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.
Communications may also be found in the Newsletters archive.
March 31, 2021
The Honourable Devin Dreeshen Minister of Agriculture and Forestry Government of Alberta
Sent by e-mail: AF.firstname.lastname@example.org
The Honourable Jason Nixon Minister of Environment and Parks Government of Alberta
Sent by e-mail: AEP.email@example.com
The Honourable Jonathan Wilkinson Minister of Environment and Climate Change Government of Canada
Sent by email: Jonathan.Wilkinson@parl.gc.ca
The Honourable Catherine McKenna Minister of Infrastructure and Communities Government of Canada
Sent by e-mail: Catherine.McKenna@parl.gc.ca
Mr. Ehren Cory, Chief Executive Officer Canada Infrastructure Bank
Sent by email: firstname.lastname@example.org
Stephen Mathyk, Regional Regulatory Assurance Manager
Alberta Environment and Parks
Sent by e-mail: Stephen.Mathyk@gov.ab.ca
Re: Concerns regarding Proposed Alberta Irrigation Expansion Project Parternship of Alberta Government, Canadian Infrastructure Bank, Irrigation Districts
We are writing to state our concerns about a recently announced project to upgrade irrigation district infrastructure, build new and expanded storage reservoirs and increase irrigation acres within eight irrigation districts in the South Saskatchewan River Basin of southern Alberta. We are asking that this monumental project be subject to environmental assessment, regulatory review and opportunities for public and indigenous consultation and input. We are requesting that subsidies for efficiency improvements that Government deems to be in the public interest are accompanied by agreements on the use of freed-up water to assist in meeting societal goals for realizing instream flow needs and improving river health.
We understand hundreds of millions of dollars of provincial grants and federal loans to irrigation districts are involved as is the future use of a scarce and valuable public resource in a semi-arid region - water. We are concerned about potential environmental implications of the proposed project particularly on stressed aquatic ecosystems. The apparently secretive process being used to define the project and financing agreements is of concern in that it may preclude consideration of opportunities to support healthy ecosystems and human needs through shared stewardship.
It has been well understood for at least two decades that the health of rivers in the Bow, Oldman and South Saskatchewan sub-basins of semi-arid southern Alberta downstream of major irrigation supply dams and diversions is compromised by significantly reduced flows and altered flow regime as well as by impacts of growing population and intensifying land use (Schindler and Donahue 2006, Byrne et al. 2006, Pentney and Ohrn 2008). Several studies of the health of aquatic ecosystems have been undertaken to inform water and watershed management planning. These studies are listed and key points summarized in Attachment 1.
Irrigation agriculture is a major cause of stress on aquatic ecosystems due to water withdrawals from rivers and through pollution of runoff from cropland and return flows. The irrigation sector holds licences to withdraw over half of mean natural annual flow and over three-quarters of licensed water allocation in the Bow and Oldman river basins (Basin Advisory Committees 2018). Increased warming with climate change through its effects on evaporation, evapotranspiration and winter snowpack will continue to contribute to declines in river flow and on health of aquatic ecosystems if we do not take action to maintain and restore them (Jiang et al. 2017, Bonsal 2020).
We understand the potential benefit of improving water use efficiency of irrigation agriculture by converting open canals to underground pipelines. However experience here and elsewhere is that modernization seldom alleviates the consequences of cyclic drought or frees water resources for river flows and the natural habitats they provide but instead increases resource use and reduces society resiliency (Scott et al. 2014). A case in point is the Irrigation Sector Conservation, Efficiency and Productivity Plan (2005-2015) by the Alberta Irrigation Projects Association (2010). It does not identify or adopt meaningful opportunities to benefit the environment. It does not identify water sources showing signs of stress. Progress is not being made to allocate conserved water to benefit aquatic ecosystems that have been assessed as degraded because of water withdrawals. Furthermore plans and decisions are being made to commit conserved water (and unused water) for expanding irrigation acres with a resulting further stress on aquatic ecosystems and less water available for future societal needs.
Also of concern to us is proposed increase of off-stream water storage. We are aware of water supply and storage evaluations for the South Saskatchewan River Basin (AMEC 2009 and 2014) that addressed a strategy of the South Saskatchewan Regional Plan (2014-2024) toward managing watersheds to “support healthy ecosystems and human needs through shared stewardship”. These studies did not recommend new storage development in the Bow and Oldman subbasins but rather suggested pursuing non-structural opportunities first. We are not aware that non-structural opportunities have been fully explored.
