The BC government is heavily promoting fossil fuels, intending to double oil and gas production by 2011. While oil and gas in BC has been concentrated in the Northeast, now the government wants to drill in many other places to get at a type of gas called coalbed methane.
Coalbed methane is gas trapped in coal seams, and it is found wherever there is coal. Plans to develop coalbed methane are popping up all over the province, including places such as Courtenay/Comox, Fernie, Princeton, Hat Creek, Hudson?s Hope, Fernie, and Iskut.
This means that people that have never had to deal with oil and gas development before will now be exposed to it. And, remember that, as with conventional oil and gas, development (or mining), a company does not need your permission to come onto your property to drill, meaning that you could live with one or more well on your property for decades.
Coalbed methane differs from conventional gas development in two key ways. First, wells must be spaced more closely together in order to be commercially viable, leading to more intense impacts on the landscape in the form of more wells, more pipelines, more roads, and more traffic.
Second, to get methane out of coal seams a company will have to pump out potentially massive quantities of the water to release the gas. This ?produced water? can be salty and may contain heavy metals, meaning that there are problems in what to do with it all. US courts have declared that coalbed methane produced water is a ?pollutant? under the US Clean Water Act.
As a result, we have seen a steady increase in the level of concern about coalbed methane development in BC. There are two main issues:
1. The BC government?s failure to develop a clear regulatory regime to respond to the unique threats posed by coalbed methane.
Most existing coalbed methane projects in BC operate as experimental projects, and are subject to draft guidelines which have loopholes. For example, the current guidelines indicate that coalbed methane wells can be spaced ?to any density,? meaning that spacing as low as one per 40 or one per 80 acres could occur. While the Minister has verbally committed to not allow well spacing any closer than one per 160 acres on private land, no such commitment has been made for Crown land, which includes the traditional territories of First Nations across BC.
Another serious threat to BC emerging from plans for coalbed methane development is the issue of produced water disposal. While re-injection of this substance is the best practice, at least one experimental project is already disposing its produced water into streams. Post-treatment data for this water indicates that in its pure form it is sometimes lethal to rainbow trout.
The BC government is preparing a Code of Practice for Coalbed Methane Produced Water. Given the huge impacts that produced water from coalbed methane could have on BC?s waterways, West Coast Environmental Law developed detailed input into this Code of Practice that can be found at http://www.wcel.org/wcelpub/2004/14173.pdf. If the government gets this Code wrong, making it too vague or unenforceable, BC could be facing severe impacts from this industry that have occurred in places like Colorado or Wyoming.
2. The BC government?s failure to respond to the genuine concerns voiced by BC communities.
The communities that have received the best information about coalbed methane are the ones that have organized themselves. This should not be the case. The BC government should be providing the best information it can to all communities ? not just those who have rallied together in the strongest manner. The BC government needs to acknowledge that there are many unanswered questions about the potential impacts of coalbed methane on our lands, our waterways, and our water supplies. One study conducted for the government recommended that at least three years of baseline water quality data be gathered before any development was to occur. Nonetheless, the government sought to lease the land last August.
Coalbed methane development is new, largely untested, and is not being commercially produced in BC at this time. It has taken decades of bad experience in the US to begin to be remedied through the development of best management practices. BC must begin by regulating coalbed methane produced water in the most rigorous manner possible, and fully addressing the real concerns of British Columbians, who are trying to make sense of this new industry before it fundamentally alters their lives.
Meanwhile, BC continues to pass up countless opportunities for renewable energy or energy efficiency in its shortsighted focus on fossil fuels. It will take a major shift in attitude to not only do coalbed methane right, but to recognize that fossil fuels themselves are not the answer.
A Recipe for Concern: Aboriginal Rights, Cumulative Impact Assessment, and Record Oil and Gas Drilling
West Coast Environmental Law
Recently, oil and gas activity has generated dramatically more revenue for the BC coffers than forestry, and this trend is expected to continue. In April of this year, the Petroleum Services Association of Canada forecast record drilling activity ? they anticipate a total of 18,300 wells in Canada, many of which are being drilled in BC. Increased activity will mean an increase in the number of seismic lines and roads being built in pristine areas; an increase in drilling rigs and related equipment that will be transported onto the land; an increase in the amount of toxic waste that will need to be disposed of; and an increase in the dangerous air emissions that could have an impact on people who live near these activities.
