Comments on the BC Ministry of Water, Land and Air Protection's Coalbed Methane Produced Water Code of Practice Intentions Paper

In late December 2004, the Ministry of Water, Land and Air Protection provided West Coast Environmental Law (West Coast) with its Code of Practice Intentions Paper [Code of Practice for the Discharge of Produced Water from Coalbed Gas Operations] for comment. The Intentions Paper is a summary document outlining the Ministry’s proposed Code of Practice.

West Coast welcomes the opportunity to provide comments; however, a limited process is no substitute for full, transparent involvement of citizens and non-governmental organizations around the issue of coalbed methane development in British Columbia.

West Coast has assembled two documents which comment on the Intentions Paper or proposed Code of Practice:

1. A Technical Review of the Intentions Paper, prepared on behalf of West Coast by the Center for Science in Public Participation and
2. This report, which reviews the Intentions Paper in light of West Coast’s Checklist for BC Code of Practice for Discharge of Produced Water from Coalbed Gas Operations – released in August 2004. Our comments respond to the questions that we asked in our Checklist in anticipation of the release of a Code of Practice.