Part 1: The Liability Management Context
by Lexa Ward and Rebecca Kauffman
Since the first oil sands mine application was submitted in 1960, operations in Alberta’s Athabasca region have only grown, with eight oil sands mines in operation in 2025 and covering approximately 500 km2.[1]Alongside growth of the oil sands mining industry, came growth in the fluid tailings waste area, used to contain the byproducts of the mining process. The total oil sands fluid tailings area increased by 7,833% between 1974 and 2020 (growing to cover from 1.5km2 up to120km2).[2]
“Tailings” is defined in the Oil Sands Mining Rules[3] as: “a by-product of the bitumen extraction process including water and sands, fines or residual bitumen or other hydrocarbons or any combination of those things” (s.1(z.2)).[4] The physical composition of tailings can include lead, mercury, arsenic, selenium, naphthenic acids, and polycyclic aromatic hydrocarbons (PAHs) – just to name a few – all of which can be harmful to the environment if they escape containment or are not managed and reclaimed effectively.[5]
While neither the governing Oil Sands Conservation Act (OSCA) nor Rules provide a definition for “tailings ponds,” they are best understood as reservoirs for liquid tailings. They have been described as “immense, open air reservoirs” for tailings.[6] Once the solid constituents of the tailings settle out from the liquid, then ideally the water can be recycled for industrial uses.[7] Whether this recycling and reclamation is feasible and effective, however, remains mostly theoretical or requiring further testing.[8] The size of the tailings ponds can reach up to 30km2 and 7.9km long, with a fluid depth up to 27m.[9] As such, their impact on the landscape, and how this affects their eventual closure and necessary reclamation must be considered in the law governing their management. The ongoing sprawl of tailings ponds is problematic, as it removes valuable features from the ecosystem, such as peatlands and forests, and creates hazards for wildlife in the area, who may mistake the ponds for safe harbour.[10] Additionally, the damage to the environment and to human health from accidental tailings releases, such as the Imperial Oil Kearl Oil Sands Mine fluid tailings releases in 2022 and 2023 can be significant.[11]
One major management issue asks, what should we do with all the waste material? In May 2024, the Government of Alberta formed the Oil Sands Mine Water Steering Committee, to guide the future of management for oil sands mine water — including tailings ponds.[12] The Committee released its first five recommendations on June 12th, 2025.[13] In response to the release of these recommendations, the ELC is releasing a series of blog posts delving deeper into some of the issues with the management of tailings ponds and oil sands mine water.
In this first blog, we consider the issue of managing liabilities stemming from tailings ponds and issues with the current framework for management and reclamation.
What is reclamation?
Once a mine closes, the Lower Athabasca Region: Tailings Management Framework for the Mineable Athabasca Oil Sands (TMF) states that the site must be “be reclaimed to a resilient and functional boreal forest ecosystem that supports the needs and expectations of current and future Albertans.”[14] The Conservation and Reclamation Regulation, under the Environmental Protection and Enhancement Act (EPEA), states that to be reclaimed, the land must be returned to an ”equivalent land capability.”[15] ”Equivalent land capability” is defined in the Regulation as: ”the ability of the land to support various land uses after conservation and reclamation is similar to the ability that existed prior to an activity being conducted on the land, but that the individual land uses will not necessarily be identical.”[16] The specifics of what form the ”equivalent land capability” will take is left to mine operators to set out in their Conservation and Reclamation and Mine Closure Plan.[17] This open-ended requirement may result in the most critical parts of the ecosystem (like peatlands) not being restored in the landscape.[18]
To facilitate effective reclamation, and beyond just the financial necessities, tailings ponds ought to be managed progressively, rather than leaving it all to the mine’s end of life. On both counts, the current regulatory framework and its implementation fall short. This blog addresses these issues and provides the ELC’s recommendations for better management of these liabilities.
Historical Context: Liability Management Before the Mine Financial Security Program
All mines must have operations approved by the Alberta Energy Regulator (AER) prior to starting work.[19] Today, the liabilities associated with these sites are managed through the Mine Financial Security Program (MFSP).
