30 days of operations respectively.

✤ LAGGARDS

Synenco, Imperial, Suncor, Shell, Albian Suncor has no ability for on-site storageof water. Suncor would therefore have toshut down its operations if required tohalt water withdrawals. Both Synencoand Imperial have water storage on-site,but the mines must maintain continualwithdrawals from the Athabasca Riverwhen in operation. Shell and Albian also have very limited capacity to storewater at 1 and 1.5 days respectively. No publicly available information on the water storage capacity of Syncrudewas identified.

17 DAYS OF WATER STORAGE

▲ The ability to store water is essential if companies are to prevent their operationsdamaging the Athabasca River during low flow periods.

PHOTO: DAVID DODGE, THE CANADIAN PARKS & WILDERNESS SOCIETY

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Extracting bitumen from the oil sands is very energy intensive, and, as a result, oil sands mine

operations are major emitters of green-house gases (GHGs). Syncrude andSuncor are Canada’s 3rd and 6th largestemitters of GHGs respectively.70 Syncrudeemitted 10.3 million tonnes of GHGsin 2005, equivalent to the emissions of2.7 million personal vehicles.71

Canada is faced with the challenge andinternational legal obligation, under theKyoto Protocol, of reducing absoluteGHG emissions by 6% below 1990levels by 2008-2012. Because of years of inaction by government and industry,current projections suggest that, by2010, emissions will be 32% higherthan 1990 levels. This trend of rapidlyincreasing GHG emissions stands instark contrast to the urgent need to

significantly reduce GHG emissionsworldwide. Developed countries such as Canada need to reduce emissions by80% or more below the 1990 level by2050 – and, by 2020, be well on trackto doing so – if we are to limit averageglobal warming to 2ºC above the pre-industrial level and thereby avoid theworst impacts of climate change.72

Research from the Tyndall Centrecommissioned by WWF shows that the intensity based targets proposed by the Canadian Government fail toprovide a framework that will providethe necessary reductions.73 In fact these targets would provide a perverseincentive, whereby companies couldreceive up to $700 million in credits justby delivering expected efficiency gains,but with absolute carbon emissionsdoubling or tripling.

limate ChangeC

▲ Oil sands projects are among the largest single emitters of greenhouse gases in Canada.PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

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Annual GHG emissions from oil sands plants and upgraders in 2007 areexpected to be 39.3-41.4 million tonnesof CO2 equivalent.74 The oil sands areprojected to be the single largestcontributor to the increase in GHGemissions in Canada, contributing close to one-half of the projectedbusiness-as-usual growth in nationalemissions between 2003 and 2010.75

In the report Carbon Neutral 2020, aLeadership Opportunity in Canada’s OilSands, the Pembina Institute articulateda strategy that could enable oil sandsoperators to be net-zero emitters ofGHG pollution for the cost of a fewdollars per barrel of oil produced. Thissection examines GHG intensity andcompany targets to reduce absoluteamounts of GHG pollution.

The methodology used to derive thedata presented in this section is the sameas that discussed in the air emissionssection. The questions concern green-house gas emissions (question 18) andtargets for reductions (19 and 20).

Climate Change SummaryTable 10 summarizes the per projectscores for the Climate Change Section.

❚ If all mines had the same greenhousegas emissions intensity proposed by Canadian Natural Horizon (23.34 kg CO2e per barrel ofbitumen produced), Alberta would avoid 6,339,662 tonnes CO2e each year – a savings of 66%.This represents almost 3% ofAlberta’s annual GHG emissions! 76


▼ Table 10 Summary of climate change scores per project.

Project GHG AbsoluteReduction Targets

GHG Intensity Per Barrel

Intensity Targets

Albian Existing 1 1 N/A

Albian Expansion 0 0 0

Canadian Natural 0 1 0

Imperial 0 0 0

Petro-Canada 0 0 0

Shell 0 0.25 0

Suncor 0 N/A 0

Syncrude 0 N/A 0

Synenco 0 0 0

Total E&P 0 0 0


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RATIONALEOver 40% of the increase in Canadiangreenhouse gas emissions between 2003and 2010 is projected to be as a directresult of new oil sands development.77

If Canada is to achieve the necessary deepreductions in its overall GHG emissions,emissions from oil sands operations mustalso be reduced in absolute terms.Greenhouse gas intensity of oil sandsoperations is, however, a useful methodto compare the efficiency of companies.