Yet despite these dramatic increases in oil and gas development, very little of this activity will be subjected to formal environmental assessments. The regulatory regime for oil and gas includes environmental permitting requirements, but these requirements are not a substitute for environmental assessment. The federal environmental assessment law usually only applies where a pipeline is being constructed, and the provincial law does not capture oil and gas drilling and related activities. This gap is becoming of increasing concern as oil and gas activity increases, as there are no legal requirements for cumulative impact assessments of these developments on ecosystems, wildlife, and communities.
West Coast joins with Treaty 8 in Fort St John
These issues were the subject of a recent forum organized by West Coast Environmental Law and the Treaty 8 Tribal Association. Treaty 8 traditional territory covers much of the northeast Peace region in BC, where most of the oil and gas activity happens in the province. In June 2003, Stuart Rush, a senior aboriginal lawyer in Vancouver, and Matt Carlson, a cumulative effects expert from the University of Alberta, joined West Coast staff lawyer Karen Campbell for a panel discussion with Treaty 8 and members of the public in Fort St. John.
Matt Carlson shared the results of a recent study that simulated the cumulative impacts of oil and gas, forestry, agriculture and human settlement in parts of northern Alberta. The study concluded that the combined impacts of all of these activities would have a tremendous impact on the study area: the industrial footprint is expected to quadruple over the next 20 to 30 years. A key indicator used in the study was caribou habitat, which the study predicted would shrink to one-sixth of its former size, from 0.4 percent of the land base to 0.06 percent of the land base in 20 years? time. The study can be found on the internet at http://www.consecol.org/vol7/iss1/art8/.
Stuart Rush spoke about recent legal developments that strengthen the requirement for meaningful consultation with aboriginal peoples where proposed resource development is to occur on lands where aboriginal rights and title are at issue. He emphasized two recent decisions of the BC Court of Appeal, successfully won by the Haida Nation, which elaborated on the nature of the legal requirement for consultation, and confirmed that meaningful accommodation of First Nation interests must be achieved prior to any resource development occurring.
We were pleased to be able to host this forum with the Treaty 8 Tribal Association.
West Coast is concerned that the current pace of oil and gas development is being undertaken without consideration of the long term impacts on our environment. We know that First Nations throughout BC share these concerns, and many want to ensure that if oil and gas development is to occur on their territories, it is done in such a way as to minimize the ecological footprint of the industry so that traditional lands and ways of life can be sustained. We are committed to working with First Nations and communities throughout BC toward a strong legal regime that will protect environmental and community values. We are also working to foster the development of cumulative impact assessments so that we can better understand the long-term implications of this rush for development.
1. West Coast is grateful for participant funding provided by the Ministry of Water, Land and Air Protection.
COMMENTS ON THE BC MINISTRY OF WATER, LAND AND AIR PROTECTION’S
COALBED METHANE PRODUCED WATER CODE OF PRACTICE INTENTIONS PAPER
West Coast Environmental Law
In late December 2004, the Ministry of Water, Land and Air Protection provided West Coast Environmental Law (West Coast) with its Code of Practice Intentions Paper [Code of Practice for the Discharge of Produced Water from Coalbed Gas Operations] for comment. The Intentions Paper is a summary document outlining the Ministry’s proposed Code of Practice.
West Coast welcomes the opportunity to provide comments; however, a limited process is no substitute for full, transparent involvement of citizens and non-governmental organizations around the issue of coalbed methane development in British Columbia.
West Coast has assembled two documents which comment on the Intentions Paper or proposed Code of Practice:
1.) A Technical Review of the Intentions Paper, prepared on behalf of West Coast by the Center for Science in Public Participation;1 and
2.) This report, which reviews the Intentions Paper in light of West Coast’s Checklist for BC Code of Practice for Discharge of Produced Water from Coalbed Gas Operations – released in August 2004. Our comments respond to the questions that we asked in our Checklist in anticipation of the release of a Code of Practice.
Both documents may be viewed or downloaded from our website (http://www.wcel.org ).
West Coast does not support coalbed methane development proceeding at this time. As stated in Oil and Gas in British Columbia: 10 Steps to Responsible Development (West Coast et al, 2004), we do not support coalbed methane development until such time as “?comprehensive studies into well spacing and water issues are completed to the satisfaction of affected communities, and until appropriate safeguards are put in place.”
