Discussion Paper Feedback Form

DISCUSSION PAPER FEEDBACK FORM

Discussion Paper Title: Energy Well Integrity

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3)  To what extent do you agree with the accuracy of the Discussion Paper? Please select.

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4)  Are there any topics that were omitted that you would like to see included in future versions? Please list.

I would like to point out that although the Discussion Paper does not think that ‘methane entering potable water sources is not a serious health issue in comparison to many other chemical contaminants’ and that ‘Gas entering shallow groundwater wells may be a nuisance, including exceptionally an explosion hazard, but other than making groundwater unpalatable in some cases, no severe health impacts appear to have been demonstrated at this time..’ For those who rely on groundwater this is an issue of serious concern and should not be played down. In many Canadian provinces, such as British Columbia, it is often the most marginalised segment of the population who lives next to the gas extraction zones and cannot necessarily afford to drive to the supermarket to buy potable water. Therefore, First Nations have good grounds to be worried about water contamination in their traditional territories. See eg Fort Nelson First Nation, “A Water Sustainability Act for B.C. Legislative Proposal: Submissions of Fort Nelson First Nation” (15 November 2013) 2-3 <http://engage.gov.bc.ca/watersustainabilityact/files/2013/11/Fort-Nelson-First-Nation.pdf> accessed 13 May 2014.

5)  Are there any questions that you would like to see addressed? Please list.

I also wonder whether ‘the remote possibility of interwell communication during hydraulic fracturing’ (p. 10) is this, in fact, remote? There are a number of incidents in British Columbia and Alberta. Unfortunately, the information on this is on the BC Oil and Gas Commission website is not up-to-date, but nevertheless there is evidence that it may not be that remote. See eg BC Oil and Gas Commission, “Safety Advisories” <http://www.bcogc.ca/node/5806/download> accessed 2 May 2014. The key in avoiding interwell communication appears to be its prevention/containment.

I also think that it would be worth emphasising that although many problems can be mitigated at the stage when shale gas wells are productive, potential adverse impacts on the environment and local populations may arise long after the well abandonment. Therefore, Nova Scotia legislators or the future regulatory framework should address the issue of who is liable for any potential environmental damage after the abandonment.

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Name: Sanna Elfving Email:

Thank you!