Dear Minister Dabrusin and the Impact Assessment Agency of Canada,

The undersigned organizations are writing to express support for a group of concerned Albertans known as “No CO2 Pipelines Alberta”. This community group, located around St. Paul, Alberta, has raised serious concerns regarding the safety, environmental, and long term community risks associated with the proposed Oil Sands Alliance CO2 transportation network and storage hub project (the “Pathways Project”), which would directly affect the region where they work and live.

According to the Government of Canada, the Pathways Project would be the largest carbon capture, utilization, and storage (CCUS) project in the world. The proposed project would consist of a more than 400-kilometer CO2 transportation pipeline network connecting multiple oil sands facilities to a large underground carbon storage hub in northeastern Alberta, near the Cold Lake region. The project is intended to capture and transport CO2 for underground storage. Given its unprecedented scale, potential environmental impacts, and implications for communities, the undersigned organizations agree it would be irresponsible for the project to proceed without a comprehensive federal environmental impact assessment (EIA).

The Pathways Project is currently being negotiated as part of the Canada-Alberta Memorandum of Understanding, signed on November 27, 2025.[1] This agreement included an April 1, 2026, deadline to finalize a trilateral agreement between Alberta, Canada, and the Oil Sands Alliance partner companies. As of the date of this letter, no final agreement has been made public.

We share many of the same concerns as No CO2 Pipelines Alberta regarding the Pathways Project, including:

• CO2 pipeline leaks pose significant public safety risks. High concentrations of CO₂ can displace oxygen, leading to acute health impacts, including respiratory distress and, in severe cases, death. CO2 leaks may also impair vehicle operation, potentially limiting emergency response (see Pipeline Failure Hazards Map, below). These risks are not hypothetical. In February 2020, a CO2 pipeline rupture near Satartia, Mississippi affected more than 200 people and resulted in at least 45 hospitalizations.[2] Recent oil pipeline failures in Alberta further highlight oversight and infrastructure reliability. In April 2026, an Imperial Oil pipeline leaked around 863,000 litres of bitumen emulsion in the Cold Lake region. Imperial Oil is one of the companies behind the Pathways Project. Events like this raise serious concerns about whether proponents and regulators can adequately prevent failures and protect nearby communities, watersheds, and ecosystems from harm.
• Significant uncertainty remains regarding the long-term integrity of underground CO2 storage and the potential for future leakage. The oil and gas sector already has a well-documented history of delays in decommissioning infrastructure and restoring impacted lands. Without a legally enforceable, industry-funded cleanup and monitoring plan, long-term liabilities and associated costs may ultimately fall to landowners and the public.
• There has been a lack of meaningful consultation with affected communities. Landowners, municipalities, and residents who will be directly affected by this project have not been adequately informed of the project’s risks, nor meaningfully consulted.
• The project appears to be advancing without free, prior, and informed consent of affected Indigenous Nations, raising serious concerns regarding impacts to Treaty, Constitutional, and inherent rights, and is inconsistent with Canada’s commitments to reconciliation. As stated in the Speech from the Throne:
  “The Government will be a reliable partner to Indigenous Peoples, upholding its fundamental commitment to advancing reconciliation.”
• CCUS projects carry risks of groundwater contamination, increased industrial water use, potential increased of seismic activity, land disturbance, and impacts to wildlife and ecosystems.
• The Pathways project is also tied to continued oil sands expansion and related export infrastructure. Any federal EIA must therefore consider the broader cumulative impacts of enabling additional fossil fuel production and associated greenhouse gas emissions.
• Despite being presented as a climate solution, significant uncertainty remains regarding the overall effectiveness of large-scale carbon capture and storage projects in achieving meaningful emissions reductions.[3,4]
• Further concerns arise from the performance of existing carbon capture and storage projects, many of which have struggled to consistently meet their stated capture targets, including projects in Alberta. Independent analyses have also raised concerns regarding the long-term economic viability and effectiveness of the Pathways Project.[5] Carbon capture technology should not be used to justify continued fossil fuel expansion while delaying more effective and proven emissions reduction measures.
• The project is expected to rely heavily on public funding despite being led by some of the wealthiest oil and gas corporations in the country. Billions of dollars in taxpayers support for a project with uncertain climate benefits demands rigorous public scrutiny and accountability.

We are also deeply concerned about the regulatory framework guiding this project. Current approaches appear to defer impact assessment responsibilities to the province under a co-operation agreement,[6] despite the national significance of the Pathways Project. Given longstanding concerns about the effectiveness and independence of the Alberta Energy Regulator (AER),[7,8,9] there is reason to question whether environmental and social impacts will be adequately assessed. The AER’s decision not to require a provincial impact assessment[10] only reinforces the urgent need for federal oversight.

As a project of national relevance, Canada has a responsibility to ensure a transparent, science based and comprehensive evaluation of the Pathways Projects and its cumulative impacts. The absence of a federal EIA limits the ability of Indigenous Nations, local communities, and the public to fully understand the implications for their lands, water rights, and long-term well-being.