We sincerely hope that the Ministry, in developing and finalizing its regulatory regime for coalbed methane development, will take our comments into consideration, address the concerns that we have raised, and implement the safeguards that both we and our technical consultants have recommended. We also hope that the Ministry will engage the public in a broad and open process of consultation, on all issues of concern around coalbed methane development.
A. A RIGOROUS REGULATORY REGIME
1. Is the Environmental Management Act being used to its fullest potential to protect against a new and largely untested environmental challenge?
The Ministry’s decision to proceed by way of a Code of Practice does not use the Environmental Management Act to its fullest potential, and British Columbians are not receiving the highest level of protection possible within the confines of our existing legislation. The highest level of protection afforded by the Act is to require individual permits or other authorizations for activities identified in Schedule 1 as high risk. Such permits provide an opportunity for site-specific concerns to be taken into account when authorizing waste discharges.
The Ministry’s choice to proceed by way of a generic Code of Practice, rather than by individual permits, precludes the government from considering site-specific concerns or from regularly re-assessing the environmental safety on occasion of a permit renewal. In our view, a generic approach to regulating produced water is highly risky, given the newness of coalbed methane activity in BC, the fact that we simply don’t know what kind of water will be produced as a result of that activity, and BC’s high level of biodiversity.
In our view, given the environmental risks and all of the unknowns, the Ministry should adopt a precautionary approach and begin by regulating coalbed methane produced water in the most rigorous manner possible under the Act – i.e., through the use of individual permits. Only after the Ministry has gained some experience with produced water pollution, should the Ministry consider downgrading coalbed methane produced water discharges to Schedule 2 of the Waste Discharge Regulation, if in fact this is ever appropriate.
In addition, given that under a Code of Practice dischargers will not need to obtain a permit authorizing them to discharge water, persons aggrieved will not appear to have available to them the normal recourse of an appeal to the Environmental Appeal Board (under section 100 of the Act) in respect of a “decision of a director” (which includes issuance of a permit). Thus, some of the remedies which are normally available to the public under the Environmental Management Act, will not in this case be available in respect of concerns over the discharge of coalbed methane produced water.
2. Are comprehensive valid baseline studies required in advance of development?
Answer: Baseline monitoring has been stipulated as a requirement, but with insufficient detail
The Intentions Paper states that “Anyone proposing to discharge produced water into perennial or seasonal streams, or to ground via infiltration under the proposed code will need to do receiving environment baseline monitoring.” (page 5)
This requirement is a step in the right direction; however, “baseline” needs to be properly defined to mean the state of affairs existing before development has begun or any produced water discharges have occurred in a particular stream. A true baseline does not measure an already contaminated environment or one where development has already occurred.
Secondly, a proper baseline study requires sufficient time to carry out and needs to take into account temporal variances in the environment that may occur with the passing of seasons, the influx of snowmelt, the occurrence of a drought, normal variations from year to year, etc.
For example, according to a report prepared by Summit Environmental Consultants for the BC Ministry of Energy and Mines reviewing available information in the Crowsnest Coalfield in the East Kootenays, dated March 31, 2004, there was very little data available and “[t]his is a potentially critical information gap and baseline water quality monitoring will very likely be needed at least three years before CBG (coalbed gas) development.”
Thirdly, the scope of the baseline monitoring program specified is not sufficiently broad. The program fails to require a survey of soil conditions, soil structure or wildlife which may be impacted by discharges to streams, or soil conditions , soil structure, vegetation or wildlife that may be impacted by discharges to the ground. The scale of the monitoring has also not been linked to the scale of the proposed development. If dozens or hundreds of coalbed methane wells will likely be planned, baseline data should be conducted on a watershed or even a regional level, since impacts will occur on this scale.
3. Is comprehensive produced water testing and monitoring required, and made available to the public in a timely manner?
Answer: Under the proposed Code of Practice, testing and monitoring are required, but reports need not be routinely submitted to government. Summary reports of data only need to be submitted if a Code standard is exceeded, if analysis of the data indicates a “deleterious environmental change” or if a government official instructs the discharger to do so (page 4 and 6). Data need not be made publicly available unless a government official directs this to be done (page 6).
