Introduction
The 2019 Critical Review (CR) by Brook et al. (Citation2019) summarizes research done by Environment Canada and Climate Change (ECCC) related to ambient concentrations and ecosystem effects in Canada’s Oil Sands Region (OSR) of northern Alberta. Herein, expert discussants provide additional perspectives and information on the topic. Their appearance as coauthors does not necessarily indicate their agreement with the opinions of other discussants. While discussants believed that the CR is a useful summary of ECCC efforts in the OSR, they found that relevant research not performed by ECCC was omitted and that the CR did not balance or explain contradictions and disagreements found among research reports and publications. The online supplement (Watson, Altshuler, and Chow Citation2019) to this Discussion identifies more than 850 resources that address oil sand processes, emissions, effects, and environmental controls in Alberta’s OSR and other parts of the world. Brook et al. (Citation2019) offer a response to this Discussion as an online supplement.
The CR isn’t critical—Dr. Allan H. Legge
The CR provides a description of ECCC work first done under the Joint Oil Sands Monitoring (JOSM) Program and then the Oil Sands Monitoring (OSM) Program. It is not a typical A&WMA CR that intends to examine and evaluate a wide range of publications and reports that consider issues from different perspectives. The CR assumes that the work described, and the results presented from areas of air, water, and wildlife themes are valid. A more holistic, integrated, transparent, and inclusive approach to research and monitoring activities in the OSR is missing. For example, ECCC modeling found that acidification was widespread in eastern Alberta and Saskatchewan. However, field measurements (e.g., Hazewinkel et al. Citation2008) do not show such acidification. There is no demonstration of an understanding of OSR operations and processes (Anon Citation2019) that affect emissions. The important role of Traditional Environmental Knowledge (TEK) (Garibaldi Citation2009) of the First Nations and Métis peoples is omitted. ECCC’s viewpoint is that they are the only ones with scientific credibility and thus the only ones that can provide true answers.
ECCC experiments seem to have been motivated by the assertions of Kelly et al. (Citation2009): “Historical stack discharges of particulate rich in aluminum and a strong correlation between Al and polycyclic aromatic compound (PAC) concentrations in snow suggest that large amounts of particulate PACs have been discharged since the onset of oil sands production in the 1960s … . . If deposition rates are constant throughout the year, the estimated annual release of PACs would be equivalent to a major oil spill, repeated annually.” The main source of deposited PACs appears to be petroleum coke (petcoke) dust from storage areas near oil sands facilities (Zhang et al. Citation2016) which is highly erodible by wind (Wang et al. Citation2015b). Upgrader and flue gas desulfurization stack emissions have been shown to have relatively low particulate matter (PM) emission rates that have decreased over time and that contain few PACs (ERCB Citation1994; Golder Associates Citation1998; Wang et al. Citation2012).
There is a lack of awareness of environmental monitoring programs done in the past in the OSR. A specific example is the Provincial/Federal Alberta Oils Sands Environmental Research Program (AOSERP) carried out from 1975 to 1980 and summarized by Smith (Citation1981). It was noted by Smith (Citation1981) that “ … AOSERP has produced an extensive data base which has resulted in a reasonable understanding of existing environmental conditions both in the natural and in the human environment of the region.”
Although the CR provides a summary of ECCC efforts in the OSR, the scientific community awaits a ‘weight of evidence’ review that provides answers and not simply the use and output of models.
Broader goals and results from the oil sands monitoring (OSM) program—Dr. Monique Dubé
The OSM Program is one of the largest multi-media environmental monitoring programs in the world with over C$350M invested to date. The OSM Program objective is to integrate monitoring, evaluation, and reporting to: (1) assess the environmental state and whether there have been changes in the oil sands region; (2) determine relationships between environmental stressors and responses and evaluate the extent to which responses are caused by oil sands-related stressors; and (3) assess cumulative effects.