Prior to the MFSP, the Government of Alberta did collect security for oil sands mines; however, there was no true prescribed formula for the security payments.[20] This resulted in an inconsistent system and there were noted concerns that the security collected was often nowhere near enough to cover reclamation costs.[21] In fact, in 2010, the ELC called for a formal program for the calculation and collection of MFSP to be implemented.[22] This report found that the lack of a formal system for reclamation cost estimation, along with consistent use of inconsistent methods to calculate mine security resulted in inadequate security collected to effectively account for reclamation.[23]
Current Fluid Tailings Management Regulation & Policy
Today, oil sands mine operations must apply and get approval from the AER to operate, under the EPEA.[24] The OSCA states that AER approval is necessary for an oil sands operation or scheme.[25] The operator must also have AER approval for tailings management (TMP).[26] The approved management plan for the mine must be in line with the requirements of Directive 085 (D-085), which is regulation issued pursuant to OSCA.[27] As a regulatory instrument, D-085 incorporates many of the policy objectives and principles set out in the TMF.
In line with the TMF, the goal of D-085 is to minimize the accumulation of fluid tailings by ensuring that fluid tailings are treated progressively and reclaimed throughout the lifetime of a project with all new fluid tailings “ready to reclaim” (RTR)[28] within a maximum of ten years past the end of the mine’s lifespan.[29] Legacy tailings, those that existed prior to January 1, 2015, must be RTR by the end of the mine’s life.[30] A principle of D-085 is to consider the net environmental impact of tailings management.[31] There ought to be an eye to the consequences of oil sands mines and tailings accumulation on the environment, and the net environmental impacts of tailings and their management must be considered in planning an operation’s tailings’ management.[32]
Despite clear expectations, the AER has expressed concerns in TMP approvals that the mine operator will be unable to meet the RTR by ten years post mine life, or meet other goals and outcomes prescribed by the TMF and D-085.[33] For greater detail on the TMP approvals, and the concerns voiced by the AER in their decisions, please see Part 2 of this blog, a case study on Suncor’s Base Plant TMP approval decision. Regardless of these ongoing concerns, the AER granted conditional approvals to each TMP.[34]
In this blog, we consider two primary management options: the fluid tailings accumulation thresholds of D-085 and the TMF; and the MFSP, as prescribed by OSCA and EPEA and guided by Manual-024.[35]
Fluid Tailings Accumulation Thresholds
The main mechanism D-085 uses to manage fluid tailings accumulation is a series of “thresholds.”[36] The volumetric amount of each threshold is set by the AER but the level of response triggered by each threshold remains the same.[37]
Thresholds are based on the mine’s end of life fluid tailings target, which is equivalent to five years (or less) of fluid tailings accumulation for the project.[38] The seriousness of the response increases as each threshold is met, as each threshold represents a heightened risk to the operator’s ability to effectively manage their fluid tailings in line with the TMP, and in turn raises a greater threat to the environment.[39]
Management actions may include the initiation of a management plan to reduce fluid tailings to an appropriate volume, or the AER responding with financial and regulatory tools – including those available under the MFSP.[40] There are three thresholds of fluid tailings volume which raise a level of concern and require a management response.[41]
The first is the profile deviation trigger. This threshold is triggered when the volume of accumulated tailings grows 20% faster than the approved fluid tailings profile.[42] According to the TMF, additional measures should be implemented to manage growth if this trigger is reached.[43]
The second threshold is the total volume trigger which is met when the total volume of fluid tailings accumulated surpasses the approved maximum accumulation volume.[44] This threshold activates a more stringent management approach than the profile deviation trigger.[45]
The final threshold, and the one with the most stringent response, is the total volume limit. This occurs when the total volume accumulated is greater than 140% of the end of life mine target.[46] Reaching, or worse surpassing, this threshold means the environment is being put to an unacceptable level of risk and merits the most serious response.[47]
The Mine Financial Security Program
The MFSP is a regulatory requirement, pursuant to EPEA and its Conservation and Reclamation Regulation, for oil sands mine operators to provide financial security to ensure mine liabilities are managed and the costs of doing so will not be borne by the public.[48] It is meant to account for the liabilities associated with the suspension, abandonment, remediation, and surface reclamation of mines.[49]
There are four “types” of mine financial security that may be collected under the MFSP: i) the base security deposit (BSD); ii) the asset safety factor deposit (ASFD); iii) the operating life deposit (OLD); and iv) the outstanding reclamation deposit (ORD).[50]
The BSD provides immediate funds to the government in the event they must fulfill necessary reclamation work. The example provided in Manual 024 is situations where the mine’s approval holder defaults on their obligations and does not complete reclamation.[51] The amount is set based on the sector and type of operation, and is intended to reflect the complexity and amount of work needed to make the mine site safe.[52] Mines approved prior to the MFSP did pay a financial security deposit; this was retained in place of the prescribed BSD and are generally higher than the MFSP BSD.[53]
The ASFD is essentially a guardrail for cases when the mine’s assets fall below the level of the set liability ratio (3.00).[54] If the asset-to-liability ratio falls below this mark, the mine operator must post sufficient financial security to make up the difference and bring the ratio back to acceptable levels.[55] The ASFD does not seem to have ever been collected upon.[56] In 2020 there was the possibility that operators may have had to pay the ASFD as oil prices crashed.[57] However, the Alberta government temporarily changed the asset calculation formula to be based on revenue, rather than the present value of their oil deposits.[58] This allowed operators to side-step the possibility of owing ASFD security.[59] In light of this, it is a concern whether the ASFD would ever be collected upon, when necessary, if the government can change the goal posts, even temporarily.
