An essay from the same shelf of documents as The TIER Files. Sources at the bottom.
The Office of the Auditor General keeps a running list of recommendations it has made to Alberta ministries and has not yet closed. The list is public, updated with each major report, and dull in the way that important ledgers are dull. In the Report of the Auditor General for December 2023, the Ministry of Environment and Protected Areas sat at nineteen outstanding recommendations. Eleven of those were older than three years. One lineage traced to October 2008.
That is the number this site’s topic list picked up, and it was correct for that snapshot.
It is no longer the live number.
In the Auditor General’s December 2025 report on the province’s 2024-25 consolidated financial statements, Environment and Protected Areas sits at thirteen outstanding recommendations. Nine are older than three years. Two carry a status the office uses sparingly: Not Implemented. That status means the department previously accepted the recommendation and has since told the Auditor General it no longer plans to implement it. The recommendation stays on the outstanding list because the underlying risk, in the Auditor General’s judgment, remains.
Nineteen became thirteen. Two of the thirteen are refusals that stay on the list.
Thirteen is better arithmetic than nineteen if you are keeping score on closures. It is a messier story if you read the two refusals.
What the thirteen still say
The current list is a portfolio of unfinished systems work. Three July 2024 recommendations concern surface water: when to set and update water conservation objectives, how licences and compliance monitoring work, and what the public gets to see about use and allocation. Three March 2022 recommendations concern pesticide management. Two June 2021 recommendations concern environmental liabilities, including who cleans up when a private operator is gone, and case-by-case assessments shared with the Alberta Energy Regulator. Oil sands monitoring annual reporting, originally November 2018 and repeated in March 2023, is marked ready for the Auditor General’s assessment. Wetland replacement controls, originally April 2010 and repeated in 2015 and 2021, are also ready for assessment, which means management asserts progress and the office has not yet verified it. Fifteen years is a long time to wait for a verification visit.
Sitting among them, for readers of this site, is a December 2023 recommendation that belongs next to The TIER Files: that Environment and Protected Areas implement a process to collect underpayments to the TIER Fund identified through its review of industry-submitted information used to calculate emission obligations. In the December 2023 narrative, the Auditor General described errors found in facility-specific benchmarks, including an underpayment on the order of thirty million dollars. As of the December 2025 ministry chapter, that recommendation is still not ready for assessment.
A compliance system that can find an underpayment and lacks a settled process to collect it is a system with a known leak. The fund’s audited statements already show how little of the cash window becomes grants. Leaving identified underpayments uncollected is a second, quieter problem in the same plumbing.
The two that became permanent
The December 2025 assessments of implementation are where the tone changes.
On flood mitigation, three of the four March 2015 recommendations are implemented: mapping updates, flood-risk assessment, and project-assessment improvements. The fourth, to designate flood hazard areas and complete floodway development regulation, is Not Implemented. The departments say they will rely on existing measures. The Auditor General reports no evidence those measures work as claimed, and no plan to monitor outcomes. Municipal Affairs declined to provide its risk analyses, citing privilege. The office says that left the report incomplete on a matter of public interest.
On the Mine Financial Security Program, originally July 2015, the Auditor General assessed the design recommendation as Not Implemented because the calculation method continues to overstate the economic value of mining assets and the department stated it will not make further substantive changes. The department asserts the method is reasonable and the program is functioning as intended. The Auditor General reports finding no evidence to support those claims.
I read public audit reports for a living on this site, and those reports now say something rarer than delay. They say the department has chosen to leave specific risks on the books and to say so out loud.
How to read a shrinking list
Recommendation counts move. Items get implemented, repeated, transferred after ministry reorganizations, or closed for changed circumstances. Between December 2023 and December 2025, sand-and-gravel recommendations that carried the 2008 origin date left the Environment and Protected Areas outstanding list, three flood items closed as implemented, and the surface-water trio arrived. The net fell from nineteen to thirteen.
That is real progress on some files. It is also how a ministry can look busier at closing recommendations while two of the hardest ones convert from overdue to refused. The Auditor General’s device of keeping Not Implemented items on the outstanding list is the right accounting choice for a reader: the risk did not leave with the department’s refusal.
If you want a single sentence for the TIER season ahead: the department that administers the industrial carbon fund still has an open Auditor General recommendation on collecting underpayments it has already found, and the same ministry now carries two recommendations it has formally declined to implement. The story is in the status column.
If I have misread a status, a page cite, or a date of origin, show me and I will correct this. The live OAG recommendations list can move between reports; the cites below are the December 2023 and December 2025 published snapshots.
Sources
- Report of the Auditor General - December 2023, Environment and Protected Areas chapter and government-wide recommendations table (19 outstanding; 11 older than three years), oag.ab.ca PDF.
- Audit of the 2024-2025 Consolidated Financial Statements of the Province of Alberta - December 2025, Annual Summary of Recommendations and Environment and Protected Areas chapter (13 outstanding; 9 older than three years; 2 Not Implemented), oag.ab.ca PDF.
- Flood Mitigation Systems - Assessment of Implementation, December 2025, AOI PDF.
- Mine Financial Security Program - Assessment of Implementation, December 2025, oag.ab.ca report page.
- Surface Water Management performance audit, July 2024, oag.ab.ca PDF.
- Working dataset for this essay held with the investigation notes.