In previous correspondence with Alberta Wilderness Association regarding major resource projects, Terence Hubbard emphasized the federal government’s commitment to:

“…upholding Canada’s world-leading environmental standards and its constitutional obligations to Indigenous Peoples.” [11]

Subjecting the Pathways Project to a rigorous federal EIA would demonstrate that commitment in practice. We therefore urge the federal government to exercise its authority under section 9(1) of the Impact Assessment Act to designate the Pathways Project for a federal EIA. In doing so, we join requests from Indigenous Nations,[12] numerous supporting organizations,[13] and Dr. Amil Shapka[14] in calling for a rigorous and transparent federal review of this project.

Governments and industry must prioritize immediate and sustained reductions in greenhouse gas emissions. CCUS should not be treated as a substitute for real emissions reductions or used to justify continued fossil fuel expansion. Projects of this scale should proceed only where they can clearly demonstrate clear climate benefits and where risks to communities, water, ecosystems, and future generations have been fully addressed. Protecting public health, environmental integrity, and Indigenous rights must be central to all decision-making regarding the Pathways Project.

Supporting references:

[1] Government of Canada. (2025, November 27). Canada-Alberta Memorandum of Understanding. https://www.pm.gc.ca/en/news/backgrounders/2025/11/27/canada-alberta-memorandum-understanding
[2] Simon, J. (2023, September 2023). The U.S. is expanding CO2 pipelines. One poisoned town wants you to know its story. NPR. https://www.npr.org/2023/05/21/1172679786/carbon-capture-carbon-dioxide-pipeline.
[3] Environmental Defence. (January, 2025). Federal Impact Assessment Needed for Pathways Alliance’s CO2 Hub. Media backgrounder. https://environmentaldefence.ca/wp-content/uploads/2025/01/PIA-Backgrounder-2-1.pdf
[4] Findlay, M. H. (May 1, 2026). Canada should back away from carbon capture and storage and focus on infrastructure like pipelines. Globe And Mail. https://www.theglobeandmail.com/opinion/article-canada-should-back-away-from-carbon-capture-and-storage-and-focus-on/?intcmp=gift_share
[5] Kalegha, M. (2024). Financial Risks of Carbon Capture and Storage in Canada: Concerns About the Pathways Project and Public Energy Policy. Institute for Energy Economics and Financial Analysis.
https://ieefa.org/sites/default/files/2025-01/Financial%20Risks%20of%20Carbon%20Capture%20and%20Storage%20in%20Canada_December%202024.pdf
[6] Government of Canada. (2026, April 2). Alberta and Canada sign co-operation agreement to accelerate major project assessments. https://www.canada.ca/en/impact-assessment-agency/news/2026/04/alberta-and-canada-sign-co-operation-agreement-to-accelerate-major-project-assessments.html
[7] Sousa, A. (2024, March 06). First Nation sues Alberta Energy Regulator over tailings leaks from oilsands mine. CBC. https://www.cbc.ca/news/canada/edmonton/first-nation-sues-alberta-energy-regulator-over-tailings-leaks-from-oilsands-mine-1.7135069
[8] Riley, S.J. (2026, April 10). ‘Largest single transfer in history’: 4,000 oil and gas wells just became orphans — nearly doubling Alberta’s total. The Narwhal. https://thenarwhal.ca/alberta-orphan-wells-increase/
[9] Freehill, L. (2025, August 26). Alberta Energy Regulator CEO cancels public hearing for Grande Cache coal mine. CBC. https://www.cbc.ca/news/canada/edmonton/alberta-energy-regulator-ceo-cancels-public-hearing-for-grande-cache-coal-mine-1.7618556
[10] Achtymichuk, N. (2024, December 23). AER declines request for an Environmental Impact Assessment of the Pathways Project. University of Calgary. Faculty of Law.
https://ablawg.ca/2024/12/23/aer-declines-request-for-an-environmental-impact-assessment-of-the-pathways-project/
[11] Letter from Terence Hubbard to Alberta Wilderness Association. https://www.albertawilderness.ca/wp-content/uploads/2026/04/20260422_lt_iaa_thubbard_president_re_cooperation_agreement_ab_canada.pdf
[12] Letter from Indigenous Nations to Minister Guilbeault.
https://iaac-aeic.gc.ca/050/documents/p89090/159929E.pdf
[13] Joint letter of support from organizations to Minister Guilbeault. https://www.albertawilderness.ca/wp-content/uploads/2025/02/20250211_lt_joint_engos_to_eccc_designate_pathways_ccus_hub_iaac_req_support.pdf
[14] Letter from Dr. Amil Shapka to Minister Dabrusin.
https://www.noco2pipelines.ca/_files/ugd/927a5e_769e4d7093b148ddbce9b9e8924786b1.pdf