Thanks for the opportunity to speak to you today on what I see as one of the most important freshwater issues in Canada today.
My name is Tony Maas. I'm senior freshwater policy adviser with WWF Canada.
As some of you may know, and as others may not, WWF Canada prides itself on being a science-based and a solutions-based organization. What that means is that we tend to focus our efforts on working across sectors--public, private, not-for-profit--to look for and implement solutions to today's increasingly complex environmental problems, as long as we understand, as well as possible, the underlying science. When we don't understand that science, or when it is incomplete or in question, we advocate precaution.
With that as an early background, not unlike my colleague from the Pembina Institute, I'm here recommending that no further approvals for oil sands projects that require water withdrawals be granted in the near term. I make that recommendation because we believe decisions are being made in the absence of best possible science and with little or no precaution.
I should also note here that WWF is an active member of the phase two management framework committee, the P2FC. This is the group of industry, first nations and Métis, and other environmental organizations, as well as federal and provincial government representatives, that is working to develop a recommendation for what we hope will be an improved water management plan for the lower Athabasca River. As part of that, we have agreed with our colleagues on that committee not to discuss publicly the internal workings of the committee, as it's ongoing.
I'm going to frame my discussion around the concept of environmental flow, or what in Alberta is often referred to as instream flows.
Aquatic ecologists widely recognize that a river's natural flow regime--the peaks and troughs, the high and low flows--is critical to sustaining the integrity and productivity of freshwater ecosystems. The Athabasca River is unique when it comes to environmental flows. It is unimpeded by dams, so flows are largely natural. It is in fact the third-largest free-flowing river in North America.
Because the Athabasca is not impeded by dams and other infrastructure, there is significant interannual and intra-annual variability. It is this variability that sustains not only the integrity of the river but also the downstream Peace-Athabasca delta. That delta, as you might know, is 80% protected by Wood Buffalo National Park, which is a UNESCO world heritage site.
Also worth pointing out in connection with this interannual and intra-annual variability is that winter low-flows are the most critical period of time for the health, productivity, and survivorship of species in the Athabasca River, simply because flows are lowest at that point.
When we talk about environmental flows, it's important to recognize that there are sustainable limits to the degree to which we can disrupt flow regimes. When we think about this in the context of oil sands development, it appears very much that we put the cart before the horse.
Alberta Environment has licensed oil sands operators to extract significant volumes of water from the Athabasca River before setting sustainable limits on those withdrawals and before appropriate protections were put in place. This has been acknowledged, in fact, through the phase one management framework approach; however, we believe the phase one management framework for the lower Athabasca, the existing management framework that is in place, is inadequate, for at least three reasons.
First of all, as has been mentioned, there is no ecosystem base flow. An ecosystem base flow is essentially a threshold or limit below which, in order to protect the ecosystem, no further withdrawals from the river should be allowed. However, under the phase one approach, industry is allowed to take at least 5.2% of the median flow at any time, regardless of the severity of low flow.
It's important to recognize that some of the statistics that were put out this morning around the percentage of annual average flow that oil sands operators take from the river can be very misleading. The important timeframe to be considering is the period of these very low flows. At these times, the proportion of flow being taken by oil sands operators is much more than the annual average numbers would lead you to believe.
Second, there are no provisions for peak flows, those high flows that are very important to replenishing the Peace-Athabasca delta. The phase two framework simply assumes, without significant scientific support, that withdrawals will not affect ecosystem health, and it will therefore allow operators to withdraw the maximum amount of water they can during that period of time.
Finally, and I think incredibly importantly--it's come up a number of times--the phase one framework failed to acknowledge the impacts of climate change on future flows in the Athabasca River. Science tells us that flow is in fact declining in the Athabasca River, and that the decline is largely due to human-induced climate forces.
Over the past couple of years, WWF has commissioned reports by Dr. Jim Bruce, who some of you may know. He's the chair of the groundwater report that has been mentioned a number of times. He's also a member of the Intergovernmental Panel on Climate Change and a world-renowned, Canadian-renowned, climate scientist.
In a report commissioned by WWF, Dr. Bruce predicted that by 2050 the mean annual flow of the Athabasca could decline by 25%, and low flows could decline by 10%. We recently asked Dr. Bruce to update his report. What came out of that was a warning that his early predictions might be wrong for a couple of reasons, and that flows might decline quicker.
Those reasons include the fact that greenhouse gas emissions are increasing more rapidly than the IPCC assessments suggest, and headwater glaciers that provide some of the base flow to rivers like the Athabasca have passed the tipping point. They were providing more flow to rivers because of melting, and are now providing less base flow.
Finally, when we think about environmental flow we can't forget the quality dimension. It is important to recognize that when we're looking at the flow of a river, it carries pollution from upstream activities to downstream communities and ecosystems. I think an important way of looking at this is as an issue of watershed equity. When we are putting downstream communities at risk, we are putting ourselves increasingly in a position of conflict.
At the heart of this issue is the tailings ponds that have been discussed at length today, the seepage from those tailings ponds and its impact on the health of downstream communities such as Fort Chipewyan. But when you think about the potential--regardless of how low it might be--for a catastrophic breach of a tailings pond, the watershed equity issue stretches well downstream into the Mackenzie River basin, including the Northwest Territories.
Here again there's significant uncertainty related to the human and ecosystem impacts associated with tailings seepage, but there's also significant uncertainty related to how pollutants would disperse in the event of a catastrophic tailings breach.
To conclude, I think it's safe to say that for too long oil sands development has progressed without the appropriate oversight and leadership of the federal government. There are clear indications that the federal government has an incredibly important role to play and responsibilities in the realms of fish and fish habitat protection, transboundary water issues, and protection of aboriginal rights. What has been called a complex and confusing allocation of water management powers between federal and provincial governments is often used as an excuse for inaction.
We have a couple of specific recommendations for the federal government to demonstrate and take leadership on freshwater issues related to oil sands. Federal leaders, including the Minister of Fisheries and Oceans, should be encouraged to support the recommendations that come out of the phase two water management framework committee, and ensure that the framework has full political support so it moves toward an implementable water management framework and is resourced so that it can be implemented and enforced.
As you may be aware, under the original phase one management framework, a DFO biologist proposed a more stringent approach that was much more protective of the ecosystem. It included an ecosystem-based flow; however, it is unclear to us why that approach did not end up as part of the phase one management framework.
Finally, there is an opportunity here for the federal government to show leadership in an area where there is potential for growing conflict around transboundary water issues within this country. Alberta and the Northwest Territories are in the midst of negotiating a bilateral agreement under the Mackenzie River basin transboundary agreement. The federal government is a party to that agreement, and we recommend that the federal government participate in those negotiations to ensure that what emerges out of that is a robust water management plan that ensures watershed equity and reduces conflict.
Thank you.