The OLD is intended to address the risks that arise as the mine nears its end of life.[60] The mine must post financial security when there are less than 15 years of oil sands deposits left, to ensure that all abandonment, remediation, and surface reclamation costs are fully secured by the time there are six years left in the mine’s life.[61] The OLD is offset by the BSD, where only amounts above what is already held under the BSD are required to be posted under the OLD.[62] For mines with a high BSD, such as Suncor’s Base Plant, this may result in a scenario where the OLD never needs to be collected. However, for mines with a low BSD, such as Suncor’s Fort Hills[63] the OLD may need to be collected sooner rather than later to ensure all costs are covered. Further, there are concerns that by deferring these security payments, the mine may not be as profitable as forecast at this point and may be unable to meet its necessary OLD contributions and therefore be unable to fully account for its necessary reclamation work.[64]
Finally, the ORD is intended to ensure that there are adequate funds for reclamation work at the end of the mine’s life, in case the operator diverges from their AER-approved reclamation plan and defers reclamation work.[65] If the mine does not meet its reclamation goals in the approved timeline, it must furnish additional security.[66] This is meant to incentivize mines to conduct reclamation work immediately and continuously, by making the cost of deferring regulation greater than the cost to act proactively.[67] However, the Auditor General noted it may end up having the opposite effect: the more optimistic an estimated reclamation goal, the higher the likelihood that the mine will fail to meet the goal.[68] Therefore, in some ways the ORD creates a disincentive to plan reclamation in advance, due to concerns that they may end up owing ORD security if they fall short.[69]
The MFSP is intended to keep mine operators accountable for their own mining works, in line with the polluter pays principle.[70] Collecting financial security from mine operators is intended to prevent the public from having to pay the costly project closure costs for these mines, should the operators fail to follow through on their commitments. However, this outlook may be looking at the situation through rose-tinted glasses.
In reality, the AER reported that, as of June 2024, the total financial security held for all mines in Alberta (coal and oil sands) is $1.71 billion.[71] The oil sands alone represent $912.85 million.[72] However, the security held pales in comparison to the estimated liability, which stood at $57.3 billion in June of 2024.[73] While the liability estimate is for both coal and oil mines, it does not negate the fact that the liabilities of oil sands undoubtedly represent a proportion, potentially a large one, of that amount. Of perhaps greater concern is that an internal estimate from the AER in 2018 found that oil sands liabilities alone may be as high as $130 billion.[74] While the AER said the estimate represented the “worst-case scenario,” the fact that the current MFSP securities barely scratch the surface of the official estimated liabilities, let alone worst-case scenario estimates, is enough to raise significant concern.[75]
ELC Recommendations
Although there is no doubt that the management and clean-up of tailings ponds will be a massive and multi-pronged job, there are changes that could be made to improve the liability management for fluid tailings. In fact, we can once again look to the 2010 ELC Report “Seeking the Right Balance: Financial Security for Conservation and Reclamation of Alberta’s Oil Sands Mines” which proposed several recommendations to improve financial security for the reclamation of Alberta’s oil sands mines.[76] This report was published prior to the TMF, D-085, and the MFSP’s creation, and some of the recommendations were implemented as part of these programs. However, a number were left unfulfilled and remain missing elements key to the effective and environmentally conscious management of tailings fluid.
The implementation of these recommendations, while not a solution individually or in and of themselves, each represent a step in the right direction for the diligent management of oil sands tailings.
