SAGE is a leading voice for a healthy and environmentally sustainable community.
SAGE submission to the Coal Policy Committee
June 9, 2021
Published in The Lethbridge Herald
04 June 2021
Getting Serious About Global Warming and Climate Change
The Canadian Net-Zero Emissions Accountability Act (Bill C-12) recently passed second reading in parliament. Though the science of climate change has been well established since the 1980s, and the first consensus report from the Intergovernmental Panel on Climate Change (IPCC) was published in 1990, there has been little achieved globally to meet the necessary zero-net-emissions of greenhouse gases by 2050. This is also reflective of the Canadian response, as we have neglected to meet any emission targets these past three decades. We are speaking here of a ritual of failure.
What does ‘net-zero’ really mean? To use a house as an example, ‘net-zero’ would mean that your home would generate as much energy as it uses (for heating and electricity). To accomplish this in a home, you would first try to minimize wasted energy (turn off those lights, and turn down the thermostat when you are not at home). You might then invest in improved efficiencies, like better windows, insulation, and high-efficiency furnaces and water heaters. To achieve net-zero, you would then invest in solar panels (or buy ‘green’ electricity) to provide the remaining energy consumed in the home.
Net-zero for a whole country is manifestly more complicated. A national framework would work roughly like the home – reduction, achieve efficiencies, and shift to renewable energies. But it gets more complicated when carbon offsets like sequestration and Clean Development Mechanisms (CDMs) are introduced. Carbon offsets allow companies or whole sectors of the economy to pay other companies to reduce emissions or sequester carbon in the soil or underground.
On a personal level, for example, one might decide to fly to Europe on vacation. Your share of the flight would produce 0.11 kg CO2(eq) for each kilometer. A round trip from Calgary to London (14,000 km) would produce about 1500 kg CO2(eq). Through a carbon credit process, you would now pay a company who has permanently removed (sequestered) that amount of carbon from the atmosphere, or a company that has purchased a more efficient technology that has prevented carbon emissions to the atmosphere. The result is a net-zero emission of greenhouse gases.
On a larger scale, whole industries that find it difficult to reduce their carbon emissions may pay other industries for sequestering carbon, or implementing technologies to reduce carbon emissions.
As an example of carbon sequestration, a farmer might be credited with carbon offsets for agricultural techniques that keep more carbon in the soil. The farmer could then sell these credits to a company that produces emissions – the sequestration in one area balances the emissions in another (the result is ‘net-zero’). Other schemes might include tree planting (biosequestration) or technologies that remove carbon from a smokestack or directly from the atmosphere. In general, carbon sequestration allows for some continued use of fossil fuels, as long as the equivalent amount of carbon is removed from the atmosphere.
Similarly, Clean Development Mechanisms (CDMs) allow a Canadian company to pay for the emission reduction on behalf of another company (anywhere in the world), with Canada getting credit for the reduction. It might benefit the emerging economy by lowering pollution, and it would be less expensive for the Canadian company compared to other available options. This extra complexity, however, requires more bureaucracy to validate and account for carbon offsets, and it allows for wealthy nations to continue business-as-usual emissions and meet targets by simply buying it – a carbon indulgence.
Obstacles and concerns around carbon offsets include ‘additionality’ (assessing if the carbon offset scheme is something that otherwise would not have been done) and ‘permanency’ (to be sure what is taken out of the atmosphere remains out). There is a concern about ‘carbon leakage’ where a country off-shores polluting industries to less developed countries, which doesn’t really reduce global emissions, but makes one country appear to be making gains at the expense of another. From the perspective of international trade, if one country has more opportunities for carbon offsets (or if they are not aligned with global emission reduction targets), they may have an unfair competitive advantage. This would require complex negotiations and possibly confrontational tariffs. Some sectors of the economy will have more difficulty reducing emissions than others, affecting profitability and future investment decisions, and possibly creating shortages in important industrial or building supplies. The costs of reducing carbon emissions may also fall more heavily on developing nations or the poor within developed countries, allowing unequal advantages to those who can afford to pay for carbon offsets. In a word: Complicated.
Bill C-12 is an aspirational effort to set an accountability framework and targets to reduce greenhouse-gas emissions. The legislation proposes that the federal Minister set five-year targets beginning in 2030 to achieve net-zero by 2050. The Minister is expected to meet international commitments with an emission reduction plan based on the best scientific information available. If it sounds loosey-goosey, it is. The Climate Accountability Act is short on details, but obliges Canada to plan a framework for climate action. It is a first step. And it is an important first step.
It is an important enough first step that Bill C-12 requires non-partisan support and thoughtful improvement before the Third Reading in parliament. And it will need effective plans to be developed over the following six months to achieve targets while transitioning good jobs to a future economy. As we have learned by ignoring this issue for three decades, the longer we wait that harder it will be. As Ecojustice has said: “Net-zero by 2050 will ensure Canada’s fair share contribution to keeping global temperature rise below 1.5 C.”
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Albertans Want to Know How to Manage the Demand on Limited Water Resources
Published in Lethbridge Herald
13 May 2021 (link)
Editor: The UCP government’s “sector by sector approach to economic stimulus” (Lethbridge Herald 30 April 2021 MLA Neudorf presents party’s sector-based approach for economic recovery) is out-of-date, and out-of-step.
It is this narrow focus on promoting one industry absent a broader land use, environmental, social and public interest context that made Alberta a petro-state and has brought the current frenzy of opportunistic proposals for coal exploration and extraction in our Eastern Slopes.
