A/HRC/45/12/Add.3
Para 91, 5th sentence, comments:
The report referenced (footnote #147) is focused on the thousands of conventional oil and
gas wells, and not oil sands facilities. Oil sands projects are designed to operate over decades
and almost all are still active sites. Restoration and remediation work has begun in the oil
sands, but the reclaimed area is still small since most is still in active use. Oil sands
development is subject to environmental standards that are among the most stringent in the
world. The Government of Alberta requires that companies remediate and reclaim 100
percent of the land after the oil sands have been extracted. Reclamation means that land is
returned to a self-sustaining ecosystem with local vegetation and wildlife. It is recommended
that “including at the oil sands in Alberta” is changed to “including conventional oil and
natural gas wells in Alberta”.
Comments from the province of Alberta
General considerations:
There is a need to ensure the report is clear on which government the author is referring to
throughout the report.
The term “tar sands” and “oil sands” are used inconsistently. The Government of Alberta’s
preferred term is “oil sands.
There are many First Nations, such as the Fort McKay First Nation, that are supportive of
pipeline projects, including the TransMountain Expansion project.
There are instances where statements in the report are not substantiated with reference, and
allegations that are not proven with facts. For example, allegations are made (paragraphs 78
and 92) regarding the disappearance of an Indigenous woman, inferring that the
disappearance is related to concerns she raised of exposure to toxic pollution from oil sands
operations. These allegations are made without documentation or proof.
Para 10, comments:
Drinking water on federal lands including reservations is the sole responsibility of the Federal
Government and drinking water off-reserve is the responsibility of the provincial
government, unless other arrangements have been made. Safe Drinking Water for First
Nations Act (2013) published by Indigenous Services of Canada https://www.sacisc.gc.ca/eng/1330528512623/1533729830801
Para 26, 4th sentence, comments:
A reference to the Government of Alberta would provide more context, as the federal
government is not the only entity working on this issue. For example, through Oil Sands
Community Odour Monitoring Program; a voluntary program set up by the Wood Buffalo
Environmental Association to better understand ambient air quality in the region. Additional
examples
include:
https://www.aer.ca/protecting-what-matters/reporting-on-ourprogress/improving-air-quality-and-odours-in-fort-mckay/status-of-recommendations.html
Para 29, last sentence, comments:
A distinction between oil sands operations and metal mines is required. It needs to be clear
that these figures are specific to metal mines (based on reference 33). Because the paragraph
refers to Alberta tailings ponds at the beginning, this could be misinterpreted as oil sands
mines. It is implied that scientifically confirmed numbers from metal mines (which are
permitted to release treated effluent to the environment) may indicate contamination of
surface water by oil sands mines (which are not permitted).
Para 39, comments:
Alberta Health has been working with the communities for years to develop an appropriate
approach to community health status assessment that incorporates the considerations of all
parties within the communities and continues to work with the communities to address their
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