- Better fulfillment of the “polluter pays” principle – the official liability estimate and the internal liability assessment indicate that the current amount held under the MFSP is not enough to offset existing liabilities.[77] Security costs should be based on the polluter pays principle and account for reclamation work in full. Currently, it looks like the public will end up being on the hook to pay for oil sands mine reclamation if the operator’s work is not effective.[78] As such, the security required from operators by the AER should be sufficient to cover the entire reclamation of the mine site should the operator fail to do so themselves.[79] This full amount should be required up front and not delayed towards the mine‘s end of life.[80] Finally, the security should be based on the costs to reclaim the oil sands mine operation, and not be offset by assets, revenue, or other elements. The security held should be sufficient to cover all necessary reclamation for the mine site.[81]
- Increase in public transparency.[82] Currently, there is very limited access to view historic oil sands mine approvals. Although you can find a record of approvals on the AER Historical Approvals database, any further information on the approvals are paywalled at $10.00 per request. Similarly, while recent applications and decisions are available online in digital databases, finding results can be a challenge, and to effectively use the search may require information (such as application or approval numbers) which the layperson may not know or have access to.[83] These documents should be publicly available and readily accessible to allow for increased transparency and scrutiny. Similarly, to increase public transparency around oil sands fluid tailings management, security payments should only be returned to mine operators following a formal and public review of the reclamation work done.[84] This will not only ensure that the work being conducted is transparent and accessible to the public, it will also help create a stopgap against agency capture, an aspect which transparency and public input helps mitigate against.[85]
- Any concerns expressed by the AER in the TMP approvals, especially regarding the mine meeting its fluid tailings profile or passing the thresholds, should require close oversight and potentially carry higher penalties for non-compliance.
- Accurate mine security payments must be prioritized to minimize risk of public liabilities. The temporary amendment of the ASFD, to avoid operators having to pay an additional security due to changing oil prices, should not occur again. When a security assigned under the MFSP comes due, it ought to be collected upon.
- Finally, RTR timelines, a mine’s end of life, and reclamation work should not be allowed to extend indefinitely from TMP amendments and mining operation extensions without clear demonstrations of progressive reclamation. For an example of this, please see the forthcoming Part 2 of this blog, a case study on Suncor’s Base Plant tailings management. As mine operations expand and extend their lifespan, it follows that their fluid tailings may accumulate, and the tailings area may expand. To mitigate the environmental harms that may ensue from the continued growth and accumulation of fluid tailings, mine operators ought to be required to demonstrate a consistent and high level of progressive reclamation to be approved for mine extensions or mine lifespan modifications.
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[1] Alberta Energy Regulator, State of Fluid Tailings Management for Mineable Oil Sands, 2023 (October 2024) <https://static.aer.ca/prd/documents/reports/State-Fluid-Tailings-Management-Mineable-OilSands.pdf> at xi; Environmental Resources Conservation Board, Decision 60-06; Government of Alberta, “Oil Sands 101” (No Date, accessed 30 July 2025) online: https://www.alberta.ca/oil-sands-101. https://had.aer.ca/link/decision2433; Government of Alberta, “Oil Sands 101” (No Date, accessed 30 July 2025) online: https://www.alberta.ca/oil-sands-101.
[2] Gillian Chow-Fraser and Alienor Rougeot, “50 Years of Sprawling Tailings: Mapping Decades of Destruction by Oil Sands Tailings” (2020) CPAWS Northern Alberta and Environmental Defence Canada at 5 online: https://cpawsnab.org/wp-content/uploads/2023/10/50YearsSprawlingTailings_WEB_ForDistribution.pdf [Chow-Fraser & Rougeot].
[3] Alberta regulations issued pursuant to the Oil Sands Conservation Act, RSA 2000, c O-7 [OSCA].
[4] Oil Sands Conservation Rules, Alta Reg 76/1988 at s.1(z.2) [OSCR].
[5] Chow-Fraser & Rougeot at 25-30.
[6] Chow-Fraser & Rougeot at 9.
[7] Chow-Fraser & Rougeot at 9.
[8] Chow-Fraser & Rougeot at 9.
[9] Chow-Fraser & Rougeot at 9, 11 & 24.
[10] Chow-Fraser and Rougeot at 9.