The GRI guidelines recognize greenhousegas emissions as an important environ-mental metric and require participatingcompanies to report them. This surveyincludes onsite as well as offsite emissionsincluding those associated with upstreamnatural gas production. Reporting GHGemissions associated with upstreamnatural gas production is not a standard

practice but is included here because ofthe considerable amount of natural gasused by oil sands mining companies andto enable a fair comparison between oilsands operations.

RESULTSThe results presented in Figure 8include operational onsite emissionsfrom the mine fleet, processingoperations, tailing ponds, the mine face, electricity generation (on oroffsite), heating and upstream naturalgas production. No attempt has beenmade to account for transfers of CO2

from the biosphere to the atmospheredue to the destruction to the borealwetlands and forests. These impacts,although of concern, are many times less than the direct GHG emissionsassociated with oil sands extraction.



Proposed Operations

Current Operations


Synenco

Imperial Oil



Petro-Canada

Shell

Canadian Natural

Suncor*

Syncrude*

Total E&P

Greenhouse Gas Emission Intensity

0.00 90.00 150.00

kgCO2eq/bbl30.00 60.00 120.00

Figure 8Project-specific

greenhousegas

emissionson a per

barrelbasis.

▼

18 GHG EMISSION INTENSITYWhat is your operational greenhouse gasemission intensity in kilograms (kg) per barrel (bbl) bitumen?

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✪ LEADERS

Albian Existing, Canadian Natural Both Canadian Natural and AlbianMuskeg’s existing operations havesignificantly lower greenhouse gas(GHG) intensities of 23.34kgCO2eq/bbl and 24.44 kgCO2eq/bblin comparison with the other projects.

✦ MIDDLE

Synenco, Petro-Canada,Imperial, Shell, Total E&PThe Synenco Northern Lights, Fort Hills, Kearl, Jackpine and Joslynmines have GHG intensities of 41.56kgCO2eq/bbl, 40.50 kgCO2eq/bbl,40.39 kgCO2eq/bbl, 36.14 kgCO2eq/bbland 39.87 kgCO2eq/bbl respectively.

✤ LAGGARDS

Albian Expansion The Albian Muskeg River MineExpansion project will produce relativelymore emissions per barrel than the othermine projects with a GHG intensity of44.44 kgCO2eq/bbl. It is disappointingthat this expansion is projected toperform to a lower standard than theexisting Albian Muskeg development.The Albian Muskeg River MineExpansion project will use gridelectricity to power its operations, which accounts for its higher emissionintensity. Although Syncrude andSuncor’s operations cannot be directlycompared with other operations becauseof data limitations, they are currentlythe third and sixth largest individualgreenhouse gas emitters in Canada.78

▲ Producing a barrel of oil from the oil sands produces substantially more GHG emissions thanconventional oil production. PHOTO: THE PEMBINA INSTITUTE

18 GHG EMISSION INTENSITY

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RATIONALEA public opinion poll of Albertansconducted by Probe Research in April2007 showed that 92% of Albertanspolled felt that oil sands companiesshould reduce greenhouse emissions inall their plants. The same poll showedthat 70% of Albertans felt that absolutereductions in greenhouse gases wereappropriate, compared to only 20% ofAlbertans polled that preferred targetsthat reduced intensity of greenhouse gas emissions per barrel only.79

Voluntary targets are recognized by ISO14001 as a necessary component of anenvironmental management system.80

✪ LEADERS

Albian Existing The Albian Muskeg River Mine has atarget to cut annual emissions from itsoil sands business by 50% below startup emissions by 2010. This represents areduction of 1750 kt/yr of CO2.81 Thiscommitment applies to the integratedAlbian Sands Athabasca Oil SandsProject, which includes upgrading;

however a closer look at the methods for achieving the reduction indicatesthey will include offsetting emissions.This means that the actual amount ofreduction is lower, and any shortfall ofthe 50% reduction target will be metthrough offsets. WWF only recognizesoffsets which are accredited to the GoldStandard, which is not met by some ofthe offsets proposed by Shell Canada.82

While we recognize that Albian having a target is unique in the sector, theabsolute reductions achieved by Albian,as opposed to through offsets are not yet clear.

✦ MIDDLENone

✤ LAGGARDS

Shell, Synenco, Imperial,Petro-Canada, CanadianNatural, Total E&P, Suncor,Syncrude, Albian Expansion No other oil sands companies havepublicly available absolute greenhousegas reduction targets.



19 ABSOLUTE REDUCTION TARGETSDo you have absolute greenhouse gas (GHG) emission reduction targets? If so, what are they?

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RATIONALEAbsolute emissions reduction targets are preferable to intensity targets. A company that complies with anabsolute emission reduction targetreduces its GHG emissions; a companythat complies with an intensity targetcould well increase its GHG emissions.Nonetheless voluntary intensity targetscan still lead to a reduction in emissionsrelative to a business-as-usual case.

