Letters to Government
SAGE writes letters to all levels of government; municipal, provincial and federal.
Letters on issues that are recent or unresolved may be posted here, but the list is not comprehensive.
All our communications may also be found in the Newsletters archive.
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For pdf, click here.
January 29, 2017
To: The Honourable Rachel Notley, Premier of Alberta
Cc: The Honourable Shannon Phillips, Minister of Alberta Environment & Parks, Ms. Maria Fitzpatrick, MLA, Mr. Todd Loewen, MLA
From: Braum Barber, Southern Alberta Group for the Environment
Re: Castle Provincial Park and Castle Wildland Provincial Park
The Southern Alberta Group for the Environment (SAGE) would like to thank you for establishing the boundaries of the Castle Provincial Park and Castle Wildland Provincial Park through Orders in Council announced on January 20, 2017. Furthermore, we would like to express our appreciation that First Nations were consulted and have enthusiastically supported the designation of these parks.
We commend the Government of Alberta for its ongoing commitment to protect the Castle with its unique biological diversity and its importance as a source of water for Lethbridge and other communities in the Oldman River watershed.
We also appreciate the clear language in the Vision and Value statements in the draft Castle Management Plan: the commitment to high standards of conservation, the protection of biodiversity including at risk species, maintaining the integrity of riparian areas and wetlands, and the recognition and respect for the land use and values of Indigenous peoples. It also prudently recognizes opportunities for growth in tourism and high quality outdoor recreational uses that will be a social and economic benefit to the region.
SAGE supports the strong position the Government of Alberta has taken on restricting access to off highway vehicles and better managing how people can enjoy camping and other outdoor experiences. Science informed indicators of riparian and wetland health, the integrity of critical habitats, and the impact of linear disturbances provide a sound basis for current conservation decisions and future restoration efforts.
Future generations will value the Castle Provincial Park and Castle Wildland Provincial Park. To paraphrase a wise adage: “Nobody has ever wished we had fewer natural areas.”
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January 29, 2017
To: Mayor Spearman and Council
Re: Community Curbside Recycling
The Southern Alberta Group for the Environment (SAGE) commends the City of Lethbridge for its leadership and commitment to better managing municipal solid waste: by setting strong waste diversion goals, by its dedicated support for diversion in the ICI and C&D sectors, and by its decision to implement community wide curbside recycling.
We understand the complexity of the issues around waste diversion, but we also understand that there are long term benefits to recycling and composting, including the surety of feedstock for future manufacturers, the conservation of non renewable energy and mineral resources, the reduction of pollutants and greenhouse gases to the atmosphere, the protection of fresh water systems from leachate contamination, and the simple fact that it is becoming increasingly difficult to site landfills close to urban centers where we may dispose of our solid waste. As SAGE has consistently advocated: in the absence of strong motivations to reduce our consumption and repair/reuse products, we have a minimum obligation as a community to responsibly manage our waste.
SAGE would also like to acknowledge the skilled and committed team in Waste & Recycling Services for their efforts in providing a coherent waste management plan adopting best practices from many other municipalities. Perhaps more importantly, we appreciate their notable efforts in communicating the process, the outcomes and the benefits of the waste management plan in the broader community. Our understanding has greatly benefited by their clearly presented research.
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19 April 2016
Hon. Lawrence MacAulay
Minister of Agriculture and Agri-Food
House of Commons
Ottawa, ON K1A 0A6
Dear Minister MacAulay:
Re: Prairie Farm Rehabilitation Administration (PFRA) Community Pastures
The Southern Alberta Group for the Environment (SAGE) is a non-profit, volunteer organization that advocates and advances environmental sustainability in our region. We are writing to ask that you halt the transfer of any more PFRA Community Pastures to the provinces and that there be a Strategic Environmental Assessment of the decision made by the previous government to end the Community Pasture Program of the Prairie Farm Rehabilitation Program and transfer the lands to the governments of Saskatchewan and Manitoba.
As we live in a prairie region, we are well aware of the value of our nation’s remaining native grasslands for biodiversity (including about 90 Species at Risk), for carbon sequestration, for soil and water conservation, for livestock production, for outdoor recreation and for preserving and interpreting our cultural heritage (indigenous and homesteading). Nationally, native grasslands occupy less than 20% of their pre settlement extent. Community Pastures in Saskatchewan comprise a significant amount of what remains. Privatization of these lands will likely result in degradation and outright loss of these significant values.
We are deeply concerned over the impending demise of PFRA pastures, including sale of native grassland parcels already undertaken by the government of Saskatchewan. We are pleased to see a recommendation from the Federal Standing Committee on Finance (March 2016) that “The federal government consider re-establishing the Prairie Farm Rehabilitation Program.” We encourage you and your colleagues to act on that recommendation.
Hon. Catherine McKenna, Minister of Environment and Climate Change Catherine.McKenna@parl.gc.ca
Hon. Ralph Goodale, MP for Regina-Wascana Ralph.Goodale@parl.gc.ca
Hon. Carolyn Bennett, Minister of Indigenous and Northern Affairs Carolyn.Bennett@parl.gc.ca
Right Hon. Justin Trudeau, Prime Minister of Canada, Justin.Trudeau@parl.gc.ca
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Southern Alberta Group for Environment calls for headwaters restoration to benefit majority of citizens in Southern Alberta.
