ConocoPhillips S14A-004 and S14L1-003
Submitted Prior to June 16th, 2014
Paul Dixon, Executive Director
Sahtu Land and Water Board
Fax to: 867-598-2325
Email to: [email protected]
Dear Mr. Dixon:
ConocoPhillips Canada (CPC) has applied to the Sahtu Land and Water Board (SLWB) for a land use
permit and a water licence to drill ten (10) oil exploration wells using horizontal hydraulic fracturing
(fracking) as the main drilling method. This application is a clear indication of the intent to significantly
increase the level and extent of fracking activities in the Sahtu region over the next few years. Although
a previous CPC fracking project was permitted by the SLWB without an environmental assessment, the
size and scope of this current application makes an environmental assessment essential, particularly given
increasing public and scientific awareness and concern over the risks associated with horizontal hydraulic
Just recently, a federally funded study on fracking released by the Council of Canadian Academies raised
serious concerns about the impacts of fracking on surface water, groundwater, and greenhouse gas
emissions.1 Although the study focused on shale gas drilling, its findings apply to shale oil fracking as
well given that large volumes of water and chemical contaminants are required and that gas release is a
by-product of both. The study noted that there is inadequate evidence to predict what will happen to
contaminated fracking fluids left underground and that current technology cannot fully prevent gas from
leaking upward into groundwater or to the surface during or following fracking operations. The study
highlighted the risk of fracking fluids to surface water through improper handling and/or disposal.
Northerners have been discussing similar issues as those raised by the Council of Canadian Academies.
Growing public concern about fracking throughout the NWT over the past year culminated in a petition to
the NWT Legislative Assembly in March 2014, which was signed by 790 people from throughout the
Mackenzie Valley, including the Sahtu communities. This petition called for the GNWT to refer any land
or water use applications involving horizontal hydraulic fracturing to full environmental assessment, due
to the following concerns.
Horizontal hydraulic fracturing (fracking) is new to the NWT and is clearly controversial – it is
banned or under moratorium in many places in the world.
Fracking permanently contaminates very large volumes of fresh water. This does not match the
objectives of the NWT Water Stewardship Strategy.
In other places, fracking brought lots of outside workers, alcohol, illegal drugs and crime with it. We
don’t have a plan to deal with an increase in these social issues.
Fracking will require transporting toxic fracking chemicals and polluted waste water through our
communities, along our highways and on the Mackenzie River. NWT workers will also be exposed to
these hazardous substances.
Sahtú elders tell us that water flows through the deep geology of the Sahtú and that different areas are
connected in ways that science has not documented. We also know that underground networks of
fractured rock and wells will eventually leak.
We have to look at the bigger picture. Our land, water, wildlife, cultures, communities and economies
are already under stress and will suffer from the additional stress of fracking and associated
development without proper assessment and planning.
Extracting oil and gas increases greenhouse gas emissions and makes global climate change happen
faster. Greenhouse gas emissions come both directly from the fracking operation and from burning
the oil and gas that is extracted.
The decision to allow fracking in the NWT without an environmental assessment has created severe
social tension in the Sahtu and across the NWT.
The CPC application raises particular concerns:
 CPC is proposing to increase the volume of water required for each well (from its previous
permit) and expects to draw this water from nearby lakes. This water will be permanently
contaminated with chemicals and is therefore lost as a freshwater resource.
 CPC is proposing a significant increase in the number of fracking stages per well, which will
means that more toxic fracking chemicals are required, raising issues about shipping, handling,
disposal, and long term underground monitoring of these contaminants.
 More fracking stages increases the risk of destabilizing underground geological formations and
opening up pathways for the leakage of gas and contaminated water to groundwater and to the
 In the traditional knowledge (TK) study documents submitted with the application, it is noted that
elders and harvesters know very little about the proposed fracking operations. How can they
properly assess impacts on their traditional values and inherent rights without a full disclosure
and discussion of the nature and extent of fracking operations proposed in the region?
 CPC may assume that its previous permit gives it the social licence to expand this activity, but
recent and growing opposition to fracking as indicated in the NWT petition and petitions from
citizens in Tulita and other Sahtu communities clearly show that this company does not have a
social licence to proceed.
 The documents submitted with the CPC application are enormous: almost 200 megabytes of data
and information, much of which cannot be easily downloaded and certainly cannot be printed or
reviewed by ordinary citizens. In fact, it is completely unreasonable to expect that the public or
the agencies representing public interests can review these documents in detail and conclude by
June 16th whether this proposed project will or will not have significant impacts on the
environment. This is especially true given the Council of Canadian Academies report that very
little is known or can be assumed about the impacts of fracking operations on surface water,
groundwater, and gas emissions.
Finally, the Government of the NWT, which is the body now responsible for regulating oil and gas
activities, including horizontal hydraulic fracturing, has only just begun the process of establishing
regulations for this form of exploration and development technology. In effect, our NWT regulatory
framework is currently inadequate to properly manage fracking operations.
For all of these reasons, the undersigned strongly demand that the Sahtu Land and Water Board refer
ConocoPhillips’ application to an environmental assessment with full public hearings. An environmental
assessment is currently the only means by which the public and public agencies can properly review the
ConocoPhillips application and determine the impacts of this project on the people and environment of
the NWT.
Yours truly,
Contact (phone or email)