Thankfully many Albertans think more broadly.
The public conversation about coal, in spite of government attempts to constrain it, has expanded to include long-term impacts of open-pit coal mines on tourism, recreation, human health, biodiversity and climate. No topic has evoked more concern than impacts on water. Water flowing down from headwater tributaries to the rivers of semi-arid southern Alberta and on to Saskatchewan is arguably our most precious natural resource.
Water is the life blood of another industry sector being narrowly targeted for UCP government stimulus – irrigation agriculture. The province’s announcement in fall 2020 of an $815 million deal with the Canada Infrastructure Bank and eight irrigation districts in the Bow River and Oldman River basins boasts plans for new pipelines, reservoirs and a 15 per cent increase in irrigated acres. The amount of water needed to irrigate an additional 208,000 acres of cropland dwarfs the amount that would accommodate coal mine development.
Irrigation agriculture over the past 120 years has acquired licenses to withdraw over half of the mean natural annual flow in the Oldman River and Bow River that converge to form the South Saskatchewan River. This one sector controls three quarters of all water allocated in these basins. Because of over-commitments, since 2006 no new allocations have been allowed for any purpose because of risk of shortage for meeting existing commitments including a requirement to pass half of mean natural annual flow to Saskatchewan.
Rivers in southern Alberta are suffering from huge amounts of water extracted by the irrigation agriculture sector especially during prolonged dry periods. With climate change, stress on rivers is predicted to increase as is the risk of shortage to meet existing licensed allocations and accommodate future population and economic growth.
Broad-thinking Albertans are asking how best to manage demand on our limited water resources to reduce, not increase, environmental, social and economic risk today and in the future. Were these impacts or forgone opportunities for other sectors of our economy considered in government’s decision to focus on stimulating expansion of the irrigation agriculture sector?
Those of us who have asked are still waiting for answers.
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Time to Step Up and Protect Our Water
Published in The Lethbridge Herald (Link)
28 April 2021
The government of Peter Lougheed implemented the Coal Policy after substantial consultation and expert review over a period of four years. They decided to restrict coal development in the mountains. Their conclusion was that the Eastern Slopes were vital to the economy and the well-being of human population because this region was the primary source of clean water for the province.
Minister Nixon assures Albertans [Government Will Continue to Protect Alberta’s Water, Lethbridge Herald, April 17, 2021] that the water is being protected and that the rules remain unchanged. This assurance is difficult to reconcile with the numbers. The Oldman Allocation Order (Section 3) provides that an allocation may only be made for one of seven purposes (municipal, commercial, recreation, community water supply, agriculture, irrigation and industrial purposes). Allocations of water for industrial purposes must not exceed 150 acre-feet, per this order.
For context, let’s remember that this government negotiated with Australian coal mining corporations (seemingly outside of public enquiry) and rescinded the 1976 Coal Policy without notice and without consultation with Albertans. They then opened the Eastern Slopes to coal leases and immediately permitted temporary licenses for removal of water (outside of the allowed allocation) for exploration. After massive expressions of public outrage, they reinstated the Coal Policy … well, except for the already leased lands and without addressing the Grassy Mountain and Tent Mountain coal mining projects already put in process. There appears to be no cost-benefit or net-jobs analysis for this fixation on coal mining.
For the Grassy Mountain project alone, Benga Mining Limited has applied for the total 150 acre-feet allowed in the Oldman Allocation Order. In addition, they have requested 100 acre-feet to be transferred permanently from a water license held by Devon Canada (diverted from the Crowsnest River) and 200 acre-feet transferred temporarily for 25 years from a license for municipal purposes held by Blairmore (diverted from York Creek). This is for only the one mine. Where will the water come from for mining the leases that have already been sold? What will the impact be on all of these small creeks when large volumes of water are removed? Is this what Minister Nixon was saying?
The UCP government has promised Albertans a consultation process for a new Coal Policy. The Terms of Reference for this consultation does not include water allocation. It also does not include a discussion on potential water contamination (like selenium, arsenic or calcite). It does not include a discussion on parks and other recreational uses on public land, and it does not include a discussion on future economies based on tourism (assuming there are tourists interested in industrial landscapes). The UCP government wants this process done by the end of the year – which is nothing like the robust process used by Premier Lougheed. Does this sound like protecting anything (except coal mining)?
So, you can see nothing has changed. The UCP government is driven to divert public attention using a faux-consultation while they continue to entrench coal mining along the Eastern Slopes. There are no apparent plans for protecting the quality or quantity of water needed by Albertans and an agriculture-based economy. All this cheap land and free water to mine coal for a 1% royalty. And all this without a risk analysis for lost jobs and other costs in the downstream economy. It brings to mind the adage about selling one’s birthright for a mess of pottage.
It is time, Lethbridge, to step up and protect our water.
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Oh, the wonderful things about green bins
Published in the Lethbridge Herald
22 April 2021
Lethbridge residents: You and I produce a lot of garbage, more than the national average. But we don’t have to; half of what we dump into a giant hole next to the Oldman River north of town is useful organic material that could become compost.
But what’s the big deal? Why should you, dear citizen of Lethbridge, care about putting organic materials like banana peels or your lawn clippings into a big hole? The answer is the methane produced by landfills. Methane is a greenhouse gas 25X more warming than CO2. Landfills are a major source of air and water pollution.
Perhaps you are thinking: “I don’t care about global warming.” Well, even though we disagree on that point, we have great news! There are many other reasons to get behind composting that have nothing to do with climate change.