The Southern Alberta Group for Environment (SAGE) together with others in the conservation community is calling for reduced linear footprint, strict limits on off?highway vehicles (OHVs) on public lands, and a ban on OHVs in parks and protected areas. A communiqué was sent to the Government of Alberta on January 13, 2016 (Attachment 1). The Southern Alberta Group for Environment (SAGE), established in 1984, works to protect and restore the health of our environment – water, air, and land – in Lethbridge and region.
The headwaters of the Oldman River are important to the more than one hundred thousand residents of Lethbridge and surrounding communities not only because most of our water supply originates in the mountains and foothills, but also because they provide places for amazing outdoor recreation experiences, including wildlife viewing.
Unregulated OHV use in the headwaters of the Oldman River threatens aspects of the watershed most valued by the large majority of its residents. Over the last decade, five separate surveys and consultation processes have clearly shown watershed protection and sustaining biodiversity are priority values among southern Albertans (Attachment 2). Results also show strong support for reducing linear footprint, restricting motorized access and regulating off?highway vehicles. “There is overwhelming public support for a principled approach to planning for the new Castle Park and for linear footprint and recreation plans being developed for the Porcupine Hills and Livingstone area” says Cheryl Bradley, SAGE director. “A
principled approach would restore disturbances to native condition, restrict and regulate offhighway vehicles, and provide non motorized outdoor recreation opportunities“.
Read more and download the pdf version with pictures by clicking here.
South Saskatchewan Region Biodiversity Management Framework (BMF)
RE: Nov. 20, 2015 draft of South Saskatchewan Region Biodiversity Management Framework.
Comments by Lori Goater with input from the SAGE Board (following stakeholders workshop in Lethbridge on Dec. 2, 2015)
Thank you for the opportunity to contribute. It is important that the South Saskatchewan Region Biodiversity Management Framework (BMF) has a strong foundation in order to maintain biodiversity in the region over the long term. The public is supportive of responsible environmental stewardship of our landscape.
Managing our collective impacts on water, air, and biodiversity are in everyone’s best interest.
Considerable effort has already been invested in monitoring biodiversity within our region. As recognized in the draft BMF, many projects have been dedicated to monitoring suites of biodiversity indicators and evaluating their status relative to past, current and future conditions. An overwhelming amount of information suggests that biodiversity is becoming increasingly threatened across the region. Thus, the government is challenged with the difficult job of arresting biodiversity loss in a timely and transparent manner in the face of growing population and land use pressures.
Habitat extent and quality, as well as species presence and abundance, offer many ways to measure biodiversity and the overall integrity of ecosystems. The Air Quality and Surface Water Quality Management Frameworks are built on gradients and thresholds, so it would be convenient if this approach could be applied to monitoring the status of biodiversity as well. The ‘holy grail’ for resource managers is a biodiversity indicator with a linear gradient of ‘health’ and predictable response to increasing landscape disturbance. However, biodiversity is inherently complex & dynamic, responding to the unique environmental variables of each situation.
The Government of Alberta should be commended on its intent to reduce the cumulative effects of development on the environment. Predictive modelling has been invaluable in assessing the impacts of land use scenarios on biodiversity; historic land use and water management trends have been analyzed based on understanding species responses to habitat alteration. This draft BMF is primarily a monitoring strategy, the results of which could contribute to better informed decision-making in the long term, however time is of the essence for maintaining many ecological communities (e.g. rough fescue grasslands, cottonwood forests) and Species At Risk (e.g. Westslope Cutthroat Trout, Bull Trout, Sage Grouse, Grizzly Bear). Several important inadequacies need to be addressed before government can be confident of achieving its biodiversity objectives.
The core of the draft BMF proposes measuring the urgency of management response based on interpreting the condition of an amalgamation of biodiversity indicators. Logically, this approach should be as strong as the science that supports it. Unfortunately, the draft indicates that the breakpoints between risk categories have no scientific basis (inappropriately based on the IUCN guidelines for defining endangerment of species), the ‘trigger’ tolerances between management levels are set arbitrarily, and performance is ranked relative to current condition instead of a sustainability benchmark. Considering the wealth of available science and the considerable importance of biodiversity (as espoused in the first half of the draft), it was disappointing to see the framework built on such a weak foundation. The majority of workshop participants were, not surprisingly, confused and frustrated during the explanation of the indicators and triggers section.
The draft BMF requires substantial investments in monitoring AND analysis. Co-opting non-government organizations to support the data-collection process could be a sensible approach; improving both monitoring efficiency and data credibility. However, it is clear in this draft that the government is inadequately prepared to analyze the large amounts of raw monitoring data that would result. The vague plan to summarize indicator data into ‘pyramids’ and draw superficial interpretations based on the aforementioned methodology would discredit the entire process. To prevent this, we suggest that organizations such as AEMERA be given license to define priority biodiversity targets (e.g. native mixed grasslands), select appropriate biodiversity indicators (e.g. obligate grassland bird species) and produce complete status assessments. This would increase transparency and unburden the government to focus on improved planning and managing risk. The government needs to move away from its traditional role as sole data source and become more active and transparent in facilitating information accessibility.