The OSM Program has a multi-stakeholder governance structure, jointly led by Alberta Environment and Parks (AEP) and the federal ECCC and is funded by industry under regulation at C$50M per year. Indigenous communities are actively involved in the design, governance and implementation of the Program, including community-based monitoring. The program includes Alberta’s three OSRs (Athabasca, Cold Lake, and Peace River) and monitoring is conducted for eight theme areas, encompassing air, water, land, and biodiversity. The OSR Program includes over 20 organizations and over 70 work plans with 53 project leads. An Operational Framework Agreement (OFA) (Dubé et al. Citation2018) was developed and signed by multiple stakeholder groups including the provincial and federal governments and 18 First Nation and Métis communities with the vision of: “An integrated monitoring, evaluation and reporting system inclusive of and responsive to Indigenous Communities, that includes the acquisition and reporting of regional and sub-regional data on baseline environmental conditions, tracking any environmental impacts, and the assessment of cumulative environmental effects from oil sands development to inform management, policy and regulatory action … ”
The limited scope of the CR does not represent the OSM Program as a whole, and it is not recognized by OSM Program governance as a formal review. The CR does not include results from important terrestrial environmental effects monitoring conducted by the Wood Buffalo Environmental Association (WBEA Citation2019) and other monitoring organizations in the OSR. There have been over 130 publications (see online supplement) in the air and atmospheric deposition theme since 2009 on topics including acidification/fertilization, ambient air quality, PACs, trace elements, mercury, greenhouse gases (GHGs), and wildfire impacts. Less than one-third of these publications (31%) were included in the CR.
The CR describes improvements to the GEM-MACH (Global Environmental Multi-scale – Modeling air quality and Chemistry) model’s ability to estimate air pollutant concentrations and deposition patterns in the OSR, including the results of the TERRA (Top-down Emission Rate Retrieval Algorithm) model emission estimates derived from aircraft measurements during the period of Aug. 13 to Sept. 7, 2013. This work (Cheng et al. Citation2018; Li et al. Citation2017; Zhang et al. Citation2018) improved the understanding of air pollutant emissions and transport associated with oil sands operations. Data from the top-down aircraft measurements improved air modeling capabilities and provided key information for understanding the contribution of oil sands activities to ambient air quality and atmospheric deposition (Akingunola et al. Citation2018; Gordon et al. Citation2018; Russell et al. Citation2019; Stroud et al. Citation2018; Whaley et al. Citation2018).
The CR does not recognize the extensive air monitoring network operated by WBEA since 1998 and the Lakeland Industry and Community Association (LICA Citation2019) since 2000. WBEA operates networks of continuous, time integrated and passive air quality monitors close to industrial operations and distant (up to 150 km) from oil sands development. WBEA’s Terrestrial Environmental Effects Monitoring (TEEM) has used ground-based measurements to determine potential effects of sulfur, nitrogen, and base cation deposition on acidification and eutrophication of forest ecosystems (Foster et al. Citation2019). TEEM has identified spatial patterns of trace metals and organic compounds in the OSR, as summarized in a recently published virtual journal issue (Munkittrick Citation2019). Source apportionment using lichen and PM data by Landis et al. (Citation2019b) identifies fugitive dust emissions as a dominant contributor of contaminants close to oil sand operations.
The OSM Program also includes water monitoring for acid sensitive lakes, groundwater, surface water quality, wetlands, and sub-basin water quality, with more than 60 peer-reviewed papers of which only 25% are referenced in the CR. The CR highlighted Kurek et al. (Citation2013) that reported increases in sediment core PACs relative to pre-development levels. However, the OSM Program finds that concentrations were generally below guidelines for parent PACs in 5 of 6 lakes sampled within ~13–90 km from Kurek et al.’s AR6 reference location near Syncrude and Suncor upgraders. Estimates of oil sands constituents up to 90 km from AR6 did not account for the potential influence of construction, upgrading, and mining activities at the Horizon Mine. PACs levels were within the range typical of remote lakes and were much lower than levels in urbanized and industrialized catchments. No toxic responses to higher PAC concentrations were observed. Instead, higher productivity attributed to climate change was observed. Other sediment core studies (not in the CR) found similar results (Ahad et al. Citation2015; Elmes et al. Citation2016; Hall et al. Citation2012; Jautzy et al. Citation2013).
