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Informational Letter IL 82-11

5 March 1982

To: All Oil, Gas, and Oil Sands Operators

PRESERVATION OF ARCHAEOLOGICAL, PALAEONTOLOGICAL, AND HISTORICAL RESOURCES: POLICY UPDATE

This informational letter supersedes Informational Letter 79-18 and Interim Directive ID-G 77-1

The Energy Resources Conservation Board hereby updates the winter construction policy of Alberta Culture and consolidates its policy on archaeological, palaeontological, and historical resources.

Conditions to be Met

In order to assist implementation of Alberta's Historical Resources Act, the Board now requires as follows:

1. When requested by the Board, developers making application for permits, licences, or approvals for major projects under statutes and regulations administered by the Board shall include as part of their application the results of an inspection of archaeological, palaeontological, and historical resource sites that might be disturbed by the proposed development. To avoid delays in the processing of an application, the applicant may therefore wish to consult with the Board during early planning stages, to confirm the necessity for such an inspection.
   
   Should an historical-resource assessment be deemed necessary, take note of the policy statement regarding winter construction, dated June 1981 and attached to this informational letter. Companies contemplating major developments during the winter would be well advisedto determine the need for these assessments at such time as to allow the investigation of the project area during that time of the year best suited to the gathering of information required for a complete assessment.
   
   To assist developers, a set of guidelines entitled "Interim Guidelines: Historical Resource Impact Assessments" and a provincial map entitled "The Archaeological Resources Sensitivity Map" may be obtained through:

   The Archaeological Survey of Alberta Old St. Stephen's College 8820 - 112 Street Edmonton, Alberta T6G 2J6

   or The Energy Resources Conservation Board Maps and Publications Desk 640 - Fifth Avenue SW Calgary, Alberta T2P 3G4

2. Any holder of a permit, licence, or approval who becomes aware of an apparent archaeological, palaeontological, or historical site in the course of his development work, shall immediately notify the Board of the find and take steps to ensure that the site is preserved until its significance can be assessed. To avoid undue delay of development work the Board will arrange with the Historical Resources Division of Alberta Culture to inspect such sites brought to the Board's attention. This inspection will take place within three days of notice being received by the Board.

Notices under (2) and all inquiries in connection with archaeological, palaeontological, and historical resources, should be directed to the Manager of the Board's Environment Protection Department (261-8121).

[Original signed by]

V. E. Bohme
Board Member

ALBERTA
CULTURE
Office of the Minister

403/427-4928

402 Legislature Building
Edmonton, Alberta, Canada
T5K 2B6

June, 1981

POLICY STATEMENT

HISTORICAL RESOURCES CONSERVATION WORK CONDUCTED ON PROJECTS WITH A WINTER CONSTRUCTION SCHEDULE

When historical resources conservation work is requested of proponents for development projects having winter construction schedules, Alberta Culture has, in the past, often encountered difficulty in meeting its mandate as expressed in the Policy Statement: Historical Resources Conservation Work Occasioned by Development Programmes (May 12, 1977).

Historical resources, consisting of archaeological, palaeontological, historic, and some natural sites, are generally found as an integral component of the ground surface and upper soil deposits. Consequently, winter conditions, such as snow cover and frozen ground, severely impede the successful survey and investigation of these resources. In some instances it has been necessary to relax the technical requirements usually demanded of Historical Resource Impact Assessments on mitigative projects rather than delay significant and costly development projects until winter conditions have abated.

Unfortunately, the relaxation of these technical requirements greatly limits the successful assessment and mitigation of historical resource sites that may be impacted by development, thereby reducing the effectiveness of Alberta culture in meetings its mandate as provided for in the Alberta Historical Resources Act. This is not an acceptable solution, and as a result it will henceforth be necessary for Alberta Culture to require that the following policy be observed:

Policy Responsibilities

In order to ensure that historical resource assessments are conducted in sufficient detail to satisfactorily provide the Minister with all the information relevant to the question of the probable impact of a specific development proposal on historical resources, no specialconcessions will be made relative to difficulties encountered in winter programmes when assessing the results of the investigations necessitated by the project. Consequently, all reports will be evaluated strictly in terms of the content and quality of their results regardless of the season in which the project is initiated, and developers are advised to schedule their investigations for that time of year which will best enable their investigators to obtain the information necessary to provide a complete Historical Resources Impact Assessment.

ALBERTA
CULTURE
Office of the Minister

403/427-4928

402 Legislature Building
Edmonton, Alberta, Canada
T5K 2B6

May 12, 1977

POLICY STATEMENT

HISTORICAL RESOURCES CONSERVATION WORK OCCASIONED BY DEVELOPMENT PROGRAMS

One of the greatest strengths of any people is their appreciation of their common past. The ability to identify with a shared history results in the development of a bond amongst individuals and groups which frequently transcends all other affiliations, and gives those acknowledging this bond an identity marking them as unique in the world. For a nation, or a part of a nation, it is a priceless asset.

