As Alberta’s energy regulator, it’s our job to make sure that energy development occurs in an environmentally responsible manner. One way we can do this is by adopting a cumulative effects management approach.
What are cumulative effects?
Cumulative effects can be defined differently depending on who you talk to, but to the AER, they are the total environmental changes caused by energy development activities in combination with other past, present, and future human actions. The impacts of each activity may be insignificant by themselves, but when they’re combined with the impacts from other activities, the risk to the environment can be great.
The regulatory system that we have in place today was designed during a different period of energy development and tends to look more at each development activity in isolation, rather than looking at all of the activities occurring in the area and their impacts on water, land, biodiversity, and air quality. However, with the amount of energy development now occurring across the province, we need to shift our thinking and adopt a cumulative effects management approach to ensure that when we’re making decisions on energy development, we’re looking at the bigger picture, seeing the context of all activities that impact the environment.
Adopting a cumulative effects management approach is no easy feat and will take some time to get right. We’ll need to work closely with other government agencies that are responsible for setting policy and also responsible for environmental protection. It also requires proper planning and testing of different approaches. That’s why, over the next year, we will undertake a number of initiatives—outlined here—to start building a cumulative effects management approach.
As a first step, we developed a cumulative effects management blueprint that maps out how we can make decisions that better consider cumulative effects on the environment, and how the AER can work with our partners to implement the approach. We tested the approach on a small scale last year in central Alberta. We received water allocation requests for five energy development projects and assessed the applications against interim water-use thresholds that the government had set based on flow rates in the rivers where the projects were proposed. This exercise allowed us to better understand how such requests cumulatively affected water availability, which in turn allowed us to make a more informed decision about each project application. We will continue to refine the approach with our partners as government develops additional thresholds for air, water, land, and biodiversity.
Cumulative effects need to be considered at every stage of the regulatory process—from application, to decision, through to project closure—and we need a regulatory approach that looks at energy development within an entire area, including subsurface reserves, as opposed to project-by-project. As a result, we will be piloting an area-based regulatory approach that will give us a better understanding of the impacts of energy development and will consider the environment relative to government thresholds.
Last year, the AER began testing a single, integrated application approach that allows energy companies to submit one application for all activities of an energy development project, rather than submitting separate applications for each activity. This process allows us to see the full scope of the project and better assess cumulative effects while being far more efficient and effective as a regulator.
Cumulative effects management also means ensuring industry is accountable for its actions. As a result, we’re developing environmental performance metrics to help us assess industry’s actions against thresholds established by government. Measuring performance will also give us the insight we need to refine our regulatory approach to ensure we’re successfully managing cumulative effects. Linking industry performance with environmental performance is the key to success, and they need to work in tandem to achieve positive results.