[11] Alberta Energy Regulator, ”Ongoing Investigations: Imperial Oil Kearl Oil Sands Incidents” (no date, accessed August 14, 2025) online: <https://www.aer.ca/protecting-what-matters/holding-industry-accountable/investigations/ongoing-investigations#:~:text=Latest%20Updates,AER%20on%20February%204%2C%202023>; Brenda Heelan Powell, ”The Next Government Needs to Address Alberta’s Fossil Fuel Liabilities Part 2” (May 25,2023) Environmental Law Centre online: <https://elc.ab.ca/post-library/the-next-government-needs-to-address-albertas-fossil-fuel-liabilities-part-2/>.
[12] Government of Alberta, Oil Sands Mine Water Steering Committee (last updated June 12, 2025) online: <https://www.alberta.ca/oil-sands-mine-water-steering-committee>.
[13] Government of Alberta, Oil Sands Mine Water Steering Committee Recommendations (June 12, 2025) online: <https://www.alberta.ca/oil-sands-mine-water-steering-committee-recommendations>.
[14] Government of Alberta, Lower Athabasca Region: Tailings Management Framework for the Mineable Athabasca Oil Sands (2015) at 7 online: https://open.alberta.ca/publications/9781460121740#detailed [TMF].
[15] Conservation and Reclamation Regulation, Alta Reg 115/1993 at s.2 [CRR]; Environmental Protection and Enhancement Act, RSA 2000, C E-12 [EPEA].
[16] CRR at s.1(e) (emphasis my own).
[17] Chow-Fraser and Rougeot at 36.
[18] Chow-Fraser and Rougeot at 36.
[19] OSCA at s 10(1).
[20] Martin Olszynski, Andrew Leach, Drew Yewchuk, “Not Fit for Purpose: Alberta’s Mine Financial Security Program” (2023) 16:36 University of Calgary School of Public Policy Research Paper at 6 [Olszynski et al.]; Dean Watt, “Seeking the Right Balance: Financial Security for Conservation and Reclamation of Alberta’s Oil Sands Mines” (2010) Environmental Law Centre at 14-16 online: https://elc.ab.ca/Content_Files/Files/Seekingtherightbalancewebcopydl.pdf [Watt]. Note that as per Watt, under the former Land Surface Conservation and Reclamation Act (not in force), there was a set scheme base for security, however the Minister could require an additional security based on production (at 14). Therefore, it was possible for the actual security to vary across projects.
[21] Olszynski et al. at 6; Watt at 14-15.
[22] Watt at 88.
[23] Watt at 14-17.
[24] Activities Designation Regulation, Alta Reg 276/2003 at s.2(1)(j); Alberta Energy Regulator, ”Environmental Protection and Enforcement Act” (No Date, accessed August 10, 2025) online: <https://www.aer.ca/applications-and-notices/application-processes/application-legislation/environmental-protection-and-enhancement-act>; EPEA at s 60 & 61.
[25] OSCA at s 10(1).
[26] OSCR at s 24.1.
[27] Alberta Energy Regulator, Directive 085: Fluid Tailings Management for Oil Sands Mining Projects (2022) <https://static.aer.ca/prd/documents/directives/Directive085.pdf> [D-085]; OSCR at s 24.1.
[28] ”Ready to reclaim is defined in D-085 as ”the state achieved when fluid tailings have been processed through an accepted technology, have been placed in their final landscape position, and have achieved necessary performance criteria (at 38).
[29]D-085 at 3.
[30] D-085 at 5 & 37.
[31] D-085 at 7.
[32] D-085 at 7.
[33] Alberta Energy Regulator, Decision 20190225A: Fort Hills Energy Corporation; Application for Fort Hills Tailings Management Plan (February 25, 2019) at paras 15, 196 <https://static.aer.ca/prd/documents/decisions/2019/20190225A.pdf> [Fort Hills]; Alberta Energy Regulator, Decision 20180716A: Imperial Oil Resources Limited: Application for Kearl Mine’s Tailings Management Plan (July 16, 2018)
at paras 30-31, 50, 185 <https://static.aer.ca/prd/documents/decisions/2018/20180716A.pdf> [Kearl]; Alberta Energy Regulator, Decision 20171025A: Suncor Energy Inc., Applications for Millennium Operational Amendment and Base Plant Tailings Management Plan (October 25, 2017) at paras 64-67, 422 <https://static.aer.ca/prd/documents/decisions/2017/20171025A.pdf> [Base Plant].