We are concerned that in the proposed Code there is no requirement for data to be routinely submitted to the government or made publicly available. Regular government and public oversight would not only encourage compliance with testing and monitoring requirements, but would also facilitate public scrutiny and analysis of the data. In our view, given the importance of maintaining the quality of our water as a public resource, and the implications that produced water discharges have for our water supply, testing and monitoring results should not only be subject to regular government verification and oversight, but should also be made publicly available at the same time results are known to the companies.
We are also concerned that “deleterious environmental change” has not been defined,making it open to interpretation by the discharger or its qualified professional. Reporting levels should be clearly and objectively defined, and there should be regular oversight of the monitoring.
4. Is produced water testing and monitoring independent and professional?
Answer: The qualifications of the “qualified professional” have not been determined; and given that the professional is paid by the discharger, the relationship is not at “arm’s length.”
The proposed Code requires dischargers to implement a monitoring program (page 6), but while the program must be designed and supervised by a yet-to-be-defined “qualified professional”, it need not actually be performed by a professional person. Also, it cannot be said that the program is independent, since the qualifed professional is contracted to, and paid by, the discharger.
Because “qualified professional” has not yet been defined, it is not clear whether the qualified professional will be liable for failure to perform duties in the same way that government is liable for
regulatory negligence, nor is it clear whether they will be legally accountable for their actions to a professional body. We recommend that if “qualified professionals” are to be used, these are important features necessary to ensure some level of public accountability.
Protecting public resources from damage is a public duty and we believe that the most effective way to ensure that standards are being met so as to protect our resources is to employ professional public officials who are singularly devoted to ensuring the protection of those resources, and won’t be influenced by a contract, employment or financial relationship with, or dependence upon, the discharger.
5. Will the use of toxic materials in fracturing fluids be banned?
The proposed Code of Practice fails to address this important issue at all.
The failure to address fracturing fluid toxicity is an important regulatory omission. Coalbed methane producers commonly use toxic substances, including diesel fuel, in their fracturing fluids. These fluids can travel into groundwater with devastating effects: even trace quantities of toxic substances such as benzene can contaminate vast quantities of fresh water. Remediation of groundwater is very expensive, very difficult, and is sometimes impossible.
Water-based alternative fluids do exist and their use is preferable to the use of oil-based fluids. Given the availability of a choice, and the importance of protecting the purity and integrity of BC’s groundwater supplies, toxic fluids should be banned and water-based fluids should be required in all cases.
B. PROTECTING WATERCOURSES, FISH AND FISH HABITAT
6. Is produced water treatment mandatory?
Answer: Produced water treatment is not mandatory in all cases. In the Intentions Paper (page 3), the only time that water treatment is prescribed is to remove iron and manganese precipitates if necessary so as to minimize discolouration in a perennial stream to the greatest extent practical or if necessary to minimize discolouration in a seasonal stream. (Emphasis added.) (Note that this language is vague: it is not clear what level of discolouration is acceptable or not acceptable.)
In our view, in order to protect BC’s increasingly valuable water resources, companies should be required to to treat produced water and to adhere to disposal schedules that do not adversely affect water absorption or surrounding land, stream habitat structure, stream flow quantity or ground water quantity. There should be no exceptions, though levels of treatment should be adjusted to reflect different disposal options, keeping in mind that the preferred option is always going to be reinjection. For example, where it is possible that any produced water could be discharged on lands, or into waterways, it should be treated to a standard comparable to local rainwater or snowmelt.
The provisions of the federal Fisheries Act should be kept in mind in this context. Should produced water – even when treated – come into contact with fish-bearing streams or their tributaries, the provisions of the Fisheries Act prohibiting the harmful alteration, disruption or destruction of fish habitat become operative.2 The existence of a Code of Practice must not excuse compliance with the Fisheries Act nor insulate against potential prosecutions under that Act should harmful alteration of fish habitat occur even when complying with the Code of Practice.
In our view, given that the proposed Code of Practice contemplates surface disposal in or near fish-bearing streams or their tributaries, the Code of Practice should expressly refer to the requirements of the approval provisions of the section 35(2) of the Fisheries Act before any disposal into waters that could affect fish or fish habitat.
7. Does the Code, or ideally, will a permit, clearly indicate that re-injection of the produced water is the default preferred option?
While the Intentions Paper states that “[d]eep-well injection is one option available to the coalbed gas industry to dispose of poor quality produced water” (page 1), the proposed Code does not require dischargers to reinject their water nor to place any kind of legal priority on reinjection as an option for disposal.
