EDMONTON - Less than two weeks after Alberta enacted legally enforceable pollution limits for its oilsands region, industry figures already suggest they will soon be breached by emissions of two major gases causing acid rain.

Regulatory documents for Shell's proposed Jackpine mine expansion say annual levels of sulphur dioxide and nitrogen dioxide are likely to push past limits contained in the province's Lower Athabasca Regional Plan if all currently planned developments proceed.

The documents, filed late last week, also provide what may be the clearest picture yet of what impact two decades of development have had on northeastern Alberta.

"It validates the concern that many stakeholders have raised about the cumulative pace and scale of development," said Simon Dyer of the Pembina Institute. "It's the first real test of the (plan)."

Shell filed the papers after the Canadian Environmental Assessment Agency asked the company to give a clearer account of how the environment of the oilsands region has changed since development began and what part the Jackpine expansion would play. Written by environmental consultants Golder and Associates, the document estimates how levels of the two gases have grown over the years.

Average annual levels of sulphur dioxide are estimated at about 20 times what they would naturally be over a large area from Fort MacMurray to about 100 kilometres north. Nitrogen dioxide is estimated to be at least 10 times pre-development levels — although the report acknowledges hard data from that time is spotty.

And if all the projects that have been announced publicly or are in the regulatory process go ahead, the pollutants are projected to exceed what are supposed to be absolute caps.

Sulphur dioxide will reach average annual concentrations of 21.1 micrograms per cubic metre of air, just over the plan's limit of 20 micrograms. Nitrogen dioxide will reach 59.5 micrograms, well over the limit of 45.

Randall Barrett, director of Alberta Environment's northern region, said the projections are derived from models deliberately designed to overestimate emissions as a way to ensure caution.

"It shows us we have to be very diligent in how we are setting pollution controls for any plants in this area, because the computer models are predicting that we are getting close or over some of the air quality (levels)."

Regulators use the models to determine what sort of emission controls to impose on applicants, said Barrett.

"What would likely happen is they would go to the most stringent type of air quality pollution control, because the models are predicting you could be over the limit."

Barrett said actual air monitoring data continues to show both sulphur and nitrogen dioxides remain well under their caps. If those gases increase as more facilities come on stream, the plan includes "trigger" levels that would require industry to improve its pollution controls.

"This (modelling) is enforcing how important that monitoring is."

The government is obliged to act if pollutants exceed either the triggers or the absolute caps — an obligation that Environment Minister Diana McQueen has underlined.

"It is a legally binding commitment that holds government accountable to Albertans," she said when announcing the plan Aug. 22.

In an emailed response, a Shell spokesman said the projections are based on assumptions that all planned developments are operating at the same time at full capacity. It adds that some of the proposals have yet to start the regulatory process.

In the document, Shell points out the sulphur dioxide levels are concentrated in areas closest to its mines, regions that should be treated differently. Levels in "non-developed areas" remain below the government's cap, it says.

It also says elevated nitrogen dioxide levels are a result of "over-predicted" emissions from giant trucks used in the mines and suggests those emissions are being reduced as the vehicles are upgraded.

Dyer says the government's plan makes no provision for treating some areas differently than others. He also says contaminants in one area do ultimately spread throughout the region.

An earlier Shell document acknowledges 23 small, mostly unnamed lakes, have already passed their critical load for acid.

The document also lists cumulative effects that aren't yet governed by the regional plan, such as wildlife impacts.

Out of 22 indicator species — including birds, mammals and amphibians — 16 will suffer high or moderate negative consequences even under the current amount of development, it says. Some areas will suffer "moderate" biodiversity loss, even after reclamation efforts.

Shell argues species will rebound as the area is returned to a more natural state and adds there should be enough undisturbed regions to maintain a healthy ecosystem.

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  • Syncrude Upgrader and Oil Sands

    The refining or upgrading of the tarry bitumen which lies under the oil sands consumes far more oil and energy than conventional oil and produces almost twice as much carbon. Each barrel of oil requires 3-5 barrels of fresh water from the neighboring Athabasca River. About 90% of this is returned as toxic tailings into the vast unlined tailings ponds that dot the landscape. Syncrude alone dumps 500,000 tons of toxic tailings into just one of their tailings ponds everyday.

  • Boreal Forest and Coast Mountains / Atlin Lake, British Columbia | 2001

    This area, located in the extreme northwest of British Columbia, marks the western boundary of the Boreal region. On the border of the Yukon and Southeast Alaska, the western flank of these mountains descends into Alaska's Tongass Rainforest and British Columbia's Great Bear Rainforest. Far from the oil sands, the greatest remaining coastal temperate and marine ecosystem is imminently threatened by the proposal to build a 750-mile pipeline to pump 550,000 barrels per day of oil sands crude to the coast. Once there, it would be shipped through some of the most treacherous waters, virtually assuring an ecological disaster at some point in the future.