The CR highlights increases in metals and mercury in snow pack surveys within 50 km of AR6 (Kelly et al. Citation2010; Kirk et al. Citation2014; Willis et al. Citation2018). However, Wiklund et al. (Citation2012) in the Peace Athabasca Delta, Laird et al. (Citation2013) in 10 lakes of northwest Saskatchewan (~80–250 km from AR6), and Cooke et al. (Citation2017) in 20 OSR lakes (~10–100 km from AR6), all suggest limited evidence of temporal increases in sediment metals and mercury concentrations from oil sands development. Decreasing metal concentrations have also been reported in peat cores collected from rain-fed bogs at varying distances from AR6 (Shotyk et al. Citation2016, Citation2017). Although potential lake acidification risk is highlighted by the CR models, other studies report little evidence of lake acidification based on sediment cores collected in northern Alberta and Saskatchewan (Curtis et al. Citation2010; Hazewinkel et al. Citation2008; Laird et al. Citation2013, Citation2017). Local chemical and physical influence of industry is apparent in lake sediments (<50 km from AR6), but reduced loadings over time have been observed for some metals (Cooke et al. Citation2017). Some upstream to downstream changes have been found in chemical constituents of water in the Athabasca River, but separating natural and anthropogenic causes has been challenging (Shotyk et al. Citation2017). Oil sands process water may be present in McLean Creek and the Lower Beaver River (Sun et al. Citation2017) and in sediment pore water beneath the Athabasca River (Frank et al. Citation2014). There is a similar ecological risk from process water-affected and -unaffected groundwater (Roy et al. Citation2016). Water quantity is likely affected by long-term climate variability and not due to water extraction by oil sands operators (Sauchyn, St-Jacques, and Luckman Citation2015). Changes in sentinel organisms in rivers (Kurek et al. Citation2013; Simmons and Sherry Citation2016) and lakes (Kurek et al. Citation2013) suggest increased productivity, including potential responses to climate warming (Hazewinkel et al. Citation2008) and municipal wastewater discharges (Culp et al. Citation2018).
Studies related to swallow nestlings, harvested birds and wildlife, amphibians and wetlands, and colonial water bird contaminants are referenced in the CR, but more than 60 publications are available since 2009 with only 8% of this literature referenced in the CR. Landscape disturbance has diverse effects on abundance and occupancy of mammals and bird species. Those preferring mixed, young stage, or disturbed forests tend to be neutrally or positive affected while those preferring intact, undisturbed, and/or old growth forests are more likely to be negatively affected (Fisher and Burton Citation2018). Linear disturbances change the behavior of many species relative to intact forest (from ungulates to carnivores to butterflies to plants), largely by facilitating movement (Dickie et al. Citation2017). Caribou populations are reduced and declining, largely due to increased wolf predation resulting from increased habitat overlap (Boutin et al. Citation2012). This overlap is a result of deer population increases and northward movement as well as wolf selection for linear disturbances (Latham et al. Citation2011).
Conclusions regarding the “challenges of assessing ecosystem impacts and summarizing the major results” must be tempered by the fact that the CR was limited mostly to articles published by ECCC scientists and not all OSM data has been released via peer-reviewed publications. Statements such as “there is growing evidence of the impact of current levels of PACs on some species” may not be accurate. PAC deposition is occurring and uptake in the tissues of some species has been documented. However, clear translation of exposure to biological effects has not been identified in the species studied thus far. Statements from the CR regarding “increased coordination or integration across themes … ” are aligned with the efforts of the OSM Program but would be more helpful if the CR itself was more integrated and inclusive of the entire body of knowledge gained from multiple organizations that are part of the OSM Program. It would also be helpful if the CR showed awareness of the initiatives of the OSM Program governance committees that are facilitating this future integration.