The draft SSR BMF lacks clearly defined, tangible and measurable outcomes that would lead to place- based actions. This can likely be attributed to the failure of the planning processes for the Land Use Framework and the South Saskatchewan Regional Plan to make tough choices and trade-offs regarding land uses and to sufficiently identify and zone those landscapes in the region where conservation and restoration of native ecosystems and species is a priority. More information is required on how the BMF links to or guides human footprint management planning, recreation management planning and forest management planning for defined areas, such as is currently underway for the Porcupine Hills and Livingstone.
Generations of Albertans have benefitted from our region’s rich natural heritage. Without strong leadership toward mitigating environmental impacts, our resource-based economy will gradually erode the natural landscape beyond recoverability. Despite the urgent need for a well-designed BMF to build leadership in sustainable practices and environmental stewardship, the current draft falls disappointingly short of these goals.
BILL C - 202 CANADIAN ENVIRONMENTAL BILL OF RIGHTS
26 January 2016
To: The Right Honourable Justin Trudeau, P.C., M.P. Prime Minister of Canada
Cc: The Honourable Catherine McKenna, Minister of Environment and Climate Change
Linda Duncan, M.P., House of Commons
Rachael Harder, M.P., House of Commons
The Honourable Shannon Phillips, Minister of Environment and Parks, Government of Alberta
From: Braum Barber, Southern Alberta Group for the Environment
Dear Prime Minister,
The Southern Alberta Group for the Environment (SAGE) is a non-profit, volunteer organization that advocates and advances environmental issues on behalf of our region.
SAGE supports the private member’s bill, Bill C-202, to enact the Canadian Environmental Bill of Rights.
A federal Environmental Bill of Rights would strengthen Canada’s legal framework for protecting the environment and ensuring the rights of Canadians to a healthy environment. We believe it is time that Canada join the more than one hundred other countries in the world that have included environmental rights in their national constitution.
We fully support the principles of safeguarding the right of present and future generations of Canadians to a healthy environment, and to confirm the public trust in the Government of Canada as it relates to public stewardship and environmental law. We also support the more tangible proposal to ensure that Canadians have access to adequate environmental information and mechanisms for participating in environmental policymaking processes. Canadians should have the right to be informed on environmental issues, and have adequate legal protection against private or public reprisals for advocating for a healthy environment.
We understand that the Environmental Bill of Rights would relate only to issues that fall under federal jurisdiction, however, a strong statement from the federal government may encourage provinces that have not yet drafted similar legislation. A federal Environmental Bill of Rights would also stand as an interim step towards an explicit and more authoritative Charter right for Canadians to live in a healthy environment.
RECYCLING ISSUES, LETTERS TO LETHBRIDGE CITY COUNCIL, 21 January 2016
To: Mayor Spearman, City of Lethbridge City Council
From: Braum Barber, Chair
Southern Alberta Group for the Environment Re: Residential Waste Diversion Strategy
The Southern Alberta Group for the Environment (SAGE) is a non?profit, volunteer organization that advocates and advances environmental issues on behalf of our region. SAGE supports the efforts of the City of Lethbridge to advance waste diversion in the Construction & Demolition (C&D), Industrial, Commercial & Institutional (ICI), and Residential sectors.
We support the three sector strategies on the basis of better managing our natural resources, and reducing landfill emissions to the natural environment. According to the Conference Board of Canada, we produce more waste per capita than any other OECD nation, Alberta produces more waste per capita than any other province, and Lethbridge produces more waste per capita than the other cities in the province. This makes us one of the most wasteful groups of people on the planet.
Relying on voluntary recycling, only about 15% of the residential waste is diverted from the landfill, and the other sectors are even less effective. Research suggests that these rates of voluntary recycling will not substantially improve without implementing curbside recycling of materials and compostable waste. Clearly, with greater amounts of waste being diverted, Lethbridge will have to increase its capacity to sort, store and sell recycled commodities: SAGE supports the establishment of a city?owned, privately operated Materials Recycling Facility.
SAGE believes that City Council has the support of a majority of citizens in Lethbridge as evidenced by the Ipsos Reid poll conducted in 2013, and on the basis that most of the members of City Council were elected on platforms that included support for curbside recycling, based on a survey conducted by Accountability Lethbridge prior to the last election.
SAGE would like to commend the efforts of the Waste & Recycling Department for better positioning Lethbridge as it transitions towards greater environmental sustainability in the future, as directed in the Municipal Development Plan / Integrated Community Sustainability Plan (MDP/ICSP).
RECYCLING ISSUES II, 29 January 2016
To: Lethbridge City Council
From: Braum Barber,
Southern Alberta Group for the Environment Re: Curbside Recycling
The Southern Alberta Group for the Environment (SAGE) is a non?profit, volunteer organization that advocates for constructive solutions to environmental issues on behalf of our region. SAGE has a long history of collaborating with government institutions to develop positive policies and promote initiatives that preserve ecosystem integrity, biodiversity, and that help create a culture of sustainability. With respect to the Council decision not to support curbside recycling in Lethbridge on Monday, January 25, we would appreciate some guidance to the following questions. Your perspectives would help SAGE better align its efforts towards a common goal of maintaining and enhancing the health of the environment upon which our community relies.