We are also aware of climate adaptation strategies defined for the South Saskatchewan River Basin through a collaborative process using the South Saskatchewan River Operational Model (Alberta WaterSMART 2016). Strategies, both structural and non-structural, focused on adapting to drought and flood and increasing resilience to climate change, not increasing risk to existing water users and the aquatic ecosystem as could occur with major expansion of irrigation in the Bow and Oldman subbasins.
A further concern is whether the identification of new or expanded off-stream storage reservoirs that are part of the announced irrigation expansion project arose from a recent ranking of on-and off-stream storage options by the Alberta Irrigation Districts Association (2019)? If so, this is of concern as the AIDA study focused on benefits to the irrigation sector. Broader environmental, social and economic considerations were not addressed.
We expect there will be fulsome impact assessments including cumulative effects assessments and regulatory review of the various components of the project for compliance with relevant legislation and approved water management and land use plans and policies. Legislation that may apply includes the federal Impact Assessment Act, Fisheries Act and Species At Risk Act and the provincial Environmental Protection and Enhancement Act, Water Act, Alberta Land Stewardship Act, Wildlife Act and Irrigation Districts Act as well as a variety of approved plans and policies including the South Saskatchewan River Basin Water Management Plan, the South Saskatchewan Regional Plan and the Alberta Wetland Policy. There may be implications for interprovincial sharing of water according to the Master Agreement on Apportionment. As well the Government of Canada and the Province of Alberta have a duty to consult First Nations and Metis. We would like assurance that shared financing of the project by federal and provincial governments and irrigation districts will not affect the objectivity of impact assessments and regulatory review, opportunities for public input and determination of public interest.
Since the brief Alberta government media release (October 9, 2020) announcing the “historic investment to expand irrigation” our attempts to obtain information about project components through contacts with staff of Alberta Agriculture and Food, Alberta Environment and Parks, the Canadian Infrastructure Bank, and the Alberta Irrigation Districts Association have been unsuccessful. We are told that negotiations are ongoing and confidential. However, consultation with legitimate interests must occur and we suggest that it is better to do this prior to formalizing funding agreements. For example, we are interested to ensure any government subsidies for efficiency improvements that Government deems to be in the public interest are accompanied by agreements on the use of freed-up water to assist in meeting societal goals for increased in-stream flows and improved health of rivers.
We would appreciate being informed about the proposed project and assessment and regulatory review process. We request receiving notification of opportunities for consultation and input on any applications for approvals by government (e.g. environmental assessment process, water licence applications, expansion of irrigated acres).
Cheryl Bradley – Director, Southern Alberta Group for Environment
Arlene Kwasniak – Professor Emerita of Law, University of Calgary, in individual capacity
Carolyn Campbell – Conservation Specialist, Alberta Wilderness Association
Maureen Bell – Executive Director, Water Conservation Trust Silvia D’Amelio – Chief Executive Officer, Trout Unlimited Canada Richard Schneider – Executive Director, Nature Alberta
Peter Duck – President, Bow Valley Naturalists
For full letter, including carbon copy recipients and references, please Download the PDF:
Letter regarding Proposed Alberta Irrigation Expansion Project 2021
March 25, 2021
To: Hon. Sonya Savage, Minister of Energy
Hon. Jason Nixon, Minister of Environment and Parks
Cc: Nathan Neudorf, MLA Lethbridge-East
Shannon Phillips, MLA Lethbridge-West
Re: Terms of Reference for Public Consultation on Alberta Coal Policy
The Southern Alberta Group for the Environment (SAGE) appreciates the decision of the Government of Alberta to conduct public consultations on the Coal Policy. Though there have been a range of interpretations presented in the media, it is our understanding that the consultations will thoroughly evaluate options for a future coal policy, including ‘no-coal’ mining on the eastern slopes of the Rocky Mountains and our collective headwaters.
As the Coal Policy public consultation date approaches, SAGE would like to offer some thoughts regarding the Terms of Reference:
- That the terms of reference be expansive in nature and reflect the values of Albertans, including maintaining ecological integrity of the headwaters, establishing best-use of water in the region including instream flow needs, and identifying and realizing recreation and tourism opportunities. Foremost, a ‘no-coal’ policy for Alberta should be evaluated.
- All coal mining proposals currently in process and exploration on leases should be suspended indefinitely until the completion of a public consultation and the passing of new legislation.
- A coal policy should reflect the objectives of current legislation including the federal Impact Assessment Act, Fisheries Act and Species At Risk Act and the provincial Environmental Protection and Enhancement Act, Water Act, Alberta Land Stewardship Act, Wildlife Act and Irrigation Districts Act as well as a variety of approved plans and policies including the South Saskatchewan River Basin Water Management Plan, the South Saskatchewan Regional Plan and the Alberta Wetland Policy.
