Holding oil & gas regulators to account
Alternatives North is challenging OROGO’s proposed Environmental Protection Plan guidelines — calling for mandatory transparency, public reporting, and community oversight of oil and gas operations in the NWT.
↓ Download full submission (PDF)What are Environmental Protection Plans?
When oil and gas operators work in the NWT, they are required to file an Environmental Protection Plan (EPP) describing how they will manage environmental risks. On March 16, 2026, OROGO — the Office of the Regulator of Oil and Gas Operations — circulated revised guidelines and interpretation notes for these plans to select Indigenous governments and NGOs.
Alternatives North was not included in that initial invitation, and is asking to be included in all future consultations. More fundamentally, we are challenging the approach itself: the revised guidelines leave EPPs as almost entirely voluntary documents, with no requirement for public reporting and no mechanism for public review or comment.
“A quick search of the OROGO website revealed no posting of any Environmental Protection Plans or indeed anything with the keyword ‘Plan.’ The guidelines do not require or make provision for any form of public review.”
What we’re asking OROGO to change
Require a public rationale for all guideline changes and regulatory decisions, including when guidelines are not applied to individual cases.
Mandate annual reports on EPP performance, incidents, near-misses, and non-compliance — publicly posted without delay.
Explicitly require methane, GHG, and particulate monitoring. EPPs should address GNWT’s Climate Change Strategic Framework and water use impacts.
Full public disclosure of all drilling fluids and any substances claimed as proprietary, so communities can assess actual risks.
Replace the ALARP (“as low as reasonably practicable”) standard with the Precautionary Principle, given the remoteness and fragility of NWT ecosystems.
Require submission of all referenced codes, standards, and supporting documents — not just references to them — so public reviewers can assess their applicability.
Codes and standards need independent review
The guidelines allow operators to adopt industry codes and standards without any independent verification. Alternatives North is asking OROGO to publicly rule on the applicability of any proposed codes to NWT conditions, and to release the results of any reviews it has already conducted.
Financial responsibility must cover EPP costs
It is currently unclear how an operator’s proof of financial responsibility relates to their EPP. The guidelines should spell out that financial assurance must account for all EPP-related monitoring, reporting, and remediation obligations.
Draft and approved EPPs must be public
OROGO should commit clearly to posting all draft EPPs for public comment and publishing all approved EPPs on its public registry without delay. Currently, there is no such commitment in the guidelines.
What Alternatives North is asking for
- A written response from OROGO to this submission, with copies provided to all other commenters.
- Public posting of all comments received by OROGO, and all OROGO responses to those comments.
- A commitment that approved EPPs will be posted to OROGO’s Public Registry without delay.
- Future comment invitations to include Alternatives North as a matter of course.
- Future public reviews to be conducted through the Online Review System at new.onlinereviewsystem.ca.
This submission was signed by Kevin O’Reilly on behalf of Alternatives North, and copied to the Clerk of the Standing Committee on Economic Development and Environment. A detailed attachment with page-by-page comments on the revised guidelines accompanies this covering letter. Read the full submission (PDF).