Open letter to Debra Wortley, Energy, Mines and Resources’ rights and royalties officer, re fall 2007 Yukon oil and gas request for postings:
The Yukon Conservation Society strongly recommends that the Yukon government oil and gas branch cancel the 2007 fall request for posting.
This is because:
• The area consists of ecologically sensitive wetlands.
• There is no formal process to address cumulative impacts.
• There is no regional land use planning (but one will be coming out shortly).
• There appears to be a policy conflict within the Yukon government for dealing with climate change.
• And there is the possibility of road access to the Peel Plateau wetland region, thus ensuring future industrial development and degradation of the Peel Plateau wetlands.
All three requested areas are on the Peel Plateau wetlands.
YCS recognizes that this is a request for postings, and does not constitute surface disturbance.
But what is the point of proceeding with the next stage in the process (the call for bids) if all it means is the start of a process that will entail surface disturbance?
The conservation society is very concerned over the government depending on best management practices and mitigation measures to ensure the protection of northern Yukon wetland complexes.
Best management practices and mitigation measures can only reduce the amount of harm being done to an area, they cannot halt it.
Yukon wetlands are an ecological treasure, and the Peel Plateau wetlands deserve special consideration prior to being opened for development.
The best way to protect northern Yukon wetland complexes is through land-use planning prior to any oil and gas development.
Yukon Environmental and Socio-economic Assessment Act evaluations do not require an analysis of cumulative effects such as the effects from potential projects.
In fact, those assessments only consider proposed activities that already have a draft project proposal, project description and/or regulatory application.
YESAA essentially looks at multiple impacts from existing projects, and does not look at cumulative effects on an area from potential projects.
Thus a report such as the Fekete Associates Inc and Vector Research — 2005, North Yukon Conceptual Oil and Gas Development Scenario and Local Benefits Assessment (prepared for north Yukon oil and gas working group) is not included in YESAA cumulative effects assessment.
Awarding of oil and gas rights in an area could mean full-blown future industrial development, complete with pipelines and access roads, but no cumulative effects assessment is done prior to this development. It is assumed that assessment is only done after many projects have either been done or are planning on being done.
In other words, it is done when it is too late to protect ecological values.
Of course, the argument goes that with oil and gas exploration there is the possibility that nothing will be found.
But if oil and gas are found, it will be highly unlikely that any level of government will say no to further development even in ecologically sensitive areas.
Until potential cumulative impacts have been adequately evaluated oil and gas development, such as the fall 2007 request for posting, must be halted.
The draft land use plan for the area in and around the Fall 2007 request for posting is anticipated to come out in December of 2008.
Between now and then, only 15 months, is a short time to wait until the planning commission report is released.
If it suggests the area under discussion should be developed for oil and gas, they will still be there.
The reason YCS is requesting the fall 2007 request for posting be cancelled is because the issuance of oil and gas rights following that request will preclude almost any other form of land use.
Continuing with the 2007 request for posting in the Peel Plateau area effectively withdraws any support the Yukon has for regional planning in the area.
In fact, should oil and gas rights be issued in this area, Energy, Mines and Resources’ oil and gas branch will have dictated what the land is to be used for, instead of following the Peel watershed regional plan when it is released.
The ecology and permafrost of in northern Yukon will be damaged due to oil and gas activities, either through direct impacts such as activities like seismic exploration or through indirect impacts due to climate change.
Humans burning fossil fuels cause climate change, and the search for more fossil fuels to burn will cause more climate change, which in turn will impact northern Yukon ecosystems.
The Yukon government is pursuing contradictory policies.
The Yukon government is developing a climate change action plan that will, it is hoped, include reducing greenhouse gas emissions.
At the same time, the Yukon government would appear to be pushing ahead with developing a traditional oil and gas industry in the Yukon.
It cannot be overstated that the burning of fossil fuels, such as oil and gas, cause climate change.
These are the same fossil fuels that the Yukon government is pushing for development through its fall 2007 request for posting.
If the Yukon government truly wanted to protect the ecology and permafrost of northern Yukon they would cancel the fall 2007 request for posting, at least until land use planning is done and the climate change action plan has been released.
The location of these ‘request for postings’ presupposes an access trail, first for getting equipment in (be it for seismic or for well drilling) and then (should anything be discovered) a pipeline to get it out.
This is a classic cumulative impact that is not addressed at any stage.
Instead, it will only be addressed as a stand-alone project.
Logically, it should be addressed at the land use planning stage.
Access to the 2007 request for posting region will either be off the Dempster Highway or south of the Fort McPherson region.
Despite the best of intentions, non-oil and gas users will use these access roads, either legally or illegally.
This will open up the Peel Plateau to more and more developments, either oil and gas related or other.
The oil and gas branch must recognize that by offering the Peel Plateau wetlands area for the fall 2007 request for posting they are essentially inviting an access road.
Why not examine the impacts of what a road would mean, both through its direct construction and through the ‘other’ developments it would entail? The best way to do this would be through a cumulative impacts assessment.
The Yukon Conservation Society thanks you for this opportunity to provide input into the fall 2007 request for posting.
In closing, the society strongly recommends that the Yukon government oil and gas branch cancel the fall 2007 request for posting.
Yukon Conservation Society, Whitehorse