- A land footprint management plan should be expanded to encompass the eastern slopes. Land footprint management planning, such as is found in the Livingstone-Porcupine Hills Land Footprint Management Plan approved in May 2018, provides a science-based approach to managing human footprint (linear and spatial) to sustain those aspects of the Eastern Slopes that Albertans clearly identify as a priority – headwaters, westslope cutthroat trout, Foothills fescue grasslands, recreation opportunities and high scenic values. We encourage the Alberta Government to implement that plan and to use it as a model for other subregional plans in accordance with the Alberta Land Stewardship Act. Current exploration for coal in the Livingstone-Porcupine Hills violates the limits and thresholds of the land footprint management plan. A coal policy must be consistent with subregional plans.
- As discussed in the South Saskatchewan Regional Plan (SSRP), A Policy for Resource Management of the Eastern Slopes (“Eastern Slopes Policy”), “provides the foundation for the province’s Integrated Resource Plans at subregional and local levels within the eastern slopes and sets watershed management as the highest priority in the overall management of the eastern slopes. The natural resources are to be developed, managed and protected in a manner consistent with principles of conservation and environmental protection.” The Integrated Resource Plans for the region should be reviewed for their relevance and revised to include: current science on cumulative environmental impacts; economic principles that consider ecological values of wildlife habitat; values related to intensified demand for wilderness recreation and tourism; and the ‘internalizing’ of social and environmental costs of water pollution and climate change in decision making.
- A coal policy should clearly define all of the terms used to describe the extraction techniques of coal mining, including mountaintop removal, open pit, strip mining, etc.
- There should be clear delineation of the precautionary principle vs. adaptive management. A coal policy should establish environmental thresholds for monitoring and any enforcement or additional measures to be applied when critical thresholds are being approached or exceeded. Per the precautionary principle, unproven processes should not be implemented at full scale until adequately piloted, and there should be a willingness to terminate coal production to protect the ecosystem and other economic interests from further impact.
- A coal policy should be dedicated to improving our knowledge and understanding of surface and groundwater flow and aquatic and riparian ecosystems. Current science to establish instream flow needs (IFN) based on fish habitat, water quality, riparian vegetation, channel maintenance, etc. should be applied. Mechanisms for suspending industrial production when minimum flows are threatened should be clearly defined.
- A coal policy must review the Oldman River Basin Water Allocation Order and water licensing and transfer mechanisms in the basin to align with long-term societal goals and provide predictability in water availability. The water allocation process should reflect the current situation of over-allocation in the basin, as well as the impacts of climate change on future water availability. Conservation of water use through technological advances and efficiencies should include allocations to benefit aquatic ecosystems.
- A coal policy should incorporate restoration and reclamation management that sustains biodiversity and watershed integrity. Strategies to achieve this are provided in the Livingstone-Porcupine Hills Land Footprint Management Plan. Corporations should provide proof of secure and sufficient funds (such as a trust or Surety Bond) to cover the full costs of operating impacts due to tailing pond breaches and other catastrophic failures of production, as well as end-of-project abandonment and reclamation costs.
The Terms of Reference for the public consultation of a new Coal Policy should express the complexity of integrating existing policies and plans and include the greater scientific understanding and ecological and social concerns that have emerged since the last policy was created 45 years ago, including water allocation, cumulative effects, linear disturbance, ecological integrity and climate change. Albertans have also learned the lessons of failing to account for the ecological and social liabilities incurred from resource extraction – costs that are now being borne by the taxpayer. A new Coal Policy must be a better coal policy.
Given these concerns, SAGE believes that a no-coal option is an opportunity for the UCP government.
World governments are taking the last thirty-five years of accumulated climate science and empirical evidence seriously, and are beginning to act to reduce net greenhouse gas emissions by 40% by the end of this decade and by over 80% by 2050. The UN Secretary-General, António Guterres, has recently called on all nations to end subsidies for fossil fuels and ‘kick the coal habit’ to limit global annual warming to below 1.5°C. There is a growing consensus that coal will be the first fossil fuel that will be left in the ground.
If governments do in fact respond to this existential threat, there will be a near-term diminishing demand for coal – for thermal, metallurgical and other uses. It is not an opportune time to re-open the province to coal mining. It is, however, an opportune time to boldly end coal mining in the province. As the last of the coal-fired electricity generation facilities are retired by 2023, the province can accumulate some social license in regards to tourism and international trade by declaring Alberta coal-free. In the long term, our eastern slopes are more valuable as a desirable wilderness destination for recreation and tourism, and as a source of clean, safe water for downstream users including our multibillion-dollar agricultural industry.