  • Tailings Pond in Winter, Abstract #2 / Alberta Tar Sands | 2010

    Even in the extreme cold of the winter, the toxic tailings ponds do not freeze. On one particularly cold morning, the partially frozen tailings, sand, liquid tailings and oil residue, combined to produce abstractions that reminded me of a Jackson Pollock canvas.

  • Aspen and Spruce | Northern Alberta | 2001

    Photographed in late autumn in softly falling snow, a solitary spruce is set against a sea of aspen. The Boreal Forest of northern Canada is perhaps the best and largest example of a largely intact forest ecosystem. Canada's Boreal Forest alone stores an amount of carbon equal to ten times the total annual global emissions from all fossil fuel consumption.

  • Tar Sands at Night #1 | Alberta Oil Sands | 2010

    Twenty four hours a day the oil sands eats into the most carbon rich forest ecosystem on the planet. Storing almost twice as much carbon per hectare as tropical rainforests, the boreal forest is the planet's greatest terrestrial carbon storehouse. To the industry, these diverse and ecologically significant forests and wetlands are referred to as overburden, the forest to be stripped and the wetlands dredged and replaced by mines and tailings ponds so vast they can be seen from outer space.

  • Dry Tailings #2 | Alberta Tar Sands | 2010

    In an effort to deal with the problem of tailings ponds, Suncor is experimenting with dry tailings technology. This has the potential to limit, or eliminate, the need for vast tailings ponds in the future and lessen this aspect of the oil sands' impact.

  • Tailings Pond Abstract #2 | Alberta Tar Sands / 2010

    So large are the Alberta Tar Sands tailings ponds that they can be seen from space. It has been estimated by Natural Resources Canada that the industry to date has produced enough toxic waste to fill a canal 32 feet deep by 65 feet wide from Fort McMurray to Edmonton, and on to Ottawa, a distance of over 2,000 miles. In this image, the sky is reflected in the toxic and oily waste of a tailings pond.

  • Confluence of Carcajou River and Mackenzie River | Mackenzie Valley, NWT | 2005

    The Caracajou River winds back and forth creating this oxbow of wetlands as it joins the Mackenzie flowing north to the Beaufort Sea. This region, almost entirely pristine, and the third largest watershed basin in the world, will be directly impacted by the proposed Mackenzie Valley National Gas Pipeline to fuel the energy needs of the Alberta Oil Sands mega-project.

  • Black Cliff | Alberta Oil Sands | 2005

    Oil sands pit mining is done in benches or steps. These benches are each approximately 12-15 meters high. Giant shovels dig the oil sand and place it into heavy hauler trucks that range in size from 240 tons to the largest trucks, which have a 400-ton capacity.

  • Oil Sands Upgrader in Winter| Alberta Oil Sands | 2010

    The Alberta oil sands are Canada's single largest source of carbon. They produce about as much annually as the nation of Denmark. The refining of the tar-like bitumen requires more water and uses almost twice as much energy as the production of conventional oil. Particularly visible in winter, vast plumes of toxic pollution fill the skies. The oil sands are so large they create their own weather systems.

  • Boreal Forest and Wetland | Athabasca Delta Northern Alberta | 2010

    Located just 70 miles downstream from the Alberta oil sands, the Athabasca Delta is the world's largest freshwater delta. It lies at the convergence of North America's four major flyways and is a critical stopover for migrating waterfowl and considered one of the most globally significant wetlands. It is threatened both by the massive water consumption of the tar sands and its toxic tailings ponds.

  • Tar Pit #3

    This network of roads reminded me of a claw or tentacles. It represents for me the way in which the tentacles of the tar sands reach out and wreak havoc and destruction. Proposed pipelines to American Midwest, Mackenzie Valley, and through the Great Bear Rainforest will bring new threats to these regions while the pipelines fuel new markets and ensure the proposed five fold expansion of the oil sands.

  • <strong>NEXT -----> Craziest Pictures of the oilsands</strong>

  • Syncrude's Mildred Lake Upgrader, part of The Syncrude Project complex for oil sands processing, is pictured Monday, March 8, 2006 in Fort McMurray, Alberta, Canada.

  • The Syncrude oil sands extraction facility is reflected in a lake reclaimed from an old mine near the town of Fort McMurray in Alberta, Canada on October 22, 2009.

  • A disused mining machine on display in front of the Syncrude oil sands extraction facility near the town of Fort McMurray in Alberta on October 22, 2009.

  • Tailings pond in winter.

  • Syncrude upgrader.

  • Dry tailings.