Are you an avid gardener, but tired of trips to the yard waste depot? Green carts can take most of your yard waste AND things from your kitchen that back yard composters can’t handle. Things like those turkey bones you made soup from after you ate turkey sandwiches for a month because nobody could come over for Thanksgiving because of COVID.
Do you know any farmers or gardeners? Maybe you are one. Compost contains loads of valuable nutrients like NPK (ask a farmer) and other things plants need and people pay for. It also contains carbon and bacteria that improve soils.
Do you hate how full your garbage cart is with alternating week pick-up? Or maybe you have space but you gag at the way it smells after 2 weeks in the summer sun? Green cart pick-up would be weekly all summer, and that extra space in the black bin would leave more room for garbage (kidding). Separated and ventilated organics in the green bin won’t make you retch. Rotting without oxygen smells… well… like farts, but rotting with oxygen smells like soil.
Maybe what does concern you is Lethbridge’s honour. You may recall that we were the last city our size in Canada to get curbside recycling. What is going on? This is a community of pioneers and trail-blazers. You want the best for this city and you think we should be at least as good as Calgary, Coaldale and even Taber (yep, all composting). Composting is so obvious, even the bureaucrats and politicians up in Edmonton are figuring it out. Now, hold onto your Stetson, even Red Deer is composting! If civic rivalries are big for you, you may be thinking: “Gosh-darn-it we are not going to be last again!”
Well, good news! The city has a plan ready to go that could have us composting in Lethbridge within 2 years. And there are still cities to beat! If we do this now, we can thumb our noses at those bumpkins in Regina and Winnipeg, tsk-tsking that they still throw organics into the dump.
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Published in The Lethbridge Herald
24 March 2021
Metallurgical Coal – What is it good for …?
The eastern slopes region of Alberta is the source of the headwaters providing fresh water for wildlife and prairie communities living downstream. It has been a highly desirable destination for tourism and year-round recreational activities like camping, hiking and skiing, attracting residents and revenue. Despite vague assurances from the UCP government, allowing coal mining along the eastern slopes is still very much under consideration.
We have become more aware of the environmental impacts of mountaintop removal methods of coal extraction –risk to endangered wildlife, noise, air pollution and water pollution – but we haven’t heard much about greenhouse gas emissions. There is the perception being circulated that ‘metallurgical’ coal is somehow different and less damaging to the environment compared to ‘thermal’ coal. This is not the case. Coal is classified from high-carbon anthracite, to bituminous, to subbituminous, to lower carbon lignite. The final application (steel making, cement making, electricity generation, etc.) of coal depends on process requirements and economics. Steel making has traditionally used the higher-grade bituminous coal which is further processed into a porous mass with fewer impurities – this is called coking coal. In the end, however, the coal is burned and emissions are generated.
The dominant method of making steel is the blast furnace/basic oxygen furnace process. Coking coal is used to reduce iron ore in a blast furnace to make pig iron. The carbon remaining in the pig iron is then burned off using oxygen to make steel. For each tonne of steel about 770 kg of metallurgical coal is consumed, resulting in 1.73 tonnes of carbon dioxide emitted to the atmosphere. Worldwide, this amounts to over 2 billion tonnes of CO2 emitted for steel making each year. This sector is the second highest emitter of greenhouse gases in the world (after concrete making).
The Grassy Mountain Coal project alone (and there may be others) is expected to produce 4.5 million tonnes of coal each year for the next twenty-five years. This mine will ultimately contribute roughly 8 million tonnes of CO2 emissions each year – equivalent to almost 2 million cars. Opening up Alberta for coal mining is incongruous with global efforts to achieve net-zero greenhouse gas emissions within thirty years (let alone reducing emissions by 40% by the end of this decade). The UN Environmental Programme has recently stated that coal use must be phased out in all sectors to moderate the emerging climate crisis.
Are there alternatives? Yes. Though steel is a highly recycled material, still over 20% of it ends up in the landfill. Recycled steel contributes considerably fewer emissions. Also, new technologies for steel making are replacing metallurgical coal with hydrogen as a fuel. It still takes energy to make hydrogen, but it is cleaner to use overall than metallurgical coal. Using traditional electricity sources to make hydrogen, emission reductions of 20 to 30 percent are immediately achievable. Using renewable energy technologies to produce hydrogen for steelmaking can potentially reduce emissions by 80%. These technologies are operating in pilot phases in German, Sweden and Finland.
With the world turning its attention to meeting reduction targets in greenhouse gas emissions, it is an inauspicious time to begin to open up our eastern slopes to coal mining. The steelmaking industry is directing its attention to reducing its emissions by using new technologies that no longer rely on metallurgical coal. This is yet another reason it is not the time for Alberta to engage in coal exploitation. Alberta needs a future-oriented economy.
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March 16, 2021
To: The Honourable Jonathan Wilkinson, Minister of Environment and Climate Change
RE: Federal Review of Montem Resources’ Tent Mountain Project
The Southern Alberta Group for the Environment (SAGE) requests that the Minister of Environment and Climate Change designate Montem Resources’ Tent Mountain Project for an impact assessment under section 9(1) of the Impact Assessment Act, SC 2019, c28, s1.
The Tent Mountain Project should be designated for a federal review because:
- The designed production rate for the production is 4,925 raw tonnes per day, which is only 1.5% short of the 5,000 tonnes per day threshold set out in s.18(a) of the Physical Activities Regulations, SOR/2019-285. Since this is a doubling of the production rate compared to the previous operator in 1983, it is our perspective that the projected production rate of 4,925 raw tonnes per day meets the spirit of the Physical Activities Regulations.
