Water, Water, Everywhere

Index:

The Alberta Emergency Statures Amendment Act, 2024 Surges Executive Powers under Water Act (here)
Presentation at Water for 2050 Symposium in Red Deer by Cheryl Bradley (here)
... Surface Water Allocation (here)
... Proposed Dams and Reservoirs (here)
Managing irrigation expansion to protect native grasslands and associated biodiversity (here)
Irrigation—When You’re In a Dry Hole, Don’t Dig Another One (here)
Assumptions About Irrigation Agriculture Expansion Called into Question (here)
Comments regarding proposed EID Snake Lake Reservoir Expansion EIA proposed Terms of Reference (here)
Running on Empty - Lorne Fitch (here)
More Irrigation in a Dry Land with Shrinking Rivers? (Lorne Fitch, P.Biol.) (here)
Review comments on Proposed Terms of Reference, Environmental Impact Assessment Report, for St. Mary River Irrigation District Proposed Chin Reservoir Expansion Project (here)
EIA of the “historic expansion of Alberta irrigation” including Chin Reservoir, Deadhorse Coulee Reservoir and Snake Lake Reservoir (here)
The River of Unfulfilled Expectations (Lorne Fitch, P. Biol.) (here)
International St. Mary and Milk Rivers Study Board (here)
Request for Action: Irrigation Expansion Project (here)
... Minister's Response (here)
How much water is needed to keep a river healthy? Understanding Instream Flow Needs (here)
Water Stewardship: Letter to Nathan Neudorf (here)
Water management a key issue in municipal elections (here)
Nathan Neudorf's letter muddies the waters (here)
Concerns regarding Proposed Alberta Irrigation Expansion Project Parternship of Alberta Government, Canadian Infrastructure Bank, Irrigation Districts (here)
Albertans Want to Know How to Manage the Demand on Limited Water Resources (here)
It's our river, but who gets the water? (here)
How Does Your River Look Today? (here) 

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October 10, 2024

[This post was originally published on ABlawg.ca]

The Alberta Emergency Statures Amendment Act, 2024 Surges Executive Powers under Water Act

https://ablawg.ca/2024/10/10/the-alberta-emergency-statutes-amendment-act-2024-surges-executive-powers-under-the-water-act/

For the pdf version, click here.

Excerpts:

[...]

This ABlawg post focusses on recent amendments to Alberta’s emergency legislation. We appreciate that although in truly unforeseen emergency circumstances it might be necessary for the Executive to exercise powers that depart from the day-to-day rule of law, the primacy of the core values of the rule of law requires that legislation that authorizes such departure must precisely define what constitutes an “emergency”, clearly limit the period of departure and direct how that period is to be determined, and strictly limit Executive powers to those that are required to deal with the emergency. This post concludes that the amendments, as they pertain to the to the Water Act (RSA 2000, c W-3), are largely overly broad and ill-defined to respect the core values of the rule of law.

[...]

Not defining “emergency related to water” is a significant omission: Is an emergency related to water something short-term needing immediate response, such as a tailings pond release into a water basin? Or could it include a long-term, predictable state of affairs like drought that could be addressed via effective rule of law water management? There is significant discretion placed on the Cabinet to decide what is an emergency related to water in light of the lack of a definition or criteria providing guidance. ...

[...]

Hence the amendment removes the rule of law requirement for a special Act of Legislature and
leaves it to Cabinet to order an inter-basin transfer for specified purposes. This results in a huge loss in government transparency and accountability, as well as loss in an opportunity for public participation and Indigenous consultation. This is especially concerning because, as discussed above there is no definition of or criteria on of what constitutes an “emergency related to water” and accordingly Cabinet has considerable discretion to approve inter-basin transfers.

