The Pembina Institute and West Coast Environmental Law are pleased that the Ministry of Energy Mines and Petroleum Resources will establish a new regulation regulating the environmental impacts of oil and gas activities in British Columbia. That being said, we have serious concerns with the Regulation as proposed. We offer the following comments with regard to the November 4, 2009 draft Environmental Protection and Management Regulation under the Oil and Gas Activities Act (the “Regulation”).
These comments are divided into three sections – general comments pertaining to the approach taken by the Oil and Gas Activities Act, specific issues raised in the consultation draft Environmental Protection and Management Regulation, and some section based comments. In addition to these comments, we have reviewed the submission provided by the Canadian Parks and Wilderness Society on this regulation and endorse all of the comments made in their letter to Mike Lambert dated 4 December 2009.