1. In May 2015, Lethbridge City Council approved an environmental policy to ‘inspire, lead, and support actions to conserve, protect and enhance the environment for the Lethbridge community’ and to ‘support efforts to minimize Lethbridge’s ecological footprint by using natural resources efficiently’. In July 2015, Lethbridge City Council approved waste reduction targets of 180 kg per capita by 2021 for residential waste (from the current 330 kg per capita). On November 30, 2015 a proposed Residential Waste Diversion Strategy was presented to City Council that considered consultant recommendations regarding a materials recovery facility and a private vs public comparison for curbside collection operations.
Having defeated the proposed Residential Waste Diversion Strategy, what alternative will City Council propose that would more effectively replace this strategy, demonstrate environmental leadership, and better support the efficient use of natural resources in the city?
2. We were interested in the enthusiasm in City Council for the ‘opt?out’ strategy as it relates to the provision of city services.
What successful examples are there of citizens being allowed to opt out of paying for the provision of city?wide services that benefit all citizens?
3. Two members of the standing Environment Committee of Council (Councillors Iwaskiw and Mauro) voted against the motion before City Council on January 25 to endorse the Residential Waste Diversion Strategy. The desired outcomes of this committee are to ‘ensure that Lethbridge is a leader in environmental stewardship’ and to ‘encourage the community to contain and reduce our impact on the environment’. A key action for the committee in 2016 was to explore curbside recycling.
It is our understanding that the role of this committee is to guide policy development for leadership in environmental stewardship, and to review research and information that City Council requires to make informed decisions. Given that is the case, why were there so many questions to administration requesting information on the day of decision? More importantly, why were two members of this committee not seemingly engaged in making this plan work, essentially overturning the Finance Committee's decision to support in principle the delivery of curbside recycling in Lethbridge (November 2014). If there were concerns with proceeding with the strategy, why did the Environment Committee not provide options for a viable strategy to achieve the policy targets for residential waste diversion?
We look forward to your insights regarding this process, its failure, and how SAGE might continue to be of service in creating a culture of sustainability in Lethbridge.
October 1, 2015
To: Land Use Secretariat
South Saskatchewan Regional Plan Amendment Consultation
From: Braum Barber
Southern Alberta Group for the Environment
Re: Enhancing the Protection of the Castle Area
The Southern Alberta Group for the Environment (SAGE) commends the Government of Alberta for its commitment to protect the Castle as an important source for clean water in southern Alberta, as water storage for late season streamflow, and as a migration corridor and crucial habitat for wildlife.
SAGE supports the planned amendment to the South Saskatchewan Regional Plan (SSRP) to designate a Castle Wildland and Provincial Park that ‘would protect important fish and wildlife habitats and shared international wildlife populations, provide headwaters protection, help to manage and develop recreational and tourism opportunities, and reduce or remove industrial impacts on the landscape.’
SAGE has been actively involved in providing feedback during consultations on the South Saskatchewan Regional Plan (SSRP), and continues to be interested in supporting sustainable policy and practices in the region. Sustaining biodiversity and ecosystem function should be paramount in this plan and will require not only protection, but restoration and rigorous scientific monitoring.
SAGE remains concerned that the SSRP does not adequately address current trajectories of land use for industrial growth, which clearly indicate unsustainable impacts and unacceptable cumulative effects in the region. We believe Albertans realize and accept the idea of limits, and are willing to live within them to maintain healthy and purposeful lives. Furthermore, the document does not fully acknowledge ecological valuation in cost-benefit analyses, and ignores our collective responsibility to reduce greenhouse gas emissions. Emission goals and approaches to reducing them should be specifically stated in the SSRP, and aligned to the outcomes of the Climate Leadership discussion.
There is no clear commitment to preserve native grasslands in the SSRP, nor is there a commitment to reduce the impact on wetlands and riparian areas or to reduce the adverse effects on aquatic ecosystems caused by high quantities of water allocation for irrigation. In fact, the SSRP indicates that there is an expectation for ongoing expansion of agricultural land under irrigation and the development of on-stream storage to mitigate expected water scarcity in the future. Five grassland areas identified for conservation management by the RAC with valley and coulee connectors are ignored in the SSRP, except a vague commitment to maintain intact native grassland and habitat as a high priority, and a nod to species-at-risk protection without a clear plan to maintain and improve habitat.
The Minister of Environment and Parks has recently noted that Alberta is ‘on track to having the worst air quality in Canada.’ Fine particulate matter is an ongoing (though seasonal) concern in the south, and is substantially related to agricultural activities including intensive livestock operations. SAGE has been actively involved in the Clean Air Strategic Alliance and the Odour Project Team, which has recently completed a Good Practice Guide (available online at casahome.org). It would be appropriate to consider the documents developed through this consensus process in the SSRP.