- The potential impact on species at risk, including the Westslope Cutthroat Trout, designated as Threatened in Schedule 1 of the federal Species at Risk Act. The grizzly bear is a species of special concern under Part 4 of the Species at Risk Act; and the Whitebark pine is listed as an Endangered Species under Part 2 of the Species at Risk Act. This project may adversely impact these species and others in this ecologically important region of the Crown of the Continent in southern Alberta.
- It should be acknowledged that since the mine stopped operations in 1983 there has been a growing body of scientific knowledge related to cumulative effects, water pollution, air pollution and the ecological impacts of industrial activities. Due to the lengthy interregnum in coal production, this science should be reviewed and considered in the approval process. A similar process for the Grassy Mountain Coal Project is currently being conducted by a Joint Review Panel. The science presented in this process should apply to Montem Resources’ Tent Mountain Project, particularly as it relates to the cumulative effects of allowing these projects and other mountaintop coal removal leases approved in the region.
- Similarly, the Constitution Act of 1982 and decisions by the Supreme Court of Canada have directed that there is a ‘Duty to Consult’ First Nations on projects that adversely affect their ability to practice Aboriginal and Treaty rights in the region, which is under federal jurisdiction.
- SAGE has been a long-term advocate for the environment in the region that encompasses the Oldman River watershed. We are very concerned about the potential for water contamination from mountaintop removal coal projects in our headwaters. These waters sustain downstream communities and water-dependent industries from the mountains to Lake Winnipeg. It is important that there be greater federal evaluation and oversight of interprovincial waters: Saskatchewan and Manitoba should be considered important stakeholders given the risk of pollution.
- Finally, we believe that there is an obligation to act on global climate change and honour our commitments made at the Paris Accord, and respond to reports from the UN Environmental Programme (UNEP) that advocate for all nations to ‘kick the coal habit’ in global efforts to limit global warming and moderate the climate crisis.
SAGE understands that the Alberta Energy Regulator (AER) will require a provincial Environmental Impact Assessment for the Tent Mountain Project. We believe, however, that the long-term impacts to Canadian interests and the important aspects under federal jurisdiction, as discussed, should be considered by the Minister of Environment and Climate Change.
We look forward to your decision.
It's our river, but who gets the water?
Published in, Lethbridge Herald
25 February 2021
Water should be a top priority for everyone living in semi-arid southern Alberta. How much do you know about our water supply? Most of us know that residents of Lethbridge pay the city to pump, filter and chlorinate water from the Oldman River so that it flows from our taps on demand. We pay for it, so it’s ours, right? Nope. Technically, the water belongs to the crown and we are water ‘users’, not ‘owners’. Over many years, our government has developed rules for sharing this limited resource. With minor exceptions, you need a license to take water out of the river. Currently, in an average year, 68 percent of the Oldman River’s water is allocated for diversion. Since at least 50 percent has to pass into neighboring Saskatchewan, we often rely on water stored in reservoirs from the previous year. A series of dry years means water shortages for license-holders. This has important consequences for us and the health of our environment.
To fully understand our situation, a brief history lesson is in order. Originally, early settlers came from wetter regions accustomed to being governed by ‘riparian rights’ where you could use any water adjacent to your property as long as supply downstream wasn’t changed much. The arrival of the CPR brought major agricultural settlement in the early 1880’s. Partly due to a severe drought in 1887, urgent interest in irrigated agriculture drove the need to formalize water regulations. The federal Northwest Irrigation Act of 1894 recognized ‘prior appropriation’, and assigned water rights according to the seniority of a diversion with some government discretion. An assortment of early irrigation companies and co-operatives staked claim to water allotments. The province took over jurisdiction in 1930 (just in time for another drought), and the Water Resources Act was enacted in 1931. This act set rules for water licensing allocations and priority (‘first in time, first in right’) with each license specifying a purpose for use of the water, the point of diversion, and the rate or total volume of the diversion.
For the next 60+ years, allocations continued to be licensed, mostly for irrigation agriculture, without much thought given to supply limits or environmental impacts. In 1969 an interprovincial agreement was reached that requires Alberta to pass one-half of the natural flow of east-flowing rivers and streams to Saskatchewan. In 1991, when water managers grew concerned that we may not be able to honour that agreement, a cap was placed on allocations within southern Alberta rivers. The Water Act was revamped in 1999 so that the province could close basins to new licenses and allow the transfer of allocations among different users, with a provisional 10% holdback for conservation of rivers whose health was degraded by over-allocation.
The next prairie drought in 2001/2002 highlighted situations of over-allocation and helped spawn the Water for Life Strategy in 2003 to address issues of un-sustainability, particularly drawing attention to environmental degradation. The South Saskatchewan River Basin (SSRB) Water Management Plan (WMP) was released in 2006 along with closures to new allocations from the Oldman, Bow and South Saskatchewan rivers and their tributaries except through transfers from existing licenses. This new water marketing opportunity activated the transfer of unused allocations, effectively intensifying water use with minimal environmental benefit.
Scientists, multi-stakeholder groups, and all forms of special interest alliances have been trying for years to stretch our shared water to supply every conceivable use. So, here we are in 2021, and water managers have their work cut out for them. We urgently need to appreciate the value and limitations of our water supply and the growing market pressure it is under. Now is the time to prioritize conserving instream flows to protect river health as an essential part of managing long-term sustainability.
