November 1, 2004

Stronger regulatory process advised to govern fresh water subsurface injection

Final recommendations from a provincial stakeholder committee reviewing the use of fresh water for underground injection in Alberta are more specific and focused than the preliminary recommendations released for public review last spring (ELW May 3, 2004). Its proposals to Environment Minister Lorne Taylor include strengthening the regulatory process for assessing applications for such uses; reviewing existing water licences for these purposes; improving provincial groundwater information; and investing in research for alternative enhanced recovery technologies.

The Advisory Committee on Water Use Practice and Policy was established to examine the use of water for underground injection, including the enhanced recovery of oil (oilfield injection). The review was launched in response to concerns raised during the public consultations for the development of Alberta's Water for Life strategy.

The main concern is that underground injection may remove water from the active water cycle. Recognizing that water used for this purpose is removed from a specific watershed, the committee focused on policy and process changes aimed at achieving conservation. It has called for a measured approach to reducing the use of fresh, or non-saline, water for underground injection. Such an approach, says its report, should place the highest priority on areas where water scarcity is, or is likely to become, a concern to other water users or to environmental sustainability.

The committee's recommended actions fall into two broad categories: measures to achieve significant reductions or elimination; and more general initiatives to improve water conservation.

To reduce or eliminate the use of non-saline water for underground injection, says the report, a new province-wide regulatory process should be developed and implemented to guide decisions on a case-by-case basis. This new process must place limits on the use of non-saline water resources, with changes including:

*extension of the current process to apply to both surface water and groundwater and to forested areas as well as the settled area of the province;

*development of a "decision tree" - incorporating clear technical, environmental, economic and social criteria - to guide applicants and determine the most stringent requirements and highest urgency for conservation for potentially water-short areas where other users may need non-saline water; and

*determination of priority locations within watersheds where all reasonable efforts should be made to reduce or eliminate underground injection of non-saline water.

The committee further proposes that economic instruments be evaluated to support reductions in the use of non-saline water for underground injection. Its report also calls for a review of both term and permanent licences under Alberta's Water Act.

The new regulatory process, it says, should be applied to term licence renewals to reduce both water allocations granted and the amount of non-saline water actually being used. This envisions the replacement of non-saline with saline water or alternate technologies.) Using the decision tree, permanent licences which allow underground injection of non-saline water should be reviewed to find any practical opportunities for reduction or elimination, especially in high-priority areas.

The committee believes that there are significant opportunities to reduce and eliminate underground injection of non-saline water if the new regulatory process is implemented immediately. One prerequisite, however, is the establishment of targets related to underground injection as part of the provincial water conservation plan. The committee proposes setting initial targets within the next three years, with re-evaluation to follow at regular intervals.

Water resource information should be expanded and improved, adds the committee. Specific initiatives should include:

*increasing the coverage and detail of the provincial groundwater inventory, focusing on priority areas;

*developing a more detailed water use reporting system and public information system; and

*investing in joint government-industry research to support the implementation of new technologies to reduce the volumes of non-saline water used for underground injection.

The report may be viewed on the Water For Life Web site, www.waterforlife.gov.ab.ca.

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