Timelines to monitor environmental conditions, evaluate data, and assign indicators are much too protracted in the document. We agree that monitoring, program evaluation and assigning indicators of environmental health are important, but much work already exists – notably the Oldman Watershed Council Headwaters Action Plan 2013-2014. Once clear goals are established by the SSRP, well-researched indicators like density of linear footprint, native fish populations and invasive species can be initiated immediately. Furthermore, it would also enhance the SSRP if a clear list of indicators be included in the document, with a commitment to invest in scientific monitoring. Data gathered should be independently verified and made freely available to the public. Open and transparent processes of communicating data will be important for the success of regional planning.
A strong regional plan must be clear in stating limits, setting priorities, and providing direction for future decision making. Extant wilderness must be protected and restored, native grasslands must be protected, industrial activity and vehicular use must be curtailed in these areas, habitat connectivity must be established, the headwaters must be protected, and adequate instream flows must be maintained. Off-highway vehicle recreation must be restricted to designated trails, managed and enforced. The current SSRP does not say this clearly enough.
Furthermore, as the Municipal Government Act is under review, it would be timely to assign clear responsibilities to municipalities within the purview of the SSRP: for example, improving water quality from stormwater systems, reducing water abstractions from rivers, reducing the impact of urban sprawl on land-use, improving building standards to reduce energy consumption, and lowering emissions through alternative transportation infrastructure.
SAGE wholeheartedly supports the proposed amendment to the SSRP regarding the designation of the Castle region as park land. We hope that the Alberta Government will take the opportunity to advance other aspects of the regional plan towards achieving a sustainable future for Albertans.
DOWNLOAD a copy of the letter in pdf format by clicking HERE.
Lethbridge City Council
910 – 4 Ave. S., Lethbridge AB
Attn: City Clerk, email@example.com
Dear Honorable Mayor and Councillors:
Re: Bylaw 5894, Proposed Amendment to the City of Lethbridge Bylaw 5700
Portion of 1410 and 1520 – 24 Ave. S. (20-21-8-W4), Tudor Estates Neighbourhood
SAGE (Southern Alberta Group for Environment), a non-profit society established in 1984, is a leading voice for a healthy and environmentally sustainable community through informing citizens, participating in public processes and supporting sound environmental initiatives and actions. We have informed ourselves about the proposed change in land use classification to allow residential development on the edge of the Oldman River valley adjacent to Tudor Estates Neighbourhood. We provide the following comments for your consideration in making a decision regarding the above application for rezoning.
Current Ownership, Zoning and Use of the Land
Although the Notice of Public Hearing is not clear about ownership, we are informed that the western half of the land proposed for rezoning (1.78 ha/4.40 ac) is public land, acquired by the City in 2001 as part of a 25-acre parcel. This 4.4-acre parcel is a narrow peninsula jutting westward and flanked on three sides by steep-sided coulees of the Oldman River valley. This scenic parcel of public land is grassland and used extensively for outdoor recreation by residents of Tudor Estates and beyond, as evidenced by the network of informal trails that run through it.
It is our understanding that when purchased the parcel was zoned Urban Reserve in Land Use Bylaw 4100 and that all parcels with that zoning in the previous bylaw were arbitrarily switched to Future Urban Development (FUD) when Land Use Bylaw 5700 was instituted in 2011. It is also our understanding that at that time detailed consideration was not given to the most appropriate zoning and use of individual parcels of land designated as FUD under Land Use Bylaw 5700.
According to Land Use Bylaw 5700, FUD is “for the control of subdivision and development until the required municipal services are available, area structure or area redevelopment plans are approved, and more appropriate alternative districts are applied”. The City-owned parcel and the private land being considered for rezoning to Low Density Residential (R-L) are not part of an area structure plan or area redevelopment plan. Noteworthy is that the City-owned parcel is flanked on three sides by lands zoned as Valley District (V) and subject to the River Valley Area Redevelopment Plan (Bylaw 5277).
In an in-camera meeting on July 7, 2014, City Council entered into a conditional land sale with Douglas J. Bergen and Associates Ltd. of Coaldale that would exchange this 4.4-acre parcel of public land for $8,500 and a 1.95-acre parcel that would form part of the right-of-way for a proposed future crossing of the Oldman River valley, should a third crossing be built in future. The sale is conditional on rezoning the land to Low Density Residential (R-L) on or before December 31, 2014 and on the developer subdividing the parcel by December 31, 2015. There was not public notice associated with the conditional land sale agreement.
This appears to be the first opportunity for openly assessing the environmental aspects, alternative uses and appropriate zoning for these public lands.
Essential Municipal Services
We have been informed that thirty-seven houses are proposed for the development, twenty of these on City land. It is our understanding that municipal stormwater and wastewater utilities serving Tudor Estates are already stressed and there is not an easy fix. Hence, it is doubtful that the required municipal services are available in the Tudor Estates area to allow a change to zoning that would lead to a residential subdivision of this size.
We suggest a full assessment of the costs versus the benefits to taxpayers is needed to inform a decision regarding municipal investment in major infrastructure upgrades such as would be required to accommodate the proposed development. We have not seen such an assessment.