In contrast to this, research carried out after experience with this industry in the United States confirms that deep well reinjection is the safest and most sustainable method of disposal of produced water.3 This is because the organic and inorganic chemistry of produced water has not been well studied. The long-term impacts of dissolved contaminants such as phenols or arsenic are not well understood, and the impacts of produced water on different aquatic ecosystems across the province could be significant if its disposal is allowed on the surface. The negative impacts of surface disposal of coalbed methane produced water in the United States are extensively documented.
In this context, the default method of disposing produced water should be deep well injection so that the public does not end up bearing the risk of operations generating profit for private gain.
The burden of proof to deviate from default reinjection must lie with the company to prove that reinjection is not possible for geological reasons, not for lack of technology or ability on the part of the company, and that where surface disposal is to occur, that it will not adversely affect the local receiving environment.4 In order to ensure that those potentially affected are made aware of the possibility of surface disposal, the process whereby such approval is granted should be conducted in a transparent and accountable manner – an application should be made to the Ministry of Water,
Land and Air Protection (NOT to the Oil and Gas Commission), and should be made available for public comment and review before a decision is made.
8. Where surface water disposal occurs, will it have a beneficial use? And at a minimum, will it not adversely impact environmental quality?
Answer: All that is required under the proposed Code is for the discharger to “consider” beneficial uses; there is no requirement to actually put the water to a beneficial use.
The Intentions Paper states, “The use of this water for irrigation, stream flow augmentation or industrial purposes is encouraged if the quality is good enough or if the industry chooses to apply treatment to an acceptable level” (page 1).
In our view, if discharges are to be made to the surface (rather than the preferable course of reinjection) then if a beneficial use is possible, dischargers should be required to treat the water to an environmentally sound level appropriate to the proposed use of the water.
Currently, the proposed Code does not mandate a preference for beneficial use of the produced water; and as set out in our technical experts’ report, we also have many concerns about negative impacts to the environment arising from the standards and practices which are outlined in the Intentions Paper.
We are concerned about potential pollutants which are not on the government’s list of required substances to test for. We are also concerned that the prescribed standards are not sufficiently stringent or comprehensive and:
o will allow degradation of BC’s streams and water supplies;
o fail to protect against unacceptable cumulative impacts; and
o do not adequately protect fish and other aquatic life from total dissolved solids or other pollutants or pollutant levels.
Please see our technical expert’s report, on our website (www.wcel.org ), for a full discussion of these and other concerns.
C. MEANINGFUL COMPLIANCE AND ENFORCEMENT
9. Is the Code of Practice legally binding and therefore enforceable?
Answer: We remain concerned about the enforceability of the Code provisions.
While there does appear to be an intention to make the Code enforceable by the Oil and Gas Commission (Intentions Paper, page 1), at the present time the Code has not yet been implemented so its legal enforceability has not yet been tested.
We are concerned, however, about the wisdom of instituting a system that does not require a specific permit or review of intended operations for compliance with standards from the outset of operations. In particular, given the significant cuts to numbers of government staff which have taken place over the last several years, we are very concerned with a system that places such heavy reliance on field inspection staff to ensure that the Code’s standards are being met out in the field.
In addition, we are further concerned with the fact that under the Waste Discharge Regulation5 a discharger may apply for substitution of a different requirement in lieu of the requirements set out in the Code of Practice, however, there is no process whereby a member of the public or a person affected by the waste may apply for a substitution to “protect the public or the environment.”
10. Will enforcement responsibility exist with the Ministry of Water, Land and Air Protection and NOT the Oil and Gas Commission?
The Intentions Paper states (at page 1) that enforcement of the Code of Practice will rest with the Oil and Gas Commission, rather than being subject to the oversight of the Ministry of Water, Land and Air Protection.
We would prefer that enforcement responsibilities be given to the Ministry of Water, Land and Air Protection (and that adequate funding be provided to the Ministry for it to do so), not only because MWLAP has the most expertise in the area of environmental protection, but also because the independence of the Oil and Gas Commission has been compromised since amendments to the Oil and Gas Commission Act in 2003 made the Deputy Minister or Energy and Mines the Chair of the Oil and Gas Commission, having the tie-breaking vote in decisions. Additionally, there is also emerging concern about the ability of the Oil and Gas Commission to respond effectively to public concerns. For example, on at least four occasions, the Oil and Gas Commission’s independent Advsiory Committee conducted reviews of specific approvals and recommended that those approvals be reconsidered, yet in every instance, the Commission went ahead with the original approval.