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Parks, Recreation and Coal Mining
The eastern slopes region of Alberta is recognized as important habitat and a migration corridor for wildlife ranging from Yellowstone to the Yukon. Roughly 53,000 square kilometers of this corridor has been opened to coal mining by the UCP government without public consultation, and seemingly without consideration.
This region is the source of the headwaters, it is an important carbon sink, and it preserves local biodiversity. It has also been a highly desirable destination for tourism and year-round recreational activities like camping, hiking and skiing, attracting residents and revenue. Can we have both coal mining and natural areas for wildlife and nature-based recreation?
The decision by the UCP government to open mountaintop removal operations for coal mining will destroy large areas of wilderness, including river valleys that represent remaining habitat for some species-at-risk. Extensive industrial traffic, noise and water pollution will impact wildlife habitat and human use for distances well outside of the coal mining operations, particularly downstream. In addition, continued coal extraction perpetuates reliance on the fossil fuels that contribute heavily to global greenhouse gas emissions.
Very large areas of public land are now open for coal exploration, and leases for coal mining operations have already been sold to foreign corporations for a pittance. It has been reported that one-third of the Oldman North provincial recreation area is covered by a coal lease with a proposed mine pit on the north border of the recreation area. Other popular recreation areas that are surrounded by coal leases include Livingstone Falls, Honeymoon Creek, Racehorse and Dutch Creek.
A recent research article titled, ‘Identifying key ecosystem service providing areas to inform national-scale conservation planning’ developed new methods that integrate measures of the capacity of ecosystems to provide services (like carbon storage, clean water and nature-based recreation) with indicators of human demand. The paper identified ‘ecosystem hotspots’ in Canada that ‘should be the focus of conservation actions.’ One hotspot identified was the British Columbia-Alberta border, based on wilderness recreation.
This report suggests that a complete management planning framework would include aspects like biodiversity and ecosystem functions and services (including the provision of freshwater but also flood mitigation and soil retention). Management planning would also respect cultural and social impacts of significant land-use changes like coal mining.
The UCP government has suddenly decided to open the eastern slopes to coal mining after 45 years of protection. Considering the long-term risks to our region and the economic development options that have been sacrificed, such as nature-based tourism, this decision demanded, at a minimum, robust public consultation, sound economic analysis, and careful scientific study. Albertans got none of this.
We encourage you to share your opinions on this topic with your MLAs. The Southern Alberta Group for the Environment is a leading voice for a healthy and environmentally sustainable community. For more information, visit our site at sage-environment.org
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Radon Risks in your Home
As winter has arrived and we shut in for another COVID-19 lockdown, it is timely to consider the health of your indoor environment. An emerging health concern in our homes is a high level of radon.
You may not have ever heard of radon, but it is an invisible, odourless, tasteless, radioactive gas formed by the disintegration of radium, which is a decay product of uranium found in the soil. Radon can enter a home from the surrounding soil and accumulate over time, particularly in spaces that are not well ventilated.
Radon is considered the second leading cause of lung cancer in Canada. The Canadian Lung Association states: “As radon breaks down it forms radioactive particles that can get lodged into your lung tissue as you breathe. The radon particles release energy that can damage the cells in your lungs. When the cells in your lungs are damaged, there is the possibility of developing lung cancer. If you smoke and you live in a home with a high level of radon, you are at an even higher risk for lung cancer.” Radon is a long-term health hazard in your home.
Lethbridge is in a zone with a high potential for radon, though the actual levels can vary widely between areas and even from home to home. The amount of radon accumulating in a home will also depend on how much fresh air moves through. Some older, leakier homes and those with mechanical ventilation systems may have lower radon levels compared to newer, tightly built homes that trap the air better. The thing is, new or old, tight or leaky, you can’t really know until your home is tested.
In the latest version of the National Building Code of Canada, new homes are to be designed for future radon mitigation, if required. Testing for radon levels is also becoming more common in real estate transactions. And that is the good news: through the Canadian National Radon Proficiency Program (C-NRPP) there are more trained professionals in the region, and radon has never been easier to test for and to mitigate.
A trained technician can conduct a short-term test for a current indication of radon levels in your living space, but it is important to know that a long-term test of three to five months is required for accurate results. These long-term tests involve a small device that is left in your living space for the duration of the test. If your radon levels are above the current health safety guidelines of 200 becquerels you would be wise to plan for mitigation with the advice of a trained professional. The winter season is an optimum time to test for radon because it is the period when windows and doors stay closed – consider a professional test as the ultimate present for your friends and families!
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December 14, 2020
To: Nathan Neudorf, MLA Lethbridge-East
cc: Shannon Phillips, MLA Lethbridge-West
Joint Review Panel: Grassy Lake Coal Mine
RE: Coal Mining in the Oldman River Headwaters & Water Abstraction
The Southern Alberta Group for the Environment (SAGE) is greatly disappointed with the UCP government’s unilateral decision to open another 2000 hectares of land in our headwaters for coal extraction. It defies comprehension that this lease offering would be advanced just after the public hearing on the Grassy Mountain Coal Project concluded and prior to the Joint Review Panel making its recommendations.
Proceedings of the Joint Review Panel hearing for the proposed Grassy Mountain Coal Mine include serious, deeply concerning issues regarding impacts on water and air quality, human health, adjacent residents and local communities, indigenous traditions, wildlife habitat and migration corridors, species-at-risk, a nascent ecosystem-based tourism industry, as well as the availability of water for the ecosystem and downstream users. There are lessons to be learned from over two dozen sound scientific studies in the Appalachians which found that mountaintop removal mining devastates ecosystems, pollutes water and air, and negatively impacts public health including statistically significant increases in rates of cardiovascular disease, kidney disease, chronic lung disease, cancer, birth defects and death.