River Valley Setback and Slumping Risk
The City-owned parcel is adjacent to the Valley District and therefore subject to development setback as per the River Valley Area Redevelopment Plan (Bylaw 5277). We are informed that a geotechnical study was commissioned by the proponent, although it has not been made public at the time of preparation of this submission.
A walk along the tops of coulees adjacent to Tudor Estates and northward to Chinook Heights and Park Royal Estates provides ample visual evidence of natural slumping as well as accelerated slumping attributable to residential developments on adjacent uplands. Minimum legal setbacks do not appear to be sufficient. It is probable that the City-owned parcel on the narrow peninsula flanked by steep-walled coulees has geology similar to the areas experiencing accelerated slumping to the north and south.
We suggest a decision to rezone the lands needs to be informed by a detailed geotechnical study and risk assessment specific to the site. Such a study would involve drilling and monitoring to acquire the information on subsurface geology, drainage and factors that result in accelerated rates of slumping. Experience has shown that a desktop study that establishes a minimum setback is not sufficient to provide confidence that Lethbridge taxpayers will avoid major liability should the development proceed and there is subsequent loss of private property to slumping, such as occurred at Stafford Coulee.
Integrated Community Sustainability Plan/Municipal Development Plan Policies
SAGE is familiar with the Integrated Community Sustainability Plan/Municipal Development Plan (2010) having participated in its preparation. Our view is that the proposed rezoning and subsequent residential development is inconsistent with the policies set out in the ICSP/MDP. Of particular relevance is:
Section 6.5.1 Lethbridge’s River Valley is the Primary Open Space System.
“Policy 3) Restrict development on or near to hazardous lands in the river valley”
Hazardous lands include “…lands with slopes over 15%, and lands characterized by extensive slumping, drainage or erosion problems.” Our view is that the City lands that are the subject of this application are near to hazardous lands and therefore development must be restricted.
“Policy 4) Ensure the River Valley is accessible to all residents”
“Policy 5) Incorporate strategically located view corridors adjacent to the river valley”
“Policy 6) Increase accessibility to the river valley by requiring linear open space along the valley crest”
“Policy 7) Create a continuous pathway throughout and along the top of river valley”
We suggest that development of a subdivision with 20 residences on such a narrow peninsula would exclude recreational users and violate the above policies. Should the rezoning and development proceed, a well-established trail along the north side of the parcel would be interrupted and built upon and there would be insufficient space for a public trail along the south side of the development. Squeezing a trail between backyards and the coulee edge would create the potential for conflict between homeowners and trail users. Well-used green space along the valley crest would be lost as would the opportunity for a continuous pathway along the top of river valley extending from Lethbridge College north to the Sugar Bowl that is part of the recommended future pathway development indicated in Figure 7.2 of the City of Lethbridge Bikeways & Pathways Master Plan (2007). A more appropriate zoning for the parcel, currently zoned Future Urban Developent, is Park and Recreation (P-R) or River Valley (V).
In summary, we recommend that City Council deny the application to change the land use classification on a portion of 1410 and 1520 – 24 Ave. S. (20-21-8-W4) from Future Urban Development (FUD) to Low Density Residential (R-L). The land in question is in an area that has experienced accelerated slumping following residential development on adjacent uplands and insufficient information has been provided to demonstrate residential development on the narrow peninsula flanked by steep-sided coulees would not be at risk of accelerated slumping. Current municipal services, particularly wastewater and stormwater infrastructure, are reportedly inadequate to accommodate additional residential development and thus to justify rezoning. Much of the land (4.4 ac) is owned by the City and receives extensive recreational use.
We suggest the City Council deny the application for rezoning and vote to retain these lands in public ownership. Proceeding with proposed development of a public pathway along the top of river valley would be consistent with the Integrated Community Sustainability Plan/Municipal Development Plan (2010) and the City of Lethbridge Bikeways & Pathways Master Plan (2007). We suggest a more appropriate zoning for these public lands, currently zoned Future Urban Development (FUD), is River Valley (V) or Park and Recreation (P-R).
Braum Barber, Chair
DOWNLOAD a copy of the letter in pdf format by clicking HERE.
Re: Goldenykey Drilling in Lethbridge
To: Goldenkey Oil Inc.
From: Braum Barber, Director, Southern Alberta Group for the Environment
Re: Drilling in LethbridgeMunicipality(5-14-8-22W4M,16-16-8-22 W4M)
The Southern Alberta Group for the Environment (SAGE) appreciates the efforts Goldenkey has made to inform the residents of Lethbridge about the planned drilling for oil within the municipal limits – the public consultations were well organized and informative. We also appreciate that Goldenkey is making an effort to meet and exceed regulations in an effort to reduce the risk of drilling, completion and production processes, and reduce the impact of surface disturbances (traffic, noise, dust and odours) on residents living near the location of proposed operations.
SAGE has many concerns about the safety of oil & gas operations within the municipal limits of Lethbridge – both to its residents and to the natural environment upon which we depend for our health and wellbeing. Goldenkey has purchased rights to drill for oil near expanding residential areas, recreational facilities, and schools in West Lethbridge. We understand that this area is not scheduled to be developed for a number of years depending on residential growth in the city; however, this does not preclude the potential impact on existing municipal developments.