The UCP government might consider collaborating with the NDP to develop non-partisan legislation to ban coal mining in Alberta and protect the future for Albertans.
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.
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.
Note: Bill C-12: "An act respecting transparency and accountability in Canada's efforts to achieve net-zero greenhouse gas emissions by the year 2050" was introduced for first reading on November 19, 2020 (Canada's 43rd Parliament).
November 17, 2020
To: Rachael Harder, MP Lethbridge
CC: Right Honourable Justin Trudeau, Prime Minister of Canada
The Honourable Jonathan Wilkinson, Minister Environment and Climate Change
Dan Albas, MP, Shadow Minister for Environment and Climate Change
The Honourable Erin O’Toole, Leader of the Opposition
From: Braum Barber, Chair
Southern Alberta Group for the Environment
Re: Climate Accountability Legislation (43rd Canadian Parliament)
Since 1984, the Southern Alberta Group for the Environment (SAGE) has been active in science-based advocacy for the environment, including participation in policy processes, informing the public on important regional issues, and promoting the long-term integrity, stability and beauty of our natural environment. In that spirit, we would ask that you support the upcoming climate accountability legislation being introduced in parliament.
Though the science of climate change has been well established since the 1980s, and the first 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 target these past three decades. We are speaking here of a ritual of failure. SAGE supports the science that suggests that we are at a crossroads where non-partisan efforts in climate mitigation (and adaptation-panning) are absolutely required.
There has been a longstanding narrative that climate mitigation and adaptation is in conflict with a robust economy. We no longer have the luxury of ruminating over this. Climate change will affect agricultural productivity and food security, health and mortality, crime, energy use, weather intensity, coastal inundation, and human habitation and migration – each of these may not only have profound impacts on economic well-being, but may undermine the very structures of civilized, democratic society. In other words, our economic and social integrity depends on the enduring stability of our climate.
Though a climate change accountability act was previously submitted in the 39th parliament in 2008 and reintroduced a number of times since, it is more important than ever that Canada makes it clear what has to be accomplished and the timelines within which it must be achieved. The upcoming legislation is likely to be largely aspirational, so it is important that these aspirations are presented to Canadians as univocal.
SAGE encourages you, Rachael Harder, to support this legislation on behalf of Lethbridge and region, and for the future of Canadians.
October 14, 2020
To: His Worship Chris Spearman, Mayor, City of Lethbridge
Cc: Lethbridge City Council
From: Braum Barber, Chair, SAGE
Re: Water Quality Impacts of Open-Pit Coal Mining
The Southern Alberta Group for the Environment (SAGE) is concerned about the potential impacts of water pollution caused by impending open-pit coal mining projects allowed in our headwaters by the recent change of the Coal Policy by the Government of Alberta. This policy change was implemented without consultation with Albertans, and it eliminates Category 2, 3 & 4 land designations that had restricted open-pit coal mining along the eastern slopes.
As a current case-study, measures of water pollution have increased in the Elk and Fording rivers downstream of similar coal mining operations, including cadmium, nitrate, sulphate, iron, uranium and selenium levels. Selenium is a significant pollutant as it is known to bioaccumulate (increase in concentration) along the food chain from plants to aquatic invertebrates to fish, and then to species that consume these fish including birds and even humans. Selenium is known to cause deformations in fish and reproduction problems in aquatic species, and it is fatal at levels as low as 1.5 mg/l. Selenium is a threat to long-term ecosystem and human health.
You may be aware that the U.S. Geological Survey in Montana has recently entered a dispute with British Columbia over rising selenium levels in transboundary waters. Coal mining companies have been unsuccessful in removing selenium in treatment processes, and there are no commitments for containing long term releases of selenium to water systems due to the weathering of overburden that has been discarded to access the coal.
It may be in the best interest of the City of Lethbridge to discuss these concerns with the Government of Alberta, as there is a potential impact on the safety of drinking water, as well as our local agricultural producers and livestock operations who rely on access to clean water. For further information, you may be interested in the references provided on our website (www.sage-environmental.org) linked to our recent article in The Lethbridge Herald on this topic. SAGE would be pleased to organize a presentation on the topic for a future Community Issues Committee meeting, if there is interest.