✪ LEADERS

Albian Existing Albian’s commitment to reduce absolutegreenhouse gas emissions to 50% belowthose estimated at project start-up83

results in an intensity target as well. This applies to the Athabasca Oil SandsProject, including upgrading. Since theexisting project is granted a point forthis target in the absolute reductions section, it is not scored here to preventdouble counting.

✦ MIDDLENone

✤ LAGGARDS

Shell, Synenco, Imperial,Petro-Canada, CanadianNatural, Total E&P, Suncor,Syncrude, Albian ExpansionNo other company in our surveyreported voluntary greenhouse gasintensity reduction targets.


20 INTENSITY TARGETSDo you have voluntary project-specificgreenhouse gas emissions intensity reduction targets? If so, what are they?

▲ There are existing technologies available thatwould enable oil sands companies to substantiallyreduce greenhouse gas emissions. Only oneoperation in our survey reported a voluntarygreenhouse gas reduction target.

PHOTO: THE PEMBINA INSTITUTE



Summary

WWF-Canada and thePembina Institute believethat this environmental

performance survey represents the mostthorough and rigorous attempt to dateto report to the public on the compar-ative environmental management andperformance of proposed and active oil sands mining projects in Alberta.

The proposed and actual environmentalperformance of the oil sands miningindustry is generally poor. The averagescore in our survey was 33%. Theoverall scores for projects ranged from56% for the Albian Sands Muskeg River Mine to 18% for the SynencoNorthern Lights Project and Syncrude.The following is a summary of the majorfindings from our report.

▲ Table 11 Summary of total project scores.


Operation Percentage Score

Albian Existing (Muskeg River Mine) 56

Total E&P 43

Petro-Canada 37

Shell 37

Suncor 34

Imperial Oil 33

Canadian Natural 31

Albian Expansion (Muskeg River Mine Expansion) 26

Syncrude 18

Synenco 18

AVERAGE SCORE 33


3

2

1

Summary

There is substantial room forimprovement in oil sands mineenvironmental management.

One set of survey questions wasdesigned to determine which projectsand companies demonstrate a progressiveapproach to environmental managementby participating in exemplary managementpractices such as independent perform-ance verification, mitigation andmonitoring efforts, and voluntaryperformance targets in the absence of clear regulatory requirements. An operation that has adopted a numberof these management practices is clearlymaking an effort to address its environ-mental impacts. By this measure, there are four leading operations: the current operation and expansion of the Albian Muskeg project, Suncorand Shell Jackpine; however, none of these operations is achievingenvironmental excellence overall.

Best practices are inconsistently applied.

Although it is often stated that techno-logical breakthroughs are necessary to improve oil sands environmentalperformance, there are a host ofcurrently feasible strategies and best practices that could improve

performance if they were consistentlyapplied in the oil sands region. Current industry objectives, such asAlbian’s existing operation’s 50%greenhouse gas reduction target,Suncor’s terrestrial offset mitigation orTotal’s proposed tailings managementstrategy that produces no MFT could beimplemented by all oil sands companies.Instead these leading strategies representrare examples of best practices for thisindustry. The Government of Albertadoes not require oil sands companies to implement best practices to mitigateenvironmental impacts associated withoil sands development.

The environmental performance of this industry could be substantiallyimproved if all operations improvedtheir performance to match thecurrent industry leaders.

Our analysis provides a quantitativecomparison of the proposed and actualenvironmental performance of oil sands mine projects. We estimate that if all the companies matched the level of performance currently achieved by currently operating leaders orpromised by leading operations under development, the performance of the industry as a whole could besubstantially improved:

5

4


Summary

(Assumes maximum production of all mines; does not include Suncorand Syncrude.)

The scope for improving environmentalperformance is not limited to adoptingthe strategies of the current leaders. Inmany instances, there are technologicallyand economically feasible mitigationstrategies that surpass the performance of the current industry leader.

Voluntary improvement targets appearrare for oil sands companies.

Although almost all companies haveenvironmental policies that commit to continuous improvement, few havepublicly committed to reduce green-house gas pollution, water intensity orair emissions. The government relies onvoluntary efforts by oil sands companies.The survey shows that only a few operationshave voluntarily adopted progressivemanagement practices, and very few haveadopted targets to improve their intensity-based environmental performance.