Long-term ecosystem monitoring is available to determine trends and effects—Dr. Kevin E. Percy
The CR does not recognize the strategic linkage of air and terrestrial systems through plot level co-measurement. Clair and Percy (Citation2015) (not included in the CR) summarize regional forest health from 1998–2011 at the regional network of jack pine monitoring sites stratified on ecological and deposition gradients. This assessment found that deposition and trace elements in vegetation reached background levels ~40–50 km away from industrial emission sources. Measurable changes in foliar or soil parameters that could be related to oil sands development occurred only within ~20 km of industrial sources. Nitrogen (N) is being taken up by vegetation, and it is not accumulating in mineral soils. Sulfur (S) in soils was correlated with modeled S + N deposition. Soil microflora as well as vascular cover, forb cover, and shrub richness were positively related to measured atmospheric deposition of base cations. There was no correlation between ecosystem variables and S and N as acidifiers as base cation deposition was neutralizing acid inputs. Results are suggestive of a fertilization effect of atmospheric deposition.
Foster et al. (Citation2019) provide further context related to targeting ecosystem protection. Sulfur emissions from the expanding oil sands industry increased from the 1990s through the mid-2000s and have subsequently decreased. Nitrogen emissions have been steadily increasing. Use of a minimum distance to the nearest industrial (stack, mine) source yielded a more precise spatial representation of deposition compared to the use of a single point (e.g., AR6) in the approximate center of operations. Jack pine radial growth was negatively related to distance from emission sources, both before oil sands development as well as in recent years. There are no indications of widespread acidification effects in sensitive jack pine ecosystems. Approximately 63% of PAH/PACs in lichens were derived from coarse petcoke and oil sand ore emissions, 90% of which were deposited within 25 km of emission sources. Lichen lead content originated from Western Canadian regional (46%), OSR (32%) and global (22%) sources; most OSR-produced particulate lead deposited within 30 km of emission sources. Source apportionment studies indicate the important contribution of fugitive dust to elemental deposition. Potential acid input estimated from monitoring data ranged from 0.1 to 0.2 keq/ha/yr across the OSR, except in three areas near industrial operations – two where deposition of up to 0.8 keq/ha/yr was estimated and one where deposition of ~0.6 keq/ha/yr (base cation dominated) was estimated.
Petcoke dust emissions are a dominant PAC contributor—Dr. Jason Ahad
The CR notes that PACs originate from a variety of sources, including engine exhaust, stack emissions, wildfires, and fugitive dust from mine faces, tailings berms, and the large petcoke stockpiles. A growing number of studies indicate that fugitive dust, especially that from petcoke piles is a major source of mining-related PACs found in emissions and the surrounding environment (Harner et al. Citation2018; Jariyasopit et al. Citation2018; Jautzy et al. Citation2015; Landis et al. Citation2019a; Manzano et al. Citation2017; Xing and Du Citation2017; Zhang et al. Citation2016). Few studies have investigated the effects of petcoke on OSR wildlife; one of which examined the potential for petcoke to limit the exposure of aquatic biota to the residual contaminants associated with fine tailings (Baker, Ciborowski, and MacKinnon Citation2012) and another which examined the potential toxic effects of petcoke extracts in birds (Crump et al. Citation2017).
Of particular concern is the extent to which significant levels of mining-related contaminants reach the Peace-Athabasca Delta (PAD), an ecologically important landscape composed of interconnected channels and lakes situated ~150 km downstream of OSR operations. Mining-related PACs could be transported to the PAD through either direct atmospheric deposition or via the Athabasca River. In the case of the latter, dust deposited to snowpack during winter could potentially carry PACs to the river and its tributaries during the spring melting (Parrott et al. Citation2018). Hall et al. (Citation2012) found no evidence for significant atmospheric transport of mining-related PACs to the PAD, and no measurable increase in river-transported bitumen-associated PACs in sediments deposited in a flood-prone lake since the onset of OSR development. Although other work carried out in the PAD was cited in the CR, results from this pivotal non-JOSM-funded study were not discussed (financial support was provided by Suncor Energy Ltd).
One of the main initial drivers for environmental research in the OSR was to understand the extent to which surface mining activities contribute to atmospheric emissions of contaminants such as PACs at distant sites. In lakes situated around 100–220 km east-northeast of the OSR in neighboring Saskatchewan, Ahad et al. (Citation2015) found small yet discernible increases in PAC concentrations and fluxes in sediment cores over the past several decades. However, several lines of geochemical and isotopic evidence pointed to wildfires as the principal source. As with the initial work in the PAD carried out by Hall et al. (Citation2012), this seminal study was not included in the CR.