Lethbridge City Council Resolution:
6.2 Grassy Mountain Project and Proposed Open Coal Mining in the Headwaters Region of the Oldman River.
Response from Honourable Jonathan Wilkinson, December 1, 2020:
20 October, 2020
Hon. Jonathan Wilkinson
Minister of Environment and Climate Change
Government of Canada
Hon. Marie Claude Bibeau
Minister of Agriculture and Agri-Food
Government of Canada
Hon. David Marit
Minister of Agriculture
Government of Saskatchewan
Re: Conservation of former PFRA Pastures in Southwest Saskatchewan
I am writing you on behalf of the Southern Alberta Group for Environment (SAGE) based in Lethbridge, Alberta to express our support and appreciation for your agreement to proceed with a land exchange that will ensure that three former PFRA pastures in southwestern Saskatchewan - Govenlock, Nashlyn and Battle Creek – will be managed for the conservation of species at risk and migratory birds. Cooperation of the ranching community in this endeavor is also appreciated. Preserving these native grasslands is an important step towards securing habitat for 10 prairie species at risk, species also occurring in southeastern Alberta. Given that temperate native grasslands are one of the most endangered ecosystems on our planet, this is an important contribution to achieving our national goal for conservation of biodiversity.
To: Honourable Jason Kenney
Honourable Sonya Savage
Minister of Energy, Government of Alberta
Honourable Jason Nixon
Minister of Environment and Parks
Honourable Tanya Fir
Minister Economic Development, Trade and Tourism
cc: Nathan Neudorf, MLA, Lethbridge-East
Shannon Phillips, MLA, Lethbridge-West
From: Braum Barber, Chair
Southern Alberta Group for the Environment
Re: Coal Policy and Southern Alberta
Effective June 1st, 2020, the Government of Alberta rescinded the land classification system in the ‘1976 Coal Policy’ including categories 2, 3 & 4 which set some restrictions on the exploration and mining of coal along the eastern slopes. Information Letter 2020-23 issued by the Government of Alberta states: “The coal categories are no longer required for Alberta to effectively manage Crown coal leases, or the location of exploration and development activities, because of decades of improved policy, planning, and regulatory processes.” Media reports have stated that the Government of Alberta has deemed the 1976 Coal Policy ‘redundant’ with newer regulations.
Would you please inform SAGE specifically which ‘newer regulations’ (and which sections of those regulations) have been implemented that protect the headwaters and airshed of southern Alberta from open-pit coal removal?
Strategic directions in the South Saskatchewan Regional Plan 2014-2024 (SSRP) reaffirm previous land use plans for Alberta’s Eastern Slopes in that “headwaters protection is the priority for both water supply and water quality.” SSRP (p. 61) contemplated a review of coal categories in the 1976 Coal Policy, but only for the South Saskatchewan planning region, not the entire province, and in the context of approved land use plans. The subregional Livingstone-Porcupine Hill Land Footprint Management Plan (2018) (LFMP) places limits on human footprint and recognizes the need for restoration of 'legacy' footprint because of impacts to biodiversity and watershed integrity. Within the LFMP the Alberta Government defined regulatory limits on motorized access and committed to develop thresholds for spatial human footprint by 2019 (Section 2.2.5 and 3.1.2) as well as an Eastern Slopes Restoration Strategy by 2019 (Section 2.4 and 3.2.7). These commitments have not been met and yet surely must be for informed “land use decisions about where coal exploration and development can and cannot occur” (SSRP p. 61). Would you please provide SAGE updates on progress towards defining thresholds for spatial footprint and an Eastern Slopes Restoration Strategy?
The results of a recent science-based assessment of cumulative effects of land uses in Alberta’s Southern East Slopes, show that the status quo of land uses presents substantial risk to native fish - Westslope Cutthroat Trout and Bull Trout, two federally listed Species at Risk [i]. Native trout species are an indicator of watershed integrity. The study concludes that preventing harmful future development and reclaiming current footprint is key to a healthy watershed.
Open-pit coal mining has a long and sordid history. Vegetation, soil and rock are stripped from large areas and dumped into valleys. Habitat for native plants and animals is destroyed. Large volumes of water are extracted. Leaching of ‘waste rock’ discharges contaminants to surface water and ground water, and fine particulates become air pollution. Even state-of-the-art open-pit coal mines have been implicated in increasing discharges of arsenic, lead, chromium III, selenium, and < PM10 fine particulates to the water and air. Based on World Health Organization classification of carcinogenic agents coal mining pollutants such as arsenic, cadmium, and beryllium are listed as Group 1 (known carcinogen); while cobalt, nickel, and lead are listed as Group 2 (possible carcinogen) [ii]. Particulate pollution causes respiratory illnesses. Only a year ago, U.S. legislators sent a letter to the premier of British Columbia over concerns of water pollution from coal mining in the Flathead, responding to measured increases in selenium in transboundary waters. Selenium is bioaccumulative in aquatic food chains and causes developmental abnormalities and reproductive failure in fish and wildlife and domesticated animals (including humans).