There is a lack of easily accessibleinformation available onenvironmental performance.

Although all active mining companiesproduce some form of sustainabilityreport, these reports are generally notcomprehensive enough to assess thetotal environmental performance ofeach oil sands project. We appreciate the efforts of those companies thatvoluntarily provided information onrequest (Suncor, Shell, Albian, Synenco,Canadian Natural, Imperial and Petro-Canada). Despite this cooperation, ithas taken substantial time to assemblecomparative information. Although all active oil sands companies makeannual submissions to the Governmentof Alberta, this information is neithereasily available nor presented in a mannerthat would enable Albertans to compareenvironmental performance among oilsands companies.

▲ Table 12 Immediate improvement opportunities.

AirNOx Emissions

Avoided(tonnes/yr)

Savings(%)

SO2 EmissionsAvoided

(tonnes/yr)

Savings(%)

VOC EmissionsAvoided

(tonnes/yr)

Savings(%)

15,604 79% 8,439 47% 50,847 47%

Water ClimateMFT

Avoided (m3/yr)

Savings(%)

Fresh WaterSaved

(m3/yr)

Savings(%)

CO2e Avoided

(tonnes/yr)

Savings(%)

21,769,818 100% 73,566,924 59% 6,339,662 66%



3

2

1

WWF-Canada and thePembina Institute make the following recommend-

ations to improve environmentalmanagement of oil sands miningoperations in Alberta:

Government

Government needs to enforceacceptable standards of environmentalperformance and continuously improveregulations to reflect continuousimprovement in companies’ abilities to reduce environmental impacts.

The relatively weak performance by oilsands companies in this survey demon-strates the need for government toprotect the public interest by providingthe right regulations and incentives toensure that impacts on the environmentare minimized. The Government ofAlberta has recently announced thecreation of a new oil sands division to address the “big challenge” of oilsands environmental management.84

We argue that there are substantial,economically viable improvements to oil sands environmental managementthat could be implemented simplythrough regulatory approvals mandatingbest practices. Our survey clearly showsthat a reliance on voluntary implement-ation of best practices is not resulting in adequate environmental managementin the Fort McMurray region.

Companies should not be expandingoperations unless they can demonstratehow they can operate within the limits

of ecosystems and communities.Currently there is no clear trend ofimprovement.

Government needs to report on environmental impacts to public lands.

The Government of Alberta shouldensure environmental performance data for oil sands companies are easilyaccessible to the public. The PembinaInstitute and WWF-Canada stronglyurge the Government of Alberta tomake company annual environmentalsubmissions readily available to thepublic through government websites to improve public reporting of oil sands environmental impacts and the state of the environment in the Fort McMurray region.

Government must request segregatedinformation to enable comparison ofenvironmental performance.

The Government of Alberta and theGovernment of Canada should ensurethat data provided to them is based onconsistent industry-wide standards andsegregated sufficiently to provide formeaningful comparisons among miningoperations. It is currently not possible torank Suncor and Syncrude’s operationsrelative to the other projects. Intensitymeasures based on a barrel of bitumenare also more useful because futureprojects will not necessarily producetheir own synthetic crude oil.

Recommendations

2

1


Recommendations

Industry

Companies need to implement bestavailable practices and focus ondeveloping and implementing newtechnologies and processes that lead to step-wise reductions inenvironmental impacts.

The expectations for environmentalmanagement in this survey are notunreasonable. The survey shows thatsome operations, even those in theplanning stages, will not achieve a level of environmental performancealready achieved by the better existingoperations or anticipated in regulatoryapprovals. A rapid improvement inenvironmental performance of theindustry as a whole could be achieved if companies adopted existing solutionsdemonstrated by their peers andexplored new ways to reduce environ-mental impacts. The Pembina Instituteand WWF-Canada look forward toworking with companies to substantiallyimprove environmental performance in the oil sands.

A public opinion poll conducted in 2006found that 87% of Albertans polled feltthat oil sands companies could afford to do more to protect the environment.This finding is consistent with the resultsof this report. Clearly, the reputations of oil sands companies and their sociallicense to operate are at risk if thesecompanies are not seen to implementbest practices to protect the environmentand to minimize the environmentalfootprint of their operations.

Companies should not be expandingoperations unless they can demonstratehow they can operate within the limitsof ecosystems and communities.Currently there is no clear trend of improvement.

Companies should make project-specific oil sands environmentalperformance information more widelyavailable and in a consistent format.