The UCP government has recently indicated its intention to bypass established water transfer markets in the Oldman River Basin to make allocations freely available to coal companies. Bypassing established processes and expectations for water allocation and abstraction in order to expedite coal mining, without public consultation, undermines trust in fair dealings with the government. In economic terms, perceived unfairness and an additional degree of uncertainty in the equity of exchange practices increase transaction costs to industry.
The UCP machinations around water policy and allocation appear to be motivated by the proposed Grassy Mountain coal mining application: one wonders what this government has in mind to provide the required water for another 840 square kilometers of open-pit coal mining operations currently being offered? It raises questions on what other accommodations have been promised to potential bidders, which may do more to inflame rather than reduce the existing climate of concern and uncertainty about coal mining in our headwaters. As with the decision to rescind the coal policy it shows a flagrant disregard for public opinion, due consultation processes and outcomes of regional land use and water management planning.
Finally, and of most concern, significant water pollution has been measured in the Elk and Fording rivers downstream of extant coal mining operations, with evidence of negative impacts on aquatic ecology and sources of drinking water. There is no indication that there is the long-term will or the technology for the coal operators to cost-effectively remove contaminants from the water before they enter our river systems. Some of these contaminants will threaten species-at-risk and may cause enduring, bio-accumulative impacts on downstream use, including natural ecosystems, municipal drinking water, irrigation and intensive livestock operations. In other words, there is no point trading temporary gains for permanent losses for a livable future in the region.
In summary, the unilateral decision to promote coal mining on the Eastern Slopes and in our headwaters risks the long-term welfare of our economy, our wildlife, our ecosystem and our own health.
The proposal to greatly expand coal mining in our headwaters also requires much greater public consultation; it requires a comprehensive water allocation plan; and it requires greater consideration of long-term cumulative effects of water contamination to downstream users. It should also be emphasized that the decision to sell more coal mining leases prior to the recommendations from the Joint Review Panel is unutterably inappropriate.
Coal, Calcite and Cutthroats
Published in, Lethbridge Herald
26 November 2020
Calcite build-up on streambeds is an environmental hazard of open-pit mountaintop coal mining proposed in the headwaters of the Oldman River. As with selenium pollution, described in a previous article, water flowing through waste rock accumulated during the coal mining process dissolves calcium carbonate and carries it downstream. Unlike selenium, calcium carbonate is not considered a toxic pollutant in water. However, when calcium carbonate reaches a high enough concentration, it solidifies into calcite. The process is similar to the buildup that forms in tea kettles and humidifiers. Calcite coats the stream bottom and, in effect, turns it into concrete. In some cases streambed sands and gravels can only be broken free with hammer blows.
Where calcite accumulates, the stream bottom becomes uninhabitable to invertebrates that form the base of the aquatic food chain. Aquatic plants are smothered. Trout that use an undulating movement to flush sediment and excavate hollows in loose gravels for laying eggs, referred to as redds, can no longer spawn. This is especially devasting to native cutthroat and bull trout, both “threatened” species, federally and provincially.
In reaches where a stream bottom becomes cemented, bank erosion increases causing more sediment to be released and the stream to over-widen. This impact on streams has previously been observed in Eastern Slopes watersheds experiencing a high degree of surface disturbance from logging and other industrial development, including Racehorse Creek and Dutch Creek. Adverse effects on reproduction of native trout have been noted.
Calcite formation is occurring downstream of coal mines operated by Teck Resources Limited in southeastern BC in the Elk River valley. Monitoring has detected increase in calcite over time with 30% of the river and stream channels surveyed in 2018 impacted by calcite at levels higher than background. Recent studies to assess effects on Westslope Cutthroat Trout, a Species at Risk, found density of redds decreased as calcite concentration increased in stream reaches.
Teck, under its permit to operate, is required by Environment and Climate change Canada to reduce calcite levels in mine-affected streams in the Elk Valley. This direction is issued under the federal Fisheries Act. Since October, 2017 the company is experimenting with adding antiscalant (a chemical that inhibits formation and precipitation of crystallized mineral salts) to a stream to inhibit formation of calcite. A geo-synthetic cover over waste rock is also being tried to prevent water leaching of calcium carbonate. Cost of these mitigation measures is estimated to be several hundred million dollars.
The proposed Grassy Mountain Mine north of Blairmore straddles the valleys of two streams that are habitat for Westslope Cutthroat Trout – Blairmore Creek and Gold Creek, tributaries of the Crowsnest River. This native species once inhabited most streams in southwestern Alberta from the alpine to the prairies, but now occupies only a small fraction of its original distribution. A strategy for recovery of its habitat has been developed and is in the process of being implemented. If the mine is allowed to proceed, recovery efforts will be undercut and calcite build-up in spawning habitat would become one more risk pushing this threatened species to the brink of extinction.
More at: The Rockies and Coal Mining
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Selenium's Impact on the Environment
Published in, Lethbridge Herald
23 October 2020
As residents living along the Oldman River anticipate the impacts of open-pit coal mining in our headwaters, we should know more about the potential changes in water quality and their effects on river health and, therefore, our health.
Open-pit coal mining involves the removal of rock that sits above the coal seams that the mining company targets for extraction. This rock, or overburden, is typically dumped into the river valleys near the mine where it is exposed to weathering. It is the weathering process that releases pollutants like cadmium, nitrate, sulphate, iron, uranium and selenium into the environment over time – in the form of particulates in the air but, more significantly, into river systems.