SAGE is currently aware of three coal exploration and development projects underway on public lands in the headwaters of the Oldman River in response to government’s decision to remove the 1976 Coal Policy and its zoning restrictions. These projects are Atrum’s Elan Project (230 sq. km.) and Montem’s Chinook Project (100 sq. km) and Tent Mountain Project (20 sq. km). In addition, Riversdale Resource’s proposed Grassy Mountain Project (28 sq. km) on private land is expected to go to hearing before a joint federal provincial review panel this fall. The innuendo that our land and water remain safe from open-pit coal mining in the headwaters is belied by an announcement from Atrum Coal:
'Atrum's flagship Elan Hard Coking Coal Project in southern Alberta (Elan Project) is located on tenure that is currently deemed to be Category 2 land. Under the existing policy, Category 2 designation refers to land that is generally considered not to be appropriate for open pit coal mining. This meant that any open pit permitting approval for Elan would have required an exemption to be granted. The repeal of the policy means that the prior categorization of lands is no longer relevant for Atrum'. [iii]
As we understand this statement, the rescinding of the coal policy has been designed to reduce barriers for open-pit mining along the eastern slopes of the province, home to our headwaters.
We suspect that Montem and Atrum were consulted by government in making its decision to rescind the Coal Policy and provide ‘certainty for industry’. However, the intent of the SSRP (p. 62) appears to be violated by lack of “coordinated involvement of other governments, aboriginal peoples, stakeholders, partners and the public” in the government’s decision to open public lands in the subregion to coal exploration and development. Would you please provide SAGE documentation of any consultations that has occurred in the review of Coal Policy categories?
We understand the importance of economy in government decision-making. Sonya Savage, Minister of Energy, has stated: “Rescinding the outdated coal policy in favour of modern oversight will help attract new investment for an important industry and protect jobs for Albertans.” From the perspective of SAGE, however, this decision fails to consider the long-term health of the natural environment that provides clean water and clean air for Albertans, assets of immeasurable value. And it fails to consider other economic drivers in southern Alberta, including the greater potential for recreation and tourism.
We look forward to your responses to our concerns. SAGE remains committed to advocating for a healthy and sustainable natural environment that benefits Albertans in the long term.
[i] Cumulative Effects of Land Uses in Alberta’s Southern East Slope Watersheds – Final Report.
Alberta Chapter of The Wildlife Society
[ii] World Health Organization
[iii] Atrium Coal
To: Honourable Jason Nixon, Minister, Alberta Environment and Parks email@example.com
Cc: Nathan Neudorf, MLA Lethbridge East Shannon Phillips, MLA Lethbridge West
March 19, 2020
Re: Alberta Parks
Dear Mr. Nixon,
The virtue of parks, both big and small, is found not only in the opportunity for Albertans to experience and appreciate the natural world and inspiring landscapes, but also as a local destination for families and communities of people to gather. They are the places where Albertans celebrate important events in their lives. They are also enduring places of solitude and respite. They are places where school children and adults practice citizen science. They are places where non-human species survive.
It is the fact that these parks are uncrowded that lends to their appeal and their worth for Albertans – uncrowded as an advantage, rather than underutilized as a commodity.
Well-managed parks in Alberta provide consistent and quality amenities that are affordable to everyone: clean facilities, potable water, and day-areas with picnic tables and hiking trails. These parks are also areas protected by Parks staff from rowdiness and vandalism, offering safe and low-stress places for Albertans to recreate.
Closing, downgrading, and privatizing the management of 175 parks in Alberta will result in the deterioration and ruin of valuable infrastructure with the concomitant social and environmental costs of abandonment.
In addition to local users of the Alberta Parks system, these parks offer destinations for tourism and provide revenue to small businesses and jobs for many people living in small towns located near parks. In an era when diversification of the economy is paramount, it is a wonder that the economic benefits of provincial parks would be disregarded.
In our region, Park Lake was established in 1932 and was among the first provincial parks in Alberta. The park has served local people, including the citizens of Lethbridge, for these past 88 years as a family destination offering camping, swimming and beach activities.
The closure of this park would be an incomprehensible loss.
Abandoning years of investment and disregarding the legacy of enjoyment by Albertans is, simply, shameful. The 175 parks being considered for closure or private management will be left unprotected and unserviced. Opportunities for recreation will be considerably diminished. Ending long-term environmental programs for controlling invasive species will put these local ecosystems at risk.