SAGE also understands that there are existing gas wells in the area currently owned and operated by Bonavista Energy Corporation. Many of these wells were drilled before the land was annexed by the City, and before extensive municipal plans were made to develop West Lethbridge. Oil & gas operators voluntarily agreed to cease further development in the area upon the request of the City of Lethbridge. This was a prudent decision by both the City of Lethbridge and Bonavista Energy Corporation at the time. We have not been informed if Goldenkey was aware of this informal agreement, nor do we know if Goldenkey communicated with the City of Lethbridge prior to purchasing the leases. Nonetheless, it would have been sensible to have discussed these precedents prior to purchasing the resource rights and surface leases.
The proposed Goldenkey Penny Project wells are exploratory which, by definition, means that the company does not know what sort of oil production to expect. We simply cannot understand why a junior oil company would drill a financially risky exploratory well at a risky location near a dense population of people. We also do not understand why Goldenkey would drill on land that is expected to be developed for residences and urban amenities. If the wells are prolific, further exploitation of the field would reduce the likelihood of future municipal development and have a greater impact on current residents (with greater traffic, noise, dust and odours).
In the event that drilling, completion and production of oil wells proceeds in West Lethbridge, there are many concerns that must be addressed:
1. The first is the mitigation of surface disturbances including noise, traffic and dust during drilling, stimulation and production. Goldenkey has said that they meet the requirements of the AER, however, we feel that they should greatly exceed these regulations considering the potential to affect a large population. Avoidance would be best, we believe.
2. Secondly, the transportation of hazardous materials through Lethbridge is of concern: including toxic produced water, produced oil, and chemicals used to sweeten the solution gas. This concern includes the storage of hazardous materials on site, which could exacerbate the impact of, say, serious grassfires (of which there have been two in West Lethbridge over the past number of years).
3. Thirdly, fugitive emissions of sour gas and chemicals pose a safety threat for downwind residential areas. These emissions may originate from leaky packing on a pump jack, the venting of tanks, potential leaks in piping systems, safety valves on compressor systems, and possibly during the replacement of sweetening chemicals. We understand that Goldenkey will be monitoring the area for H2S and that the company must develop an emergency response plan – unfortunately, any emergency response follows the development of an emergency, an emergency that may have significant impacts on the residents of West Lethbridge. A robust emission monitoring program would be expected, with data made available to the public. Incinerator technologies suitable for high wind applications and designed to adequately incinerate chemicals carried over from separation would also be expected.
4. Fourth, we are concerned about the risks of contaminating groundwater aquifers and surface water from spills, leaks, and unpredictable communication up the wellbore, via offset wells, or through geological formations induced by the hydraulic fracturing of the formation. Baseline samples of groundwater and air quality would be expected, with a long-term monitoring plan to indicate negative trends due to industrial activity.
5. And, finally, we are concerned that the reclamation/restoration will be inadequate for the purpose of using the land for residential development, parks and schools. We understand that there are financial mechanisms for restoration/reclamation of the sites (such as AER Licensee Liability Rating program, and the orphan well fund), however, we would expect a commitment for reclamation to a higher standard. Recommendations, like the Recovery Strategies for Industrial Development in Native Prairie, which seem to exceed the AER directives in outcome, might be considered.
There is clearly a gap in regulatory processes and government oversight that would allow oil exploration to occur within the municipal limits of a city and near dense populations. We understand the Goldenkey is working well within the expectations of AER regulations, and we appreciate that the company does not believe there is significant risk in their operations. Our apprehensions reflect the concerns of any group of people being exposed to (what we consider unnecessary) risk; and we are concerned about the impacts on our environment - the clean air, clean land, and clean water we rely on for our collective wellbeing. The cumulative impacts of industrial and agricultural development in southern Alberta are becoming more evident.
With respect, SAGE believes that the Penny Project is not an appropriate industrial activity within the municipality of Lethbridge. We have asked our MLAs to address the issue of drilling near dense populations, and we hope that Goldenkey will be fairly compensated if the project is declined.
Braum Barber SAGE
cc. Mayor Chris Spearman, City of Lethbridge
Hon. Robin Campbell, Minister of Environment and Sustainable Resource Development
Re: Draft South Saskatchewan Regional Plan (SSRP)
To: Honourable Robin Campbell, Minister ERSD
cc: Bev Yee, Assistant Deputy Minister, ESRD Greg Weadick, MLA Lethbridge-West Bridget Pastoor, MLA Lethbridge-East
From: Braum Barber, Director, Southern Alberta Group for the Environment
The Southern Alberta Group for the Environment (SAGE) has enthusiastically supported the process of developing the Draft SSRP. We believe that it is extremely important that the Government of Alberta take a leadership role in managing land-use for the long-term benefit of Albertans, and the SSRP is a promising effort in this direction. We encourage the government to continue to pursue regional planning; however, we believe the current Draft SSRP will require some adjustment to be effective.
