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.
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 December 14, 2020

 To:       Nathan Neudorf, MLA Lethbridge-East

cc:       Shannon Phillips, MLA Lethbridge-West
            Joint Review Panel: Grassy Lake Coal Mine

 RE:      Coal Mining in the Oldman River Headwaters & Water Abstraction

The Southern Alberta Group for the Environment (SAGE) is greatly disappointed with the UCP government’s unilateral decision to open another 2000 hectares of land in our headwaters for coal extraction. It defies comprehension that this lease offering would be advanced just after the public hearing on the Grassy Mountain Coal Project concluded and prior to the Joint Review Panel making its recommendations.

Proceedings of the Joint Review Panel hearing for the proposed Grassy Mountain Coal Mine include serious, deeply concerning issues regarding impacts on water and air quality, human health, adjacent residents and local communities, indigenous traditions, wildlife habitat and migration corridors, species-at-risk, a nascent ecosystem-based tourism industry, as well as the availability of water for the ecosystem and downstream users. There are lessons to be learned from over two dozen sound scientific studies in the Appalachians which found that mountaintop removal mining devastates ecosystems, pollutes water and air, and negatively impacts public health including statistically significant increases in rates of cardiovascular disease, kidney disease, chronic lung disease, cancer, birth defects and death.

The UCP government has recently indicated its intention to bypass established water transfer markets in the Oldman River Basin to make allocations freely available to coal companies. Bypassing established processes and expectations for water allocation and abstraction in order to expedite coal mining, without public consultation, undermines trust in fair dealings with the government. In economic terms, perceived unfairness and an additional degree of uncertainty in the equity of exchange practices increase transaction costs to industry.

The UCP machinations around water policy and allocation appear to be motivated by the proposed Grassy Mountain coal mining application: one wonders what this government has in mind to provide the required water for another 840 square kilometers of open-pit coal mining operations currently being offered? It raises questions on what other accommodations have been promised to potential bidders, which may do more to inflame rather than reduce the existing climate of concern and uncertainty about coal mining in our headwaters. As with the decision to rescind the coal policy it shows a flagrant disregard for public opinion, due consultation processes and outcomes of regional land use and water management planning.

Finally, and of most concern, significant water pollution has been measured in the Elk and Fording rivers downstream of extant coal mining operations, with evidence of negative impacts on aquatic ecology and sources of drinking water. There is no indication that there is the long-term will or the technology for the coal operators to cost-effectively remove contaminants from the water before they enter our river systems. Some of these contaminants will threaten species-at-risk and may cause enduring, bio-accumulative impacts on downstream use, including natural ecosystems, municipal drinking water, irrigation and intensive livestock operations. In other words, there is no point trading temporary gains for permanent losses for a livable future in the region.

In summary, the unilateral decision to promote coal mining on the Eastern Slopes and in our headwaters risks the long-term welfare of our economy, our wildlife, our ecosystem and our own health.

The proposal to greatly expand coal mining in our headwaters also requires much greater public consultation; it requires a comprehensive water allocation plan; and it requires greater consideration of long-term cumulative effects of water contamination to downstream users. It should also be emphasized that the decision to sell more coal mining leases prior to the recommendations from the Joint Review Panel is unutterably inappropriate.

 

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:

Response from Hon. Jonathan Wilkinson

 

20 October, 2020

Hon. Jonathan Wilkinson
Minister of Environment and Climate Change
Government of Canada
Email: ec.ministre-minister.ec@canada.ca

Hon. Marie Claude Bibeau
Minister of Agriculture and Agri-Food
Government of Canada
Email: Marie-Claude.Bibeau@parl.gc.ca

Hon. David Marit
Minister of Agriculture
Government of Saskatchewan
Email: ag.minister@gov.sk.ca

Dear Minister:

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
                        Premier

                        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
       https://monographs.iarc.fr/list-of-classifications

[iii]  Atrium Coal
      https://monographs.iarc.fr/list-of-classifications





                                                                                             













To:   Honourable Jason Nixon, Minister, Alberta Environment and Parks aep.minister@gov.ab.ca
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 aep.minister@gov.ab.ca
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.
Furthermore, Alberta, if it were a country, would be over 60 tonnes/capita. 