The Southern Alberta Group for the Environment opposes this policy direction and hopes that the Government of Alberta will reconsider this wholesale shift in our quality of life in Alberta.
Preserving these longstanding amenities costs nothing but a little greed foregone. As Kevin Van Tighem has said, “We are where we live, we are how we live; we are our environment. We are not separate; we are wholly integrated.”
Alberta parks are where we live and how we live.
To: Honourable Jason Nixon, Minister, Alberta Environment and Parks firstname.lastname@example.org
Cc: Nathan Neudorf, MLA Lethbridge East Shannon Phillips, MLA Lethbridge West
March 19, 2020
Re: Sale of Public Land in the Municipality of Taber (SE 31-9-13-W4)
Dear Mr. Nixon,
It is the understanding of the Southern Alberta Group for the Environment (SAGE) that the public land being offered for sale by the Government of Alberta (SE 31-9-13-W4) consists of native prairie and wetlands, both of which provides needed environmental habitat in the southern region of the province for species at risk including Sprague’s pipit, the Northern leopard frog and many others. [i]
Furthermore, grasslands and wetlands provide important environmental services including carbon sequestration and drought resiliency, vital for any response to climate disruption caused by anthropogenic global warming. Native prairie and wetlands represent some of the most endangered ecosystems on the planet and they are key components in maintaining ecological integrity in an environmentally fragile region like southern Alberta. These key components continue to be unconscionably diminished by this government to our collective detriment.
We encourage the government to withdraw this land for sale and its conversion to alternative uses.
Furthermore, we encourage the Government of Alberta to increase efforts to protect native prairie and to sustain grassland ecosystems within the regional plans developed under the Land Use Framework (LUF). In particular, we support identification of public land that should be retained and managed for the protection and maintenance of biodiversity and species at risk and the other ecological goods and services that native ecosystems provide. We also encourage the government to adopt regulations that clearly define procedures to be used for public land sale, including the requirement for public notice and meaningful consultation.
[i] A Guide to Endangered and Threatened Species at Risk in Alberta.
To: Honourable Jason Nixon, Minister, Alberta Environment and Parks
Cc: Nathan Neudorf, MLA Lethbridge East
Shannon Phillips, MLA Lethbridge West
29 February 2020
From: Braum Barber, Chair, Southern Alberta Group for the Environment (SAGE)
Re: Implementing Plans for the Livingstone-Porcupine Hills area and Castle Parks
Dear Mr. Nixon,
The Southern Alberta Group for the Environment (SAGE), based in Lethbridge, is a non-profit, volunteer organization founded in 1984 that advances and advocates environmental issues for a healthy and sustainable community. We support managing land uses in the headwaters of the Oldman River to protect water quality and sustain biodiversity while accommodating nature-based recreation as appropriate. To that end, we are contacting you to request that you proceed with implementing the recently approved management plans for the Livingstone-Porcupine Hills area and Castle Parks.
For many years poorly planned industrial developments and unmanaged motorized recreation activities have increased in the Oldman River headwaters to the extent that ecological integrity is compromised. In 2018 the Alberta government approved plans to protect headwaters and manage land uses for environmental sustainability following direction provided by the South Saskatchewan Regional Plan (2014- 2024) and considering sound, science-based information about headwaters ecosystems as well as results of extensive consultation with key stakeholders and the general public. These approved plans are:
* Livingstone-Porcupine Hills Land Footprint Management Plan (May 2018)
* Livingstone-Porcupine Hills Recreation Management Plan (May 2018)
* Castle Provincial Park and Castle Wildland Provincial Park Management Plan (May 2018)
We understand that your Department, at your direction, is hesitating on implementing these plans as approved and is suggesting modifications to benefit motorized recreation use. This direction suggests a lack of commitment to headwaters conservation and lack of equity towards non- motorized recreation use. It also signals a lack of respect for the extensive planning and consultation processes that resulted in the approved plans.
Many Albertans participated in good faith in these government processes.
We ask that you honour the outcomes.
To: Nathan Neudorf, MLA Lethbridge-East
Cc: Shannon Phillips, MLA Lethbridge-West
January 14, 2020
From: Braum Barber, Chair, Southern Alberta Group for the Environment (SAGE)
Re: Canadian Energy Centre
The Southern Alberta Group for the Environment (SAGE) is a non-profit, volunteer organization that advances and advocates environmental issues for a healthy and sustainable community. We met with MLA Neudorf on Dec 6, 2019, and appreciated his open and intelligent understanding of the key environmental matters we raised.
