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Shell has applied to increase its oil sands output capacity.

A week after Alberta enacted hard limits on air and water pollutants in its oil sands-rich northeastern corner, Shell Canada published a document that predicts the industry will exceed some of those limits.

In the document submitted to the Canadian Environmental Assessment Agency last week, Shell says oil sands projects with provincial approval will, if all built, push levels of sulphur dioxide and nitrogen dioxide over new provincial thresholds in some areas. The company found that the combination of existing and coming projects threatens to wipe out caribou, acidify nearly two dozen lakes and produce some air emissions higher than regional standards enacted by the government of Alberta on Sept. 1.

Shell is in the midst of an application to expand its Jackpine mine to add 100,000 barrels a day of output capacity. As part of that application, it analyzed the environmental impact of looming oil sands construction, including its own mine, over a vast regional area 22,000 square kilometres in size.

The provincial emissions standards, meant to place a hard cap on the overall environmental impact by industry, were an integral part of a broad Lower Athabasca regional plan that the province announced in August, with assurances the limits would be legally binding.

Now, however, the Shell report projects that if the industry continues on its current course, it will run past annual limits on sulphur dioxide and nitrogen dioxide in the area studied. Those substances contribute to acid rain, and the projection suggests Alberta will be forced to confront whether it is willing to act in the name of the environment, or move the yardsticks to preserve its bedrock industry.

Regulators "will need to start turning down projects to stay under the limits, or they're seriously going to have to ratchet back on the performance of all the existing operators to try to get those pollutants down to levels to enable the industry to grow," Simon Dyer, policy director at the Pembina Institute, a Calgary-based environmental lobby group.

The Alberta government, however, says industry in 2010 and 2011 was within the guidelines, and new scrubbing equipment, combined with emissions rules still being drafted, will help temper future emissions. Shell played down its own numbers.

"Information in the the Jackpine mine expansion application is based on conservative scientific data that assumes all existing and future developments are operating at full capacity simultaneously," a spokesman said in an e-mail.

That information, however, carries legal heft, and is used to determine the acceptability of new projects.

Randall Barrett, northern region director for Alberta's Environment Ministry, said: "We need to be very diligent on what's happening with these new [emissions] sources coming in, and be very diligent with existing sources to encourage continuous improvement."

The Shell document suggests the impact of the emissions will be tangible, identifying 23 lakes that will exceed their "critical load" for acidity.

High acidity can deaden a lake over time. With proper monitoring, impacts can be seen inside of a decade, and "as acidification progresses, eventually all fishes and molluscs are eliminated and biodiversity can be reduced considerably," said David Schindler, a University of Alberta professor who is a leading expert on water in the province.

Though the impact of the Jackpine expansion itself is relatively small against the broad landscape, Shell says between its mine and other projects, some 9e per cent of wetlands and forests in the region will be lost or altered. Animals will also be affected. The Shell document catalogues an expected habitat decline of 34 per cent for barred owls, 13 per cent for beavers, 11 per cent for black bears, 19 per cent for Canada lynx, 49 per cent for Canada warblers, 18 per cent for wolverines and, most strikingly, the potential clearing of woodland caribou, a threatened species, from the area.

"Woodland caribou populations appear to be declining to extirpation," the document says.