In surface layers of Sphagnum moss, Shotyk et al. (Citation2014) reported lower concentrations of Ag, Cd, Ni, Pb, Sb, and Tl, similar concentrations of Mo, but greater concentrations of Ba, Th, and V in samples collected from 21 ombrotrophic bogs in the OSR compared to moss from four bogs in rural southern Germany. Although the conclusions of this study were challenged (Blais and Donahue Citation2015), a subsequent investigation employing peat cores collected from five bogs in the vicinity of open pit mines and upgraders found that atmospheric contamination by trace metals was low and has been declining for decades (Shotyk et al. Citation2017). The omission of these important investigations from the CR limits its ability to assess the overall cumulative effects of oil sands mining activities.
Industry needs more timely and relevant results—Mr. Calvin Duane
Results of ECCC research have been published at least five years after sampling. If the primary purpose were to determine how oil sands development may be affecting the environment such that industry could better manage its processes and emissions, then the information is too late to be of use for ongoing development. This extended time lapse between data collection and reporting constrains timely effective management. The OSM Program is unconstrained in its timeline for delivering results, and reporting to date has been sporadic, primarily through scientific journals, and long after the fact. The situation in the OSR today differs from that when the data were acquired and interpreted. Natural bitumen in rivers needs to be considered when addressing potential sources of environmental contaminants. Forest fires contribute to adverse air quality and surface deposition. A key criticism of Regional Aquatic Monitoring Program was the lack of data availability. Program-level annual state of the environment reporting is Canada’s Oil Sands Innovation Alliance’s (COSIA Citation2019) expectation of the OSM Program.
OSR emissions are poorly characterized—Drs. Judith C. Chow and John G. Watson
Although much information is available on ambient concentrations in air, water, and land, there is minimal information on real-world emissions from OSR sources in terms of their emission rates and compositions. Canada’s National Pollutant Release Inventory (NPRI; ECCC, Citation2019) is only as accurate and precise as the data submitted to it. Stationary source compliance is often determined by methods such as Method 5 (U.S.EPA Citation2000) which over- or under-estimates PM emissions depending on how the impinger catch following a hot filter sample is treated (Watson et al. Citation2012). Dilution sampler measurements (Wang et al. Citation2012) provide more realistic measurements and also demonstrate the variability of emissions owing to a variety of processes being directed through a single stack and continuing addition of emission reduction measures. Wang et al. (Citation2016) found three methods used by three different companies to report heavy hauler emissions based on certification test results supplied by the manufacturer. Real-world measurements were lower than those reported for most pollutants. Fugitive dust, especially petcoke, has been noted above as a potentially large contributor, but measurements are lacking. Wang et al. (Citation2015b) found an order of magnitude difference between emissions from the disturbed and crusted surface of a petcoke pile, indicated that minimizing surface damage and stabilization efforts could greatly reduce off-site effects. The composition of fugitive emissions is also variable depending on the source (Wang et al. Citation2015a).
Most people are acquainted with the OSR through concerns about its greenhouse gas (GHG) emissions relative to those from other fossil fuel sources. Life cycle analysis (Keoleian and Menerey Citation1994; Watson et al. Citation1994) estimates these emissions for various portions of the well-to-wheels portion of fossil-fuel use, and there is a growing body of life cycle studies relevant to the OSR (Brandt Citation2012a, Citation2012b; Charpentier, Bergerson, and MacLean Citation2009; McKellar et al. Citation2009; Sleep et al. Citation2018). Most of these analyses show that GHG emissions are dominated by the tank-to-wheels portion of the process as opposed to the well-to-tank portion. McKellar et al. (Citation2009) found that OSR extraction and upgrading yielded ~30% more GHG emissions compared to conventional oil operations.
Given the reliance on modeling emphasized in the CR, obtaining more accurate real-world emissions in the OSR should be given higher priority.