Until quite recently in Alberta a truly common sense of provincial identity was absent. Historical affiliations generally centred on other parts of the work or on local communities, for the population was basically composed of arrivals only one or two regional generations removed from a distant homeland, or native people with very strong ties. In keeping with this pattern, traditional values and practices were also transplanted or reinforced, resulting in the rich and diverse ethnic communities which characterize this province. These communities, and the affiliations they have created, continue to thrive today as testaments to the importance of a historical sense of belonging.

While the historic ethnic groups continue to flourish within Alberta, there has in recent years been an ever growing awareness that in addition to their ethnic affiliations, individual Albertans are participants in another historical tradition, that of the Province itself. This tradition, which is equally rich in both natural and human elements, has a strength and character of its own which identifies Albertans as having a world image all their own. It reflects contributions not only from the ethnic background of settlers and their descendants, but also from the Native inhabitants and the elements of nature which constitute the framework for the provincial pageant. Thus dinosaur fossils, buffalo jumps, fur trading posts and early homesteads all play a part in Alberta's historical tradition.

Appreciation of their common past is today becoming ever more apparent among Alberta's citizens, and they are asserting increasing pressure to have this historical tradition investigated, documented and presented in public displays and publications. Unfortunately, however, the realities of modern life are such that major elements of this shared identity are in grave danger of being lost before they can be properly integrated into the structure of our historical traditions.

While some facets of real significance to the early history of Alberta still survive, many of the physical vestiges of this history exist only as palaeontological, prehistoric or historic sites. At the same time, because these sites exist on or near the surface of the ground they are very susceptible to damage or destruction through land surface modifications. In an era of rapid and major land development associated with such things as resource extraction, recreation, transportation and urbanization, a substantial number of Alberta's prehistoric and historic sites and structures have been and will continue to be destroyed before their significance can be properly established and documented. The irony of this situation is that although the evolution of Alberta's character as a Province has finally reached the stage where citizens are actively seeking identity with a common past, the evidence testifying to this common past is now being destroyed by development at a rate far in excess of anything seen in previous years.

In recognition of this situation, the Alberta Provincial Government enacted the Alberta Historical Resources Act. Among other things the Act provides the Minister responsible for Culture with the authority to require developers to prepare assessments of the effect of their proposed developments on historical resources and to undertake such studies or modification to the development plan as may be necessary to retain important historical resource values. It is the intention of this Department to make use of this opportunity to maximize the retention of important historical resource sites, specimens and information for the benefit of all Albertans, both those now living and those yet to be born.

POLICY OBJECTIVES

1. To avoid unnecessary impact on all historical resource sites.
2. To preserve the most important historical resource sites wherever technically and economically feasible.
3. To promote the recovery of information and specimens of value from those historical resource sites which cannot be preserved.

In order to meet the above Policy Objectives, the following shall be considered to be the allocation of responsibilities:

POLICY RESPONSIBILITIES

1. The developer shall be responsible for the conduct of sufficiently detailed studies in the planning stage to enable the preparation of an historical resource impact assessment report, and for the production of such a report.
2. The Historical Resources Division of Alberta Culture will be responsible for the technical and professional review of historical resource impact assessments and the preparation of review statements concurring with, rejecting or requesting a modification of such recommendations relative to historical resource sites as cannot be avoided by the development because of technical or economic limitations.
3. The developer is responsible for the conduct of all mitigative measures deemed appropriate at historical resource sites which cannot be avoided by the development because of technical or economic limitations.
4. Where the Historical Resources Division and the developer cannot agree on appropriate mitigative measures (as above), the Minister of Culture will be responsible for the final decision as to appropriate mitigative measures to be undertaken in situations where historical resource sites cannot be avoided by a development because of technical or economic imitations.
5. The responsibilities of the developer will be the same for both government and private agencies.

In order to meet the respective Policy Responsibilities, the following shall be considered to be the normal procedures for implementation:

POLICY IMPLEMENTATION

1. At the planning stage of any major development; and well prior to the commencement of any ground surface disturbance, an inventory of the historical resources to be affected by the development will be prepared by the developer utilizing information obtained from archival sources when available and field reconnaissance when necessary.
2. On the basis of this inventory the developer will prepare an historical resources impact assessment report which details the nature and location of each historical resource site, the postulated effect of the development on each historical resource site, and the proposed mitigative measures to be undertaken by the proponent to minimize the loss of historical resources relative to each site that cannot be avoided by the development because of technical and/or economic limitations.
3. The historical resources impact assessment report will be reviewed by the Historical Resources Division, Alberta Culture, prior to the commencement of land surface disturbance by the development, which will accept, reject or request modifications to the report and its recommendations as appropriate.
4. The development will be permitted to proceed in accordance with the recommendations of an acceptable historical resource impact assessment report, provided such mitigative measures as are deemed necessary are carried out in advance of any possible modification, damage or destruction of the said historical resources.