Although all active mining companies in this survey provide some form of sustainability reporting, there issubstantial room for improvement in terms of how this information ispresented. No company providedenough publicly available informationfor the Pembina Institute and WWF-Canada to complete the survey withoutsubstantial additional research andcorrespondence.

The Future We hope that this report acts as acatalyst to start a dialogue on whatrepresents appropriate environmentalperformance for oil sands companies asthey develop natural resources on publiclands belonging to all Albertans. WWF-Canada and the Pembina Institute arecommitted to working with companiesto minimize the environmental impactsassociated with oil sands development.We intend to repeat this survey in thefuture and hope to be able to reportimprovements in environmentalperformance among oil sands mineprojects in the Fort McMurray region.



AppendicesFull data and references for every question are downloadable from the PembinaInstitute’s website www. pembina.org.

1 Note that some companies have ownership stakes in multiple oil sands operations.

2 Based on data from Environment Canada (2007) NationalInventory Report, Alberta’s 2005 emissions of CO2e were233,000 kt CO2e. [6339662/233000000=.027].

3 Alberta Energy, Oil Sands, http://www.energy.gov.ab.ca/89.asp(accessed on Aug. 27th 2007).

4 Department of Energy, Talk about Tenure: Facts on Oil SandsTenure (Calgary, Alberta: Government of Alberta 2006).Available online at http://www.energy.gov.ab.ca (accessed onAugust 13, 2007).

5 Alberta Energy, About Petroleum and Natural Gas Tenure,http://www.energy.gov.ab.ca/3067.asp (accessed on August 13th,2007)

6 Alberta Energy and Utilities Board, Alberta’s Energy Reserves 2006and Supply/Demand Outlook 2007-2016, (2006).

7 Imperial Oil Limited, Imperial Kearl Oil Sands Mine Application.(Calgary, Alberta: Imperial Oil Ltd., 2005), Volume 1, 2–25.

8 Imperial Oil Limited, Imperial Kearl Project. EnvironmentalImpact Assessment. (Calgary, Alberta: Imperial Oil Ltd., 2005),Volume 1, 2–38

9 Imperial Oil Limited, Imperial Kearl Project. EnvironmentalImpact Assessment. (Calgary, Alberta: Imperial Oil Ltd., 2005),Volume 2, 9–19

10 Albian Sands Energy Inc., Environmental Impact AssessmentAppendices for the Muskeg River Mine Expansion, Appendix 2-9,Air and Noise Modelling Methods (April 2005), Table 27 andTable 28, pp. 107 and 108.

11 According to Environment Canada’s Facility GHG reportingsystem, 2005 emissions from Syncrude’s Mildred Lake andAurora Plant site and Suncor Energy Inc. Oil Sands total10,357,330.28 and 7,694,457.67 tonnes CO2e respectively.Source: http://www.ec.gc.ca/pdb/ghg/onlinedata/table_e.cfm?sortCol=11&sortDir=DESC&&year=2005&select_gas=All&npri_id=&location=prov&province=48&city=22%20km%20NE%20of%20Fort%20McMurray&NAICS_4_digit=All&cas_number=&srcNaics=srcNaics

12 Canadian Association of Petroleum Producers, StewardshipProgress Report 2006, (2006), Available at http://www.capp.ca.

13 Albian Sands Energy Inc. Albian Sands Energy Inc. operatesboth phases of the Muskeg River Mine. The Muskeg River Mineand the Scotford Upgrader together comprise the Athabasca OilSands Project – a joint venture of Shell Canada Limited,Chevron Canada Limited (a wholly owned subsidiary ofChevronTexaco Corp.) and Western Oil Sands Inc. Source:http://www.albiansands.com.

14 The Kearl oil sands project is a potential oil sands mining,pipeline and upgrading project in Alberta, proposed by ImperialOil Resources Ventures Limited (Imperial Oil) and ExxonMobilCanada Properties (ExxonMobil Canada). Imperial OilResources is the designated operator, Source:http://www.imperialoil.ca.

15 Petro-Canada, UTS Energy Corporation, Teck ComincoLimited and Fort Hills Energy are partners in the Fort Hills OilSands Project. Petro-Canada Oil Sands Inc, a wholly ownedsubsidiary of Petro-Canada, is the contract operator of theProject. Source: http://www.petro-canada.ca.

16 Shell Canada Limited is wholly owned by Royal Dutch Shell plc.Source: http://www.shell.ca.

17 Suncor Energy Inc.’s and Syncrude Canada Ltd.’s productionvalues are in barrels of synthetic crude oil (SCO).

18 Syncrude is a joint venture undertaking among Canadian Oil Sands Limited, Conoco-Phillips Oil Sand Partnership II,Imperial Oil Resources, Mocal Energy Limited, Murphy OilCompany Ltd., Nexen Oil Sands Partnership and Petro-CanadaOil and Gas, as the project owners and Syncrude as the projectoperator. Source: http://www.syncrude.com.