  • The Suncor oilsands operation uses trucks that are 3 stories tall, weigh one million pounds, and cost 7 million dollars each.

  • Oilsands at night.

  • A tailings pond.

  • Black Cliff in the Alberta oilsands.

  • Oilsands upgrader in winter.

  • Oilsands extraction.

  • Oil sits on the surface at a Suncor Energy Inc. oilsands mining operation near Fort McMurray, Alberta, Canada, on Tuesday, Aug. 13, 2013. Photographer:

  • A large oil refinery along the Athabasca River in Alberta's Oilsands. Fort McMurray, Alberta.

  • Oils mixes with water at a tailings pond at a Suncor Energy Inc. oilsands mining operation near Fort McMurray, Alberta, Canada, on Tuesday, Aug. 13, 2013.

  • Fort McMurray is in the heart of the world's biggest single oil deposit - the Athabasca Oil Sands, and the oil is extracted by surface mining and refined in the region. The oil production is at the heart of the economy.

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  • This Tuesday, July 10, 2012 aerial photo shows a Nexen oil sands facility near Fort McMurray, Alberta, Canada.

  • This Sept. 19, 2011 aerial photo shows an oilsands facility near Fort McMurray, in Alberta, Canada.

  • This Sept. 19, 2011 aerial photo shows an oilsands tailings pond at a mine facility near Fort McMurray, in Alberta, Canada.

  • This Sept. 19, 2011 aerial photo shows an oilsands tailings pond at a mine facility near Fort McMurray, in Alberta, Canada.

  • The Syncrude extraction facility in the northern Alberta oil sand fields is reflected in the pool of water being recycled for re-use.

  • A night view of the Syncrude oil sands extraction facility near the town of Fort McMurray in Alberta Province, Canada on October 22, 2009.

  • Aerial view of a lake and forests in the vicinity of oil sands extraction facilities near the town of Fort McMurray in Alberta, Canada on October 23, 2009.

  • Workers use heavy machinery in the tailings pond at the Syncrude oil sands extraction facility near the town of Fort McMurray in Alberta , Canada on October 25, 2009.

  • Fort McMurray is in the heart of the world's biggest single oil deposit - the Athabasca Oil Sands, and the oil is extracted by surface mining and refined in the region. The oil production is at the heart of the economy.

  • A large oil refinery in Alberta's Oilsands project. Fort McMurray, Alberta.

  • Next: Alberta Oil Spills

  • CFB Cold Lake, CNRL

    A bitumen leak was reported at a Canadian Natural Resources oilsands operation in the weapons range part of the RCAF base in June 2013.

  • CFB Cold Lake, CNRL

    Company officials said the leak - at what it calls its Primrose operation - was caused by faulty machinery at one of the wells, affected an area of approximately 13.5 hectares and released as much as 3,200 litres of bitumen each day.

  • CFB Cold Lake, CNRL

    Preliminary tallies put the death toll from the leak at 16 birds, seven small mammals and 38 amphibians. Dozen were rescued and taken to an Edmonton centre for rehabilitation.

  • CFB Cold Lake

    As of early August 2013, more than 1.1 million litres of bitumen had been pulled from marshlands, bushes and waterways.

  • CFB Cold Lake, CNRL

    Although CNRL could not say when the leak may finally be stopped, it estimates it will likely cost more than $40 million to clean up.

  • <em>Click through for other recent spill in Alberta</em>

  • Plains Midstream

    Little Buffalo band member Melina Laboucan-Massimo scoops up July 13, 2012 what appears to oil from the pond shoreline near the site of a 4.5 million-litre Plains Midstream pipeline leak detected April 29, 2011. Photos taken at the site and released by Greenpeace of Alberta's second-worst pipeline spill suggest at least part of the site remains heavily contaminated despite company suggestions that the cleanup is complete.

  • Plains Midstream Canada

    A boat passes by a boom stretching out to contain a pipeline leak on the Gleniffer reservoir near Innisfail, Alta., Tuesday, June 12, 2012. Plains Midstream Canada says one of their non-functioning pipelines leaked between 1,000-3,000 barrels of sour crude near Sundre, Alberta, on June 7 and flowed downstream in the Red Deer river to the reservoir.

  • Plains Midstream Canada

    Debris pushes up against a boom as it stretches out to contain a pipeline leak on the Gleniffer reservoir near Innisfail, Alta., Tuesday, June 12, 2012.

  • Plains Midstream Canada

    A boom stretches out to contain a pipeline leak on the Gleniffer reservoir near Innisfail, Alta., Tuesday, June 12, 2012. Plains Midstream Canada says one of their non-functioning pipelines leaked between 1,000-3,000 barrels of sour crude near Sundre, Alberta, on June 7 and flowed downstream in the Red Deer river to the reservoir.