11. Does the Code of Practice provide meaningful penalties for non-compliance?
Answer: These have not yet been established, so we cannot evaluate at this time.
The Intentions Paper states (at page 2) that to meet its objectives, the Ministry of Water, Land and Air Protection “?will?[e]stablish appropriate penalties for contravention of the Code of Practice under provisions of the Environmental Management Act.” Those penalties have not yet been made public.
A 2001 West Coast study found that most penalties for environmental infractions in BC are valued at $220 or $575, little more than a speeding ticket.6 Similar results have been found with the Oil and Gas Commission compliance reviews.
In our view, meaningful administrative penalties should not only be applied and effectively enforced but the government should also stipulate directly that the offence provisions of the Act will apply in the event of non-compliance with the Code of Practice.
Finally, in order to encourage deterrence, we urge the Ministry to reinstate non-compliance reporting, if not across the board, then for specific violations of this Code of Practice in order that local citizens can better understand the impacts of the development, and the corporate performance of the companies operating in their communities.
12. Will the Code of Practice allow for citizen prosecution of offenders?
The proposed Code makes no allowance for citizen prosecution of offenders.
The BC government has a current policy of staying private prosecutions commenced under federal or provincial environmental laws, including the federal Fisheries Act. This effectively stops violation charges from proceeding in the courts. At a time when the government itself is laying off monitoring and enforcement staff, allowing citizen prosecution of polluters to occur could be a means for the government to uphold its promises to “strengthen” enforcement.
West Coast opposes the policy of staying private prosecutions in BC, and believes that the threat of coalbed methane produced water impacting fisheries presents a prime opportunity to modify and ultimately reverse this policy. Since the Code of Practice potentially ventures into federal jurisdiction through the Fisheries Act, we recommend that the Code expressly recognize and respect the right to citizen prosecution under the Fisheries Act. This Act contains express incentives (through sharing of penalties) for citizen prosecution.
13. Given that it is a new and untested environmental challenge, will the Code provide for public review to evaluate the success of its implementation?
There is no provision for a public review of the success of the Code’s implementation. This is very disappointing.
In our view, implementation of the Code will be a “work in progress” for the first number of years of coalbed methane production in BC. In order to ensure that the Code is meeting its goals and the goals of the public in protecting the environment and quality of life for British Columbians, the Code should provide for regular, yearly, open, accountable, public reviews in order to evaluate its success. Citizen participation should be a component of these reviews, as it is the citizens in local communities who will gain real knowledge of the success or failure in implementation of the Code.
For all the reasons stated, West Coast cautions British Columbia against rushing ahead with coalbed methane development. Instead, West Coast urges the adoption of a precautionary approach involving careful study, implementation of duly rigorous safeguards to protect our water and land, and a through consultation with the public on all issues of concern. Thus, while West Coast welcomes the opportunity to engage in a discussion of appropriate safeguards, West Coast submits that, consistent with the 10 Steps to Responsible Development, much work remains to be done before the province should give the green light to coalbed methane development.
I: Corresp2005 1sr26 produced water code comments.doc
2. R.S.C. 1985, c. F-14, s. 35(1)
3. Kuipers, J., K. MacHardy, W. Merschat and T. Myers, 2004. Coalbed Methane Produced Water: Management Options for Sustainable Development. Prepared for Northern Plains Resource Council, Billings, MT.
4. We do not equate this statement with not causing pollution under the Environmental Management Act, given that the Act defines pollution as “substances or contaminants that substantially alter or impair the usefulness of the environment,” as this definition clearly envisions impacts to the environment. The earlier comments about the application of the Fisheries Act are also relevant in this context.
5. See B.C. Reg. 320/2004, sections 7 and 8.
6. See Undermining the Law: Addressing the Crisis in Compliance with Environmental Mining in BC, West Coast Environmental Law, December 2001, p. 46; and Oil and Gas in British Columbia: 10 Steps to Responsible Development, West Coast Environmental Law, et al, April 2004, p. 12.
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Ranchers, Residents and First Nations of the Peace Unite to Challenge B.C. Government Race for Coal Bed Methane
Source: Saulteau First Nations