We understood from statements made by the United Conservative Party (UCP) that the Canadian Energy Centre would become a source of ‘energy literacy’ that would “elevate the general understanding of Alberta’s energy sector, and help the province take control of its energy story.” And that it would centralize data and research “to reinforce this story with factual evidence for investors, researchers and policy makers.” [quotes from Drew Anderson, Alberta's energy 'war room' launches in Calgary].
It is laudable to provide a narrative on oil & gas production in Alberta based on facts and reasoned argument – it is understood that a narrative helps people manage political, social and economic events by simplifying the story, but not by distorting the story which would lead to issues around credibility.
SAGE is concerned Canadian Energy Center (CEC) is failing to provide objective narrative, data and research as promised.
To illustrate our concerns, please refer to the attached addendum regarding one CEC contribution titled, Call to shutter Canada’s oil and gas industry ignores opportunity to reduce world’s carbon footprint, published on December 31st, 2019. This article is in response to an Opinion by Bill McKibben of 350.org published in The Globe & Mail 30 December 2019.
In this Opinion piece to Canadians, McKibben argues that Canada must keep its bitumen in the ground to help avoid runaway climate change. Understandably, it may be a bit galling to the Government of Alberta for the province to be singled out as a major contributor of carbon dioxide and methane emissions related to oil & gas production, refining, transportation and combustion as a fuel. To be fair, Mr. McKibben is consistent in his criticism of all oil & gas producers, as well as massive deforestation throughout the world. Regardless, based on its mandate, the CEC is expected to rise above rhetorical commentary that displeases the Government of Alberta and provide a factual narrative to a discerning public.
It is our observation, based on the addended critique, that the CEC is not providing a narrative appropriate for a government-sponsored communication tool. It does not adequately parse the terms of discussion, nor does it provide independent resources or primary-source data. It could be argued that by its failure to adequately narrate the context and issues, it risks losing credibility as an objective resource for citizens, investors, and other governments. This diminishes the image of integrity that Albertans expect from its government. The public relations function of Canadian Association of Petroleum Producers (CAPP) is adequate to the task of defending the industry from ‘misrepresentations’. If the Government of Alberta is to participate in these sorts of communications, it is incumbent for the government to provide fact-based narrative. After all, the times seem to be changing in the energy industry, and future government revenues and employment opportunities for Albertan are dependent on sound decision-making.
In general, SAGE supports the idea of a centralized source for objective, fact-based narrative and robust data.
As a recommendation, it might be fruitful to expand the mandate of the Canadian Energy Centre to include a factual narrative on the emerging renewable energy industry as well as other Canadian sources of energy including hydro and nuclear, and to include resources for reducing emissions from the combustion of fossil fuels both in the home and in Alberta’s industry.
It would be useful for the Government of Alberta to take a lead in creating a world-class process for transitioning our economy from one strength to the next.
Addendum: Critique of:
Call to shutter Canada’s oil and gas industry ignores opportunity to reduce world’s carbon footprint.
Published by the CEC, 31 December 2019.
This article is in response to an Opinion by Bill McKibben of 350.org published in The Globe & Mail, 30 December 2019.
In this Opinion piece to Canadians, McKibben argues that Canada must keep its bitumen in the ground to help avoid runaway climate change.
The first criticism offered by the CEC’s in response to this Globe & Mail Opinion is that McKibben fails to provide evidence of the ‘inexorable math’ that he references. Providing references is always difficult in word-limited Commentary in a newspaper, but not so much on an article provided online – like the one we are using as an example. The ‘inexorable math’ McKibben refers to is most likely the series of assessments provided by the Intergovernmental Panel on Climate Change (IPCC) since 1990.
The CEC article defends the record of oil & gas production in Canada by stating: “In 2014, Canada’s total share of the world’s CO2-equivalent emissions was 1.6 percent […]” and that this value had dropped compared to 2005, as emissions in other countries have increased more quickly relative to Canadian greenhouse gas emissions. This trope has been quite popular in defending Canadian total emissions, but only as a rhetorical response – it is not what one would expect from an organization designed to provide ‘holistic’, fact-based narratives.
A 1.6 percent contribution on the surface does seem insignificant compared to countries that contribute much larger emissions, but it is less impressive when one considers that Canada accounts for less than 0.5 percent of the world population. This suggests that the Canadian economy produces over 3 times its share of greenhouse gas emissions.
Another way to present the same data is on an emission per capita basis from fossil fuel combustion (Wikipedia: List of Countries by Carbon Dioxide Emissions), which has Canadians at about 16.9 tonnes/capita compared to a world average of 4.9 tonnes/capita.