Before elaborating some specific concerns, it is important to first express some general objections about the tone of the document. Consider the following quote:
“While cumulative effects are considered to be the combined effects of past, present and reasonably foreseeable land-use activities on the environment, it is not the intention of the biodiversity management framework to return Alberta to the levels of biodiversity found prior to European settlement. Today’s Alberta includes working landscapes, and the Land-use Framework policy acknowledges the need to balance environmental, social and economic considerations. The focus of the framework is from today into the future ...” (p.38, 119).
Is there anyone who has seriously proposed that we restore the South Saskatchewan basin to a condition ‘found prior to European settlement’? Is this rhetorical flourish meant to temper expectations for the ‘need to balance environmental, social and economic consideration’ in the following sentence? As we have already eliminated at least 60% of native vegetation and 64% of natural wetlands from the region and compromised much of the natural ecosystems that remain, wouldn’t a ‘balance’ suggest conserving what remains and that some serious restoration be considered? Or are the criteria for ‘balance’ based on current conditions, or the conditions in 2017, or 2024 when the government writes a new planning document? One might argue, with so much land already converted from its natural state, that what remains must be preserved. That a proper ‘balance’ would be a no-net-loss policy with concerted efforts towards restoration and expansion of conserved land.
Perhaps this seems pedantic, but how does the concept of ‘balance’ correlate with the concept of ‘growth’? The tone of the document suggests that ‘growth’ is the sine qua non of Alberta’s economic strategy - inevitable, indeed desirable - and that conservation efforts are not intended for long-term preservation, but simply a delay in exploitation until a time when areas critical for water purification, water retention, carbon sequestration and habitat have more economic value for other land uses, as guided by the omniscient invisible hand of valuation. Unfortunately, “if land-use decisions are based on market-priced goods alone, then a reduction in environmental regulations must always appear justified.”i In other words, conservation must recognize both market and non- market goods and services, with difficult-to-monetized impacts managed by imposing sustainability constraints – the SSRP requires more sophistication in its approach to valuation. This document would be more effective with a clear admission of limits – limits to growth, and limits to converting what remains of our natural heritage for human uses.
In addition to the uncritical veneration of growth, there is a clear paucity of imagination in the Draft SSRP of what type of economic growth Alberta can expect over the next decades. Are forestry, oil & gas exploitation, and irrigation really our only vision for economic prosperity in the province? With limits on natural resources (both renewable and non-renewable), can perpetual growth of resource extraction be realized? Can further growth of land-based human activities be realized while ‘balancing’ the need for preserving natural areas?
It is our general concern that the current Draft SSRP is emasculated by its lack of clear vision for Alberta’s future. Some definition of conservation, of balance, and of growth would make clear the goals for future decisions that will be made based on this planning document. As it stands, the actual goals of the document are ambiguous and the actions emerging from the SSRP are likely to be inconsistent, if not incompatible.
13 September 2013
To:Hon. Ken Hughes; Minister of Energy, Government of Alberta
From:Braum Barber, Southern Alberta Group for the Environment (SAGE)
Re:Exploitation of Public Grasslands on Milk River Ridge
Public grasslands on the Milk River Ridge (Tp 3 – Rg 18 – W4) have traditionally been leased for grazing, but have recently been targeted for oil and gas exploitation by DeeThree Exploration Ltd. The lands are covered by a Protective Notation because of their importance for rough fescue communities, wetlands and wildlife species at risk, and they are included as a Candidate Conservation Management Area recommended by the Regional Advisory Committee to the South Saskatchewan Regional Plan. Designation as a Heritage Rangeland has been proposed by local landowners and grazing leaseholders. We are concerned that the Government of Alberta is delaying consideration of legislative protection for these environmentally significant lands until completion of the SSRP while it is moving forward with the process for approval of a proposed industrial project. We ask that a public process to consider legislated protection for the area be completed prior to any consideration of industrial development.
There are few large blocks of native grassland left in Alberta, and what native grassland does remain is largely fragmented and insecure, and less than one percent lacks clear government protection. Native grassland constitutes only about five percent of the provincial land base, and yet supports approximately half of the rare ecological communities, 40% of rare vascular plant species and 70% of mammal, bird, reptile and amphibian species considered at risk or may be at risk. The native prairie ecosystem on the Milk River Ridge has intrinsic value and provides ecological services to Albertans such as water storage, carbon capture, sustainable ranching, and biodiversity conservation. The high-value wetlands merit protection from threats under the recently released Alberta Wetland Policy.
The shale oil play in southern Alberta has raised significant concerns. Horizontal drilling with intensive hydraulic fracturing has come under close international scrutiny since its development and application. Fugitive emissions from flow back water and problems with wellbore integrity pose risks to air quality, as well as surface water and groundwater. Water contamination is of particular concern for the area proposed for oil drilling on the Milk River Ridge as it contains headwaters for both the Milk and the South Saskatchewan River watersheds. Construction of well sites, access roads, and pipelines, as well as ongoing operations in the area, will have long term negative cumulative impacts for wildlife and native grasslands that we do not know how to restore.
Suggestions that oil development can proceed without significant impact are undermined by the fact that there seems to be inadequate efforts: to e