19 Synenco and Sinopec, China’s largest refiner and marketer ofpetroleum products, formed the Northern Lights Partnership todevelop the Northern Lights Project. Synenco is the managingpartner and holds a 60% partnership interest in the NorthernLights Partnership. Source: http://www.synenco.com.

20 Total E&P Canada Ltd. is a wholly owned subsidiary of theglobal oil and gas company Total SA. Source: http://www.total-ep-canada.com.

21 Alberta Environment, Oil Sands Development and Reclamation,http://www3.gov.ab.ca/env/soe/land_indicators/41_oilsands_reclamation.html, (accessed on August 27, 2007).

22 Details about the Environmental Law Centre’s enforcementsearch service are available at:http://www.elc.ab.ca/enforcement/index.cfm.

23 Government of Alberta, Alberta Mineable Oil Sands Strategy,http://www.oilsandsconsultations.gov.ab.ca/MOSS_TOC.html,(accessed on August 27, 2007).

24 Mary Griffiths et al, Troubled Waters, Troubling Trends. TechnologyOptions to Reduce Water Use in Oil and Oil Sands Development inAlberta (Calgary, Alberta: The Pembina Institute for AppropriateDevelopment, 2006), 16.

25 Golder Associates Ltd., A Compilation of Information and Dataon Water Supply and Demand in the Lower Athabasca River Reach,prepared for the Cumulative Environmental ManagementSurface Water Working Group, (Calgary, Alberta: GolderAssociates Ltd., 2005).

26 D.W. Schindler, W.F. Donahue and J.P. Thompson, “Futurewater flows and human withdrawals in the Athabasca River” in Running Out of Steam? – Oil Sands Development and Water Use in the Athabasca River-Watershed: Science and Market BasedSolutions. (The Munk Center for International Studies,University of Toronto and the Environmental Research andStudies Centre, University of Alberta, 2007). 1-38.

27 Imperial Oil Limited, Imperial Kearl Oil Sands Mine Application,(no. 1408771 & 1414891, volume 4),(Calgary, Alberta: Imperial Oil Ltd., 2005), 3-31

28 National Pollutant Release Inventory, On-Line Data Search,http://www.ec.gc.ca/pdb/npri/npri_online_data_e.cfm, (accessed on August 27, 2007).

29 Based on Syncrude emissions of 10.357 million tonnes CO2eq in 2005, the average car consumes 10.2 L/100km and travels 15,400 km a year and the combustion of gasolineemits 2.44 kg/L CO2eq.

30 http://www.globalreporting.org/Home.

31 http://www.jantziresearch.com/ (accessed on August 27, 2007).

32 http://www.innovestgroup.com/ (accessed on October 23,2007).

33 Global Environmental Management Initiative (GEMI), ISO14001 Environmental Management System Self AssessmentChecklist, http://www.gemi.org/docs/PubTools.htm, (accessed onAugust 29, 2007).

34 Ibid.

35 Synenco Energy Inc., Northern Lights, A Synenco SinoCanadaPartnership Mining and Extraction Project Application, (2006),Volume 3, Section 3.0 and personal communication, KenDilling, June 15th, 2007.

Endnotes




Endnotes

36 Shell Canada Inc., 2006 Sustainability Report, (2007), 31.

37 For more information on the Global Reporting Initiative, go tohttp://www.globalreporting.org/AboutGRI/.

38 Source: http://www3.gov.ab.ca/env/protenf/compliance/pubs/QuarterlyReport_Jan-Mar2005.pdf (accessed October 11, 2007).

39 Suncor Energy Inc., Report on Sustainability 2006: A closer lookat our jouney toward sustainable development.(2007) 56.

40 Syncrude Canada Limited, Sustainability Report: A NewGeneration of Opportunity, (2005), 57.

41 Government of Alberta, Alberta Mineable Oil Sands Strategy,http://www.oilsandsconsultations.gov.ab.ca/MOSS_TOC.html,(accessed on August 27, 2007)

42 An exception is the approval for the True North (now Petro-Canada) Fort Hills Project. The EUB directed True North tolimit the amount of disturbed land at any one time to 5000hectares. Surprisingly, no other oil sands approvals include asimilar mechanism to assure accountability for reclamationperformance. EUB Decision Report 2002-089. True NorthEnergy Corporation. Application to Construct and Operate an Oil Sands Mine and Cogeneration Plant in the Fort McMurrayArea. October 22, 2002.