Multi-stakeholder programs must communicate—Mr. Samuel L. Altshuler
The framework under which industry, agency, and the public established the OSM Program is similar to several environmental programs conducted in the US, such as the Geysers Air Monitoring Program (GAMP) (Altshuler and Arcado Citation1989) which was formed under the guidance a MOU with representatives of industry, public agencies, and the concerned public on the steering committee. This is similar to the OSM Program as described above, but it appears to have been more useful to the entire range of stakeholders. Common to such programs is mixed sponsorship among government and industry and a steering committee of stakeholders to plan, organize, manage, review, and communicate the results of the monitoring or environmental studies. Representatives from public agencies usually manage the programs, solicit and disperse funds to researchers and consultants based on knowledge-specific requests for proposal and competitive evaluations, and distribute results in a timely manner. At the end of the day, both industry and the public at large benefit from collaboration and cost sharing with others rather than conducting their own studies. A three-legged (industry, agency, and public) consortium should be considered for optimum collaboration of all interested parties.
Examples are cited of different researchers “working in a vacuum” and unaware of others’ activities. An example was described during an aircraft air dispersion study when the researchers conducting the air studies were unaware of a massive upset in emissions at ground level. Examples are cited where it took 5 years to share data among researchers and for reports to be issued. Accurate emission inventories are critical to modeling studies.
This Discussion highlights the role of fugitive dust and its PACs content, especially for petcoke. Windblown dust emissions are typically dominated by coarse particles with aerodynamic diameters exceeding 2.5 µm (Watson, Chow, and Pace Citation2000). Many of these large particles deposit in the upper airways of the human respiratory system rather than penetrating deeper into the lung (Miller et al. Citation1979). PACs exposure from these dust sources is likely most important relative to ingestion and dermal contact as opposed to human inhalation.
With respect to the proverbial question of which is more important, the journey or the destination, it seems apparent that the OSM Program may continue, perhaps expanding for the life of OSR production, thus being a continuous journey with no destination or end in sight. If members of the concerned public are involved in the steering committee(s) and are allowed to express their concerns during the design, review, and final report preparation, that process will improve the credibility and acceptance of the final reports, demonstrating that the journey is more important than the destination.
While a number of complementary, complimentary, supplementary, and deficiency comments have been made regarding this CR, it still represents a substantial effort and can be a useful starting point for future review efforts.
Supplemental Material
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Supplemental data for this paper can be accessed on the publisher’s website.
Additional information
Notes on contributors
Samuel L. Altshuler
Samuel L. Altshuler is an Air Quality Consultant and current Chair of the Critical Review Committee. He had an active role in developing The Geysers Air Monitoring Program (GAMP) in the early 1980s.
Jason M.E. Ahad
Jason M. E. Ahad is a Research Scientist at the Geological Survey of Canada, Natural Resources Canada, Québec, QC
Judith C. Chow
Judith C. Chow is a Research Professor at the Desert Research Institute, past Chair of the Critical Review Committee, and author of the 1995 Critical Review.
Calvin Duane
Calvin Duane is Environment Manager for Canadian Natural Resources Limited in Calgary, Alberta.
Monique Dubé
Monique Dubé is Executive Director of the Integrated Environmental Analytics & Prediction Branch in the Environmental Monitoring and Science Division of Alberta Environment and Parks and is the Science Co-lead of the OSM.
Allan H. Legge
Allan H. Legge is Principal for Biosphere Solutions and has over 45 years of research experience addressing the effects of air quality on forest and agricultural ecosystems, with an emphasis on boreal forests. He has been involved in research on Alberta’s oil sands since 1975.
Kevin E. Percy
Kevin E. Percy is Executive Director, Atlantic Forest Research Collaborative, University of New Brunswick and was Lead Scientist and Executive Director of the Wood Buffalo Environmental Association (WBEA).
Eric D. Stevenson
Eric D. Stevenson is Director of Meteorology and Measurement at the Bay Area Air Quality Management District and vice-Chair of the Critical Review Committee.
John G. Watson
John G. Watson is a Research Professor at the Desert Research Institute, past Chair of the Critical Review Committee, and author of the 2002 Critical Review.
Related Research Data
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