The point is, there are a number of ways that the same emissions in the same country can be presented. It is not helpful to present the most benign relative values in the absence of absolute values, as it appears to be deceptive (whether or not it was intended to be so). To be clear, the ‘state’ is a relatively arbitrary concept for the comparison of greenhouse gas emissions by country – Why not emissions per square kilometer of land-base? Why not emissions per GDP? Why not emissions per heating degree-day representing our climatic conditions?

Many would argue that the emissions per capita is more relevant to emission reduction targets, as it implies equity between people – that everyone has an equal quota of fossil energy (energy that is directly linked to their affluence). Even this would ignore the historical emissions with which Canada has developed a robust, technologically advanced economy – which, it might be argued, means Canadians should be producing emissions at a rate much lower than the world average. And it ignores the fact that greenhouse gas emission values do not consider our imports of carbon- intensive materials and manufactured products – those emissions are attributed to the developing economy.
 
The benefit of an organization that would provide fact-based narratives would be to provide clarity in such complexity. This leads us to the more direct argument presented in the article that defends the two largest producers of fossil energy in Canada, Suncor and Canadian Natural Resources, who own and operate substantial oil sands assets within their international portfolios. The article refers to journalism from JuneWarren-Nickle’s Energy Group that these companies have lowered their emissions per barrel of oil produced by 10 to 20 percent since 2014. This is commendable, and one would hope any competitive industry would continue to improve their processes.
 

The presentation of reductions in the emission intensity of oil production raises a few concerns, however. There is no clear statement that these improvements originate in oil production in Canada or, more particularly, in bitumen production in Alberta. It also does not specify exactly what these emissions relate to. In oil & gas production, there are many sources of emissions, and many variables between different types of production that contribute to greenhouse emissions – many of them hard to monitor and quantify (see Figure 1)







Figure 1: IHS Markit

 

 
The numbers quoted in the article appear to be related to emissions created during production, and excludes transportation and refining. Some clarity on this would be important. The quoted values also fail to make any broad comparisons to oil produced in other regions of the world.

The following chart (Figure 2) suggests that Suncor and Repsol have two of the highest carbon intensities for oil production, mainly due to their exposure to bitumen and heavy-oil holdings.

 



 

Figure 2:Bloomberg Company Filings


These concerns are further exacerbated by recent research published in the journal Nature Communications by John Liggio of Environment Canada that states: “four major oilsands mines are releasing an average of about one-third more carbon dioxide per barrel of oil than they report” (Canada Oil Sands CO2 Emissions Hugely Underestimated).

 
Again, this critique is not meant to suggest that the CEC article is intentionally trying to distort the evidence, but it does suggest that more needs to be done by the CEC to meet the expectations of the public for a well-researched and presented narrative with primary-source data.
 

The CEC article begins to wrap up with a statement that ‘if we don’t produce it, someone else will’ which may or may not be accurate, depending on the future demand for oil. And, as the article states, this depends very much on the ability of the world in meeting carbon-reduction targets. After relating some data about natural gas and LNG (which McKibben doesn’t talk about), and a couple of opinion polls, the CEC article concludes: “Canada has a role to play in reducing global GHGs, but our decisions need to weighed by facts and measured holistically by our goals as a country, not by following misrepresentations and hyperbole slung at us from outside our borders.”
This is pure rhetoric: ‘misrepresentations’, ‘hyperbole’, ‘slung’, and the ever polarizing ‘outside our borders’ as if only honest critique can originate within our borders.

 
In general, the CEC article offers nothing more informative than the original Opinion by McKibben.
There is no discussion around Canada’s commitment to reduce greenhouse gases by 40% in the next decade and net-zero by 2050, and what that will mean for the oil & gas industry in Alberta.
Since bitumen production contributes almost 10% of Canadian emissions, and since most of this will be used as fuel, further contributing to world greenhouse gas emissions, it seems obvious that much will have to be done to provide stable revenues and employment in Alberta in the future.
Defending the industry is the domain of the Canadian Association of Petroleum Producers (CAPP), and should remain in this domain.
The CEC would be providing a service to Canadians if it were to better meet its mandate of providing a fact-based narrative of the future of energy in the country.


                    











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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.”


Sincerely,

Braum Barber
Executive Director

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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.


Sincerely,

Braum Barber
Executive Director

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19 April 2016

Hon. Lawrence MacAulay
Minister of Agriculture and Agri-Food
House of Commons
Ottawa, ON K1A 0A6

Lawrence.Macaulay@parl.gc.ca

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.


Yours sincerely,
Braum Barber
Chair

cc:
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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