43 Suncor Energy Inc., A Closer Look at our Journey towardsSustainable Development: 2007 Report on Sustainability, (2007), 40.

44 R. Reeves, R. and H. Walsh, The State of Alberta’s Parks andProtected Areas: An analysis of the challenges and opportunities forensuring ecological integrity. (Canadian Parks and WildernessSociety, 2007) 22.

45 The Pembina Institute, Probe Research 2006 Pembina InstituteOil Sands Survey. Final Report (May 1, 2006), Available at:http://www.pembina.org/pub/1446.

46 The Canadian Boreal Initiative (CBI) is working with a widerange of conservation organizations, First Nations, industry andother interested parties to link science, policy and conservationactivities in Canada’s boreal forest. On December 1, 2003 theCBI released the Boreal Forest Conservation Framework — themost extensive national conservation vision ever. The frameworkwas developed in concert with leading conservationorganizations, resource companies and First Nations. Convenedby the CBI, this group forms the Boreal Leadership Council,committed to the conservation and sustainable development ofCanada’s boreal forest region.

47 Canadian Boreal Initiative, The Boreal Forest ConservationFramework, http://www.borealcanada.ca/framework_e.cfm,(accessed on August, 29, 2007).

48 Alberta Biodiversity Monitoring Institute,http://abmi.biology.ualberta.ca/index.htm, (accessed on August29, 2007).

49 Emissions estimates reported as tonnes per year were convertedto grams per barrel of bitumen (g/bbl) to facilitate comparisonusing an intensity-based measurement.

50 Environment Canada, Nitrogen Oxides (NOx) Emissions forCanada, http://www.ec.gc.ca/pdb/cac/Emissions1990-2015/EmissionsSummaries/NOx_e.cfm, (accessed on September11, 2007).

51 The World Health Organization’s one-hour and annual NO2concentration guideline is set at 40 ug/m3 (World HealthOrganization, Use of the air quality guidelines in protecting public health: a global update, http://www.who.int/mediacentre/factsheets/fs313/en/, (accessed on September 22nd, 2007). The Alberta Air Quality Objectives state a 200 ug/m3 and 60ug/m3 NO2 concentration for one 24-hour and annual periods.(Alberta Environment, Alberta Ambient Air Quality Objectives,http://environment.gov.ab.ca/info/library/5726.pdf, (accessed onSept. 22nd, 2007). The Muskeg River Mine Expansion projectstates that all existing and approved NO2 emissions will result in NO2 concentrations of 261.5 ug/m3 and 63.7 ug/m3 duringa 24-hour and annual period of time respectively (Albian SandsEnergy Inc., Muskeg River Mine Expansion Application, (2005),Air Quality and Noise Assessment, Table 3.1-3, pg. 3-8). These concentrations are above the guidelines.

52 Shell Canada Ltd., Application for the Approval of the MuskegRiver Mine Expansion Project (Application for Approval). (2005),Volume 2, Appendix 2-9, 73.53 Imperial Oil ResourceVentures Ltd. Kearl Oil Sands Project - Mine Development:Regulatory Application. (2005), Volume 5, Appendix 2B.1.5, 2B-71

54 Ibid.

55 Emissions estimates reported as tonnes per year were convertedto grams per barrel of bitumen (g/bbl) to facilitate comparisonusing an intensity-based measurement.

56 The World Health Organization 24-hour SO2 concentrationguideline is set at 20 ug/m3 (World Health Organization, Use of the air quality guidelines in protecting public health: a global update, http://www.who.int/mediacentre/factsheets/fs313/en/, (accessed on September 22nd, 2007). The Alberta AirQuality Objectives state a 150 ug/m3 SO2 concentration over a24-hour period. (Alberta Environment, Alberta Ambient AirQuality Objectives, http://environment.gov.ab.ca/info/library/5726.pdf, (accessed on Sept. 22nd, 2007). The Muskeg RiverMine Expansion project states that all existing and approvedSO2 emissions will result in SO2 concentrations of 176.5 ug/m3during a 24-hour period (Albian Sands Energy Inc., MuskegRiver Mine Expansion Application, (2005), Air Quality and Noise Assessment, Table 3.1-3, 3-8).

57 Environment Canada, Guide for Reporting to the NationalPollutant Release Inventory, http://www.ec.gc.ca/pdb/npri/2006Guidance/Guide2006/toc_3.cfm, Appendix 3 (accessed on August 29, 2007).