Like some other elements, selenium is biphasic which means that it is necessary for life in small concentrations but becomes toxic to aquatic species in concentrations as low as 1.5 mg/l. Selenium ions are soluble in water, so they don’t settle in containment ponds. When released to the environment, selenium (as selenite and selenides) bioaccumulates in the aquatic system. That is, the selenium increases in concentration as it passes from plankton to aquatic invertebrates to fish that live higher in the food web. As such, fish are an important indicator species for water contamination of this type. Species that consume fish along the food chain, like birds and even humans, are also at risk of the health impacts resulting from higher selenium accumulating in their bodies.
Continue reading at: The Rockies and Coal Mining
How Does Your River Look Today?
Published in, Lethbridge Herald
18 September 2020
The next time you cross the Whoop-up Drive bridge, glance over the edge and consider your Oldman River. What do you see? Ask yourself, 'is there too little or too much water?' and 'should I be concerned?' Take a moment to consider how the flow you see compares with flows during this and other years.
Seasonal and annual variability is the key to understanding river function.
Water is essential for all life; ours and our ecosystems. Our prairie region is naturally treeless. Grasses and hardy shrubs are adapted to the semi-arid climate where regular droughts prevent trees from thriving. The exceptions are the natural woodlands rooted in the moist places next to rivers, streams and wetlands. These plants stabilize soils and support other species that can’t otherwise survive here. The waters themselves are home to diverse aquatic life dependent on the seasonal ebb and flow of precious moisture.
Seasonal water flow ranges are a critical part of the system. During the winter, snow accumulates at higher elevations. As spring arrives, meltwater and rains send a pulse of water downstream. This flow gradually lessens to a trickle as summer heats up. Repeated every year for millennia, this seasonal pattern has shaped life on the prairie and beyond. Daily snows, rains, and temperatures make every year slightly different within a natural range of variability. Occasionally, wet or dry periods set new records in the flow history. These events are often ecologically important as they physically shape riverbanks and encourage or limit dependent species.
The availability of water has likewise shaped human settlements and ingenuity. Our ever-increasing demand for reliable, clean water to supply cities, agriculture and industry has driven the race to capture, divert, and store flow whenever and wherever possible. There are three major dams and numerous other diversions upstream from us. A complex basin-wide model is constantly updated using flow gauges to maximize efficiencies. Under the Alberta Water Act, licenses are used to allocate every drop of water flowing through the system in order to meet downstream needs.
While moderated stream flows are convenient for us, river ecosystems can be profoundly affected by our tinkering. The 'natural flow regime' is fancy-talk for the pattern of quality, quantity, timing, and frequency of non-regulated stream flows. These characteristics are the foundation of river ecology (the relationships between organisms and their environment). Altering the flow regime will cause ripple effects through all dependent landscapes and organisms. Everything from channel movements and soil beds for plant seedlings, to spawning sites for fish and habitat for migratory birds, are all tied to these patterns of flow.
We think of this water as 'ours', but it’s just starting its journey and we are responsible to those downstream. We are at the top of a much larger watershed that eventually drains east into the Hudson’s Bay. In fact, we’re part of the Crown of the Continent where if you look west from Fernie the water heads off to the Pacific Ocean, North of Banff it ends up in the Arctic Ocean, and South of Milk River it flows to the Gulf of Mexico. Population growth, development expansion and climate warming are all growing threats to our limited water resources. We need to recognize the value in protecting our natural flows and variability to keep the whole watershed healthy.
So, 'should you be concerned?'
The answer is 'you bet!'
Continue reading at: Water, Water, Everywhere ... or is it?
See our Letter on Coal Policy and Southern Alberta @ Letters to Government.
Is Mountaintop Coal Mining in the Oldman headwaters worth the Risk?
Published in, Lethbridge Herald
15 August 2020
For the first time in four decades, headwaters of the Oldman River are again under threat from open pit coal mining.
Expansive scars of coal mines on Tent Mountain south of Coleman and Grassy Mountain mine north of Blairmore, projects that fizzled out by 1980, remain stark reminders of companies that left without cleaning up their mess. The Alberta Coal Policy adopted by the Lougheed government in 1976 restricted coal exploration and development along the eastern slopes of Alberta’s Rocky Mountains due to 'marginal economic benefits' and 'important environmental values, such as wildlife migration and headwaters areas'. With rescinding of that policy by the current government, coal companies are back proposing to reopen and expand surface mining on Tent Mountain and Grassy Mountain and explore large areas of mountainous country west of the Livingstone Range north to the Highwood River.
Coal mining, particularly surface mining in mountains, is one of the most brutal assaults by humans on the Earth. The changes in natural landscapes and headwaters ecosystems are profound. Vegetation and soils that have evolved over millennia are stripped to reveal ancient bedrock. Using explosives and some of the largest machines on earth, mountaintops are shattered and removed to expose coal seams. 'Overburden' is dumped into adjacent valleys. Roads are carved into the diminishing mountain sides to haul extracted coal away in giant trucks to valley bottom processing plants. Water falling as rain and snow that was naturally absorbed by vegetation and soil rushes unchecked and unfiltered to valley-bottom streams that become seriously disrupted by altered flows and contaminants. Resident fish and wildlife are destroyed or displaced for untold generations.