[34] Fort Hills at para 1; Kearl at para 1; Base Plant at para 1.
[35] Alberta Energy Regulator, Manual 024: Guide to the Mine Financial Security Program (2025) [Manual 024]; EPEA; LARP; OSCA.
[36] D-085 at 6; TMF at 16.
[37] D-085 at 6 & 9; TMF at 24.
[38] D-085 at 12.
[39] D-085 at 33-34 (Table 1); TMF at 15-17.
[40] D-085 at 5.
[41] D-085 at 33 (Table 1).
[42] Defined in D-085 as “the forecasted accumulation and reduction of fluid tailings volumes for each year to end of mine life” (at 37).
[43] D-085 at 33 (Table 1); TMF at 24.
[44] D-085 at 34 (Table 1); TMF at 25.
[45] D-085 at 34 (Table 1); TMF at 25.
[46] D-085 at 34 (Table 1); TMF at 25.
[47] D-085 at 34 (Table 1); TMF at 25.
[48] Manual 024 at v & 1; CRR at Division 2.
[49] Manual 024 at vii.
[50] Manual 024 at 19 – 27.
[51] Manual 024 at 19.
[52] Manual 024 at 19.
[53] Manual 024 at 19; Olszynski et al. at 12.
[54] Manual 024 at 20.
[55] Manual 024 at 20.
[56] Sharon J. Riley, “Alberta ‘Undermining’ System Meant to Ensure Oilsands Companies Pay for Cleanup, Critics Say” (May 18, 2021) The Narwhal online: https://thenarwhal.ca/alberta-oilsands-security-deposit-changes-critics/ [Riley]
[57] Riley.
[58] Riley.
[59] Riley.
[60] Manual 024 at 21.
[61] Manual 024 at 21.
[62] Manual 024 at 21.
[63] $38, 958, 605. Alberta Energy Regulator, Annual Mine Financial Security Program Submissions – 2024 Submissions for 2023 Reporting Year (2024) online: https://static.aer.ca/prd/documents/liability/AnnualMFSPSubmissions.pdf at 1 [AER MFSP Submissions 2024]; Olszynski et al. at 6 (Table 1).
[64] Olszynski et al. at 16.
[65] Manual 024 at 23-24.
[66] Manual 024 at 23-24.
[67] Manual 024 at 24.
[68] Auditor General of Alberta, ”Environment and Parks and the Alberta Energy Regulator — Systems to Ensure Sufficient Financial Security for Land Disturbances from Mining” (2015) Report of the Auditor General of Alberta at 30 <https://www.oag.ab.ca/wp-content/uploads/2020/05/EP_PA_July2015_AER_Systems_Ensure_Fin_Security_Land_Disturb.pdf> [Auditor General of Alberta]; Olszynski et al.at 14.
[69] Auditor General of Alberta at 30; Olszynski et al. at 14.
[70] The ELC, in “Seeking the Right Balance”, defines the polluter pays principle in the oil sands reclamation context as: “…either specific companies should be responsible for impacts on the land that results from their activities or the oil sands industry in general should be so responsible.” See Watt at 8. The importance of a polluter’s responsibility to pay for the results of their own actions is affirmed in the Purposes section of the EPEA at s 2(i).
[71]Alberta Energy Regulator, Mine Financial Security Program – Security and Liability (2024) online: https://static.aer.ca/prd/documents/liability/MFSP_Liability.pdf [AER MFSP Security & Liability].
[72] AER MFSP Submissions 2024 at 1.
[73] AER MFSP Security & Liability.
[74] Riley.
[75] Olszynski et al. at 18; Riley.
[76] Watt.
[77] AER MFSP Security & Liability; Chow-Fraser & Rougeot at 41; Olszynski et al.at 18-19; Riley.
[78] Riley; Watt at 91.
[79] Chow-Fraser and Rougeot at 44; Watt at 89-90.
[80] Chow-Fraser and Rougeot at 44; Watt at 89-90.
[81] Watt at 91.
[82] Watt at 87.
[83] Alberta Energy Regulator, Integrated Application Registry: Application Query (no date) online: <https://dds.aer.ca/iar_query/FindApplications.aspx>; Alberta Energy Regulator, Publication of Decision (no date) online: <https://webapps.aer.ca/Pod>.
[84] Watt at 91.
[85] Watt at 88 & 91.