58 Dan Woynillowicz, Chris Severson-Baker, Marlo Raynolds, OilSands Fever: The Environmental Implications of Canada’s OilSands Rush, (Calgary, Alberta: The Pembina Institute, 2005), 45.

59 Environment Canada, Volatile Organic Compounds (VOC)Emissions for Canada, http://www.ec.gc.ca/pdb/cac/Emissions1990-2015/EmissionsSummaries/VOC_e.cfm, (accessed on September11, 2007).



62 Syncrude Canada Limited, Sustainability Report: A NewGeneration of Opportunity, (2005), 57.

63 National Energy Board, Canada’s Oil Sands: Opportunities andChallenges to 2015, (2004), 68.

64 More information on this process can be found athttp://www.bitminresources.com/Process/bitmin_process.htm.

65 Synenco SinoCanada Partnership, Northern Lights Mining andExtraction Project Application: Submitted to Alberta Energy andUtilities Board and Alberta Environment, (2006), Volume 2,Section 8.0, Tailings Management.

66 Deer Creek Energy Limited, a wholly owned subsidiary of TotalE&P Canada Ltd., Joslyn North Mine Project. Alberta Energy andAlberta Energy and Utilities Board Integrated Application, (2006),Section B 5-10.

67 Alberta Environment and Fisheries and Oceans Canada, WaterManagement Framework: Instream Flow Needs and WaterManagement System for the Lower Athabasca River, (2007).

68 Calculated average from 2012 to 2034 based on the planneddevelopment case in the Imperial Oil Resources Ventures Ltd.Kearl Oil Sands Project – Mine Development, (2006), Volume 6,Section 4, Table 4-45, 4–98.

69 Alberta Environment and Fisheries and Oceans Canada, Water Management Framework: Instream Flow Needs and WaterManagement System for the Lower Athabasca River, (2007).

70 National Pollutant Release Inventory, On-Line Data Search,http://www.ec.gc.ca/pdb/npri/npri_online_data_e.cfm, (accessed onAugust 27, 2007).


Endnotes

71 Based on Syncrude emissions of 10.357 million tonnes CO2eqin 2005, the average car consumes 10.2 L/100km and travels15,400 km a year and the combustion of gasoline emits 2.44kg/L CO2eq.

72 Matthew Bramley, The Case for Deep Reductions: Canada’s Role in Preventing Dangerous Climate Change (Calgary, Alberta:The Pembina Institute, 2005). Also available online:http://climate.pembina.org/pub/536.

73 The Tyndall Centre & WWF. Climate Change Policy andCanada’s Oil Sands Resources, (UK/Canada, WWF, 2007). Also available online: http://wwf.ca/resources/pdf/TyndallFinalJointReport.pdf

74 The Pembina Institute, The Climate Change Implications ofCanada’s Oil Sands Development: Backgrounder, (Calgary, Alberta:The Pembina Institute, 2006), 5. Also available online:http://www.pembina.org/publications_item_.asp?id=213.

75 Ibid, 3.

76 Based on data from Environment Canada (2007) NationalInventory Report, Alberta’s 2005 emissions of CO2e were233,000 kt CO2e. [6339662/233000000=.027].

77 Ibid.

78 National Pollutant Release Inventory, On-Line Data Search,http://www.ec.gc.ca/pdb/npri/npri_online_data_e.cfm, (accessed on August 27, 2007).

79 Probe Research, Pembina Institute 2007 Alberta Oil Sands Survey:Final Report, (2007) Available at:http://www.pembina.org/pub/1446.

80 Global Environmental Management Initiative (GEMI), ISO 14001 Environmental Management System Self AssessmentChecklist, http://www.gemi.org/docs/PubTools.htm, (accessed onAugust 29, 2007).

81 Shell Canada Limited, Sustainable Development Report, (2006), 35.

82 The Gold Standard – Quality Assurance for CDM and JIProjects. WWF. Available at http://www.panda.org/about_wwf/what_we_do/climate_change/solutions/business_industry/offsetting/gold_standard/index.cfm

83 Shell Canada Limited, Sustainable Development Report, (2006), 35.

84 Government of Alberta, Take on the World,http://www.takeontheworld.gov.ab.ca/, (accessed on August 27, 2007).

Documents

THE OIL SANDS REPORT CARD - Pembina Institutevi UNDERMINING THE ENVIRONMENT: THE OIL SANDS REPORT CARD The Pembina Institute / WWF-Canada Table of Contents List of Figures Figure 1