John Prine captured for the 60’s generation the profound sense of destruction and loss that is wrought by mountaintop coal mining in his song Paradise – 'Mr. Peabody’s coal train has hauled it away'. To witness the loss of a mountain paradise by coal mining, southern Albertans don’t need to travel all the way to Muhlenberg County, Kentucky but rather can peer across the continental divide into the Elk River and its tributary valleys (including Fording River) in British Columbia. Five massive open-pit coal projects, operated by Teck Resources, have flattened mountains and filled valleys with piles of rubble. Biodiversity has been significantly impacted, including habitats for whitebark pine, Westslope cutthroat trout, grizzly bear and bighorn sheep.
A more insidious impact is the selenium that leaches from the previously buried rock now exposed to air and water. Naturally occurring in soils and plants, selenium is an essential trace element in healthy diets of animals and humans. However at high concentrations selenium can cause neurological disorders in humans, liver damage and paralysis in other animals, and birth defects and reproductive failure in fish. Waterborne selenium can enter the food chain where it bio accumulates. Toxic effects of selenium on aquatic life, fish and birds have been documented in the mountaintop coal mining regions of the Appalachians and more recently the Elk Valley of BC, extending up to 200 kilometres downstream in Montana. Sparwood’s drinking water supply has become contaminated.
Residents of the Oldman River Basin rely on plentiful, clean water flowing from the eastern slopes of the Rocky Mountains for survival and economic well-being including food production. Southern Albertans value our headwaters region for its scenic natural landscapes, wildlife and unsurpassed outdoor recreation and tourism opportunities. Experience elsewhere confirms that mountaintop coal mining places all that at risk. Albertans in the 1970s, based on experience, decided it was not worth the risk.
Why does today’s government think it is?
Continue reading at: The Rockies and Coal Mining.
The Environmental Impact of Meat
Published in, Lethbridge Herald
22 July 2020
Have you ever eaten a “Beyond Meat” burger?
Is it better for the environment than the meat it replaces?
Livestock production for meat consumption is a huge topic, and the best choice for the environment depends a lot on the context: where the livestock was raised, how it was raised and what it was fed.
Livestock that is naturally grass-fed and raised in free-range conditions appropriate for the land use (like grazing lands in Alberta that previously sustained bison) provides meat with a low environmental impact. Unfortunately, we know that most animals for meat production are not raised under these conditions. We also know that as the standard of living for much of the world’s population rises, so does the consumption of meat.
Sustainability is the organizing principle for meeting human development goals while simultaneously maintaining the ability of natural systems to provide the natural resources and ecosystem services upon which the economy and society depend. The global increase in meat consumption is not sustainable. Part of the problem is the social and environmental impacts of industrial-scale agriculture; part of the problem is the inefficient conversion of plant crops to meat; and part of the problem is the environmental impact of intensive livestock operations.
Much of our meat is raised on soybeans, corn and barley as feed. The global increase in meat consumption has been accompanied by large increases in grain and soybean production. One-third of the world’s arable land grows industrial-scale crop monocultures dedicated to feed animals raised intensively for meat consumption. The conversion of rainforests and natural grasslands and the application of fertilizer and pesticides for animal feed is not environmentally friendly – it releases massive quantities of sequestered carbon to the atmosphere and it is wasteful of land, energy, water and clean air.
Meat consumption is mainly driven by culture, tradition and taste. The intermediate step of feeding plant crops to animals intended for human consumption is unnecessary and wasteful. Crops grown for meat production should instead be used to feed humans directly.
Based on calories, six units of feed will convert to one unit of pork, and 12 units of feed will convert to one unit of beef. For poultry, the conversion is 2:1, which makes it a lower-impact source of protein, in general. The inefficient conversion of food energy from plants to meat will make it difficult to feed the human population of 10 billion expected by mid-century.
On Aug. 8, 2019, more than 100 leading researchers released a summary report on climate change and land through the Intergovernmental Panel on Climate Change (IPCC). The report describes plant-based diets as a major opportunity for mitigating and adapting to climate change, and includes policy recommendations to reduce meat consumption. The report states with high confidence that balanced diets featuring plant-based and sustainably produced sources of meat “present major opportunities for adaptation and mitigation while generating significant co-benefits in terms of human health.”
In the last decade, plant-based foods have been developed to create alternatives for those accustomed to the taste of meat.
A “Beyond Meat” burger has 18 ingredients, including: pea protein isolate, canola and coconut oil, rice protein, cocoa butter, mung bean protein, pomegranate fruit powder, and beet juice extract (to give the burger its meat-like “blood”).
Is this an environmentally friendly substitute for meat?
Can we make better choices with our meat consumption?
See More at, Animals & Environment.
Thinking With Animals
Published in, Lethbridge Herald
26 June 2020
In thoughtful times, what Canadian doesn’t turn to Leonard Cohen? Suzanne, the lyrics go, takes you down to her place by the river and ‘feeds you tea and oranges that come all the way from China’.
All the way from China? Yes, for this was written in 1966 when China was reasonably considered far away, both in imagination and geography. Now goods cross international borders, span what we once thought of as vast oceans, fly the (pre-pandemic) crowded skies and arrive in our stores at a fraction of the price of mandarin oranges in Cohen’s era.
But at what cost? What does it cost to curtail production here and take advantage of cheaper labour costs in other lands, to fly fresh produce around the world, and to truck pigs, cattle and poultry across borders as though they were no more sentient than crates of oranges?
If the world seems close and perhaps claustrophobic to us now, we are left to imagine how the walls of civilization close in on the ecosystems of other life forms. Species who once had