Cooperation Plan
Impact Assessment of the Suncor Base Mine Extension Project

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Document Reference Number: 140

May 31, 2021

1. Introduction

On August 7, 2020, the Impact Assessment Agency of Canada (the Agency) determined that an impact assessment is required for the Suncor Base Mine Extension Project (the Project), pursuant to Canada's Impact Assessment Act. Likewise, on February 26, 2020, the Alberta Energy Regulator (AER) determined that an environmental impact assessment (EIA) report is required for the Project, pursuant to the Environmental Protection and Enhancement Act. Suncor will also require approval under various provincial legislation to construct, operate and reclaim the Project.

This Cooperation Plan is prepared and published by the Agency to set out the Agency's intentions for cooperation with other jurisdictions for the assessment of the Project. The AER was consulted during the preparation of this Plan. This Plan is intended to be flexible and does not preclude the Agency or the AER from modifying the cooperative approach described in this Plan in order to accommodate changes that may occur during the assessment process.

2. Description of the proposed project

Suncor Energy Inc. (the proponent) is proposing to develop the Project to sustain the supply of bitumen to the existing upgraders at the proponent's Oil Sands Base Plant operation (Base Plant). The Project includes an open pit mining operation and associated infrastructure that is required to supply oil sands to new bitumen froth production facilities and deliver bitumen froth by pipeline to the existing Base Plant facilities where further processing occurs, including upgrading into various product blends for market. The Project would be located adjacent to existing Base Plant operations, approximately three kilometres north of Fort McMurray, Alberta, within the Regional Municipality of Wood Buffalo. If approved, construction is expected to start in 2026 and the footprint is anticipated to be approximately 30,000 hectares.

For more information on the impact assessment of the Suncor Base Mine Extension Project or to view the information and comments received, visit the Canadian Impact Assessment Registry (the Public Registry) at

3. Approach to cooperation

The Agency will strive to cooperate with the AER to create efficiencies and certainty for all participants, including the proponent, the public, and Indigenous groups, throughout the assessment of the Project. Where possible, the Agency may coordinate activities with the AER, including harmonizing timelines and streamlining processes, in order to best share expertise and reduce redundancies in the review process. Each jurisdiction will retain its own decision-making authority in accordance with their respective legislative requirements.

On January 28, 2021, the Agency announced that the Minister of Environment and Climate Change referred the impact assessment of the Project to an independent review panel. Should the AER review be conducted by public hearing, the Agency will explore the option of establishing a joint review panel with the AER to support the shared objective of "one-project, one-assessment".

A Joint Review Panel Agreement between the federal Minister and the AER would further describe the approach for a cooperative process, such as key steps and applicable time limits, and secretariat support to the joint review panel.

Should a Joint Review Panel not be established, other options for cooperation may also be considered.

4. Review of proponent information

The following table outlines key federal and provincial activities and deliverables for which cooperation opportunities are anticipated to support the review of information submitted by the proponent.

More opportunities for cooperation may be identified and developed at each stage of the regulatory process. The following are examples of how cooperation may be implemented.

Key federal and provincial activities and deliverables

Federal process

Provincial process

Cooperation opportunity

Drafting of the Tailored Impact Statement Guidelines (TISG) by the Agency

The Proposed Terms of Reference will be prepared by the proponent and submitted to the AER.

The Final Terms of Reference for the preparation of the EIA report will be issued by the AER.

The Agency considered the requirements contained in the Proposed Terms of Reference during the drafting of the TISG, in order to harmonize requirements, where applicable.

Meetings with federal and provincial experts have been held to inform the requirements of the TISG.

Preparation of the Impact Statement by the Proponent

Preparation and submission of the EIA report and applications (the Integrated Application) by the Proponent

The Agency and the AER may coordinate meetings with federal and provincial subject-matter experts to support the proponent in meeting the assessment requirements contained in the TISG and Final Terms of Reference.

Review of the Impact Statement by the Agency

Technical review of the Integrated Application by the AER

Completeness of the EIA report will be determined by the AER

The Agency and the AER may cooperate during the review of the proponent's information, including the identification of potential deficiencies and information requests, planning of comment periods, and information sharing.

Review of the Impact Statement by the Review Panel, including public hearings and preparation of its Impact Assessment report.

Public hearing* by a panel of AER commissioners, and decision report writing

*The AER decision to conduct a hearing by a panel typically occurs after the technical review of the EIA report has been completed.

If the AER conducts a public hearing, and a Joint Review Panel Agreement is in effect, the Agreement will outline all matters specific to the joint review process.

The Agency and the AER may consider alternatives for cooperation, should a Joint Review Panel not be established.

General engagement

General engagement

Throughout the impact assessment and application review processes, the Agency and the AER will aim to coordinate engagement activities to increase awareness of their processes, highlight areas for cooperation, and foster meaningful participation.

5. Timelines and time management

The Agency and the AER may align milestones and activities during the assessment process, when appropriate.

The Agency recognizes that efforts to align respective timelines do not supersede legislative obligations concerning time limits, which are prescribed in the Impact Assessment Act, the Environmental Protection and Enhancement Act, and other relevant provincial legislation.

6. Sharing of information

All information relevant to the impact assessment of the Project will be posted by the Agency or Review Panel on the Canadian Impact Assessment Registry. As such, the AER will have access to the public record for the federal impact assessment. The Registry contains all comments and submissions from participants in the assessment, including the public, Indigenous communities, federal departments, provincial ministries, in addition to all information submitted by the proponent.

The Agency will also post on the Registry any relevant information received from the AER (e.g. Supplemental Information Requests).

The Agency and the AER will respect requirements related to privacy and protection, including protection of Indigenous knowledge, when sharing or publicly posting information.

Should a Joint Review Panel be established, provisions regarding the sharing of information and the record of the review will be outlined in the Joint Review Panel Agreement.

7. Indigenous consultation and engagement

The Agency will lead Crown Consultation on behalf of the Government of Canada for this assessment.

For further information on Canada's Indigenous Consultation and Engagement activities, please consult the Indigenous Engagement and Partnership Plan.

8. Proposed conditions

The Agency and the AER may consult with each other regarding conditions related to decisions, to facilitate consistency and improve regulatory efficiencies when appropriate.

9. Interpretation

This Plan is not a legal document and does not change any existing federal, provincial, or Indigenous legislative or regulatory jurisdiction, right, power, privilege, prerogative or immunity by virtue, nor does it create any new legal powers, duties, or legally binding obligations.

10. Contact Information

The Agency's office designated for administering the impact assessment for the Project is:

Impact Assessment Agency of Canada – Suncor Base Mine Extension Project
160 Elgin Street, 22nd Floor
Ottawa ON K1A 0H3
Tel.: 343-549-5813

The AER's office designated for the Project is:

Alberta Energy Regulator
Calgary Head Office
Suite 1000, 250 – 5 Street SW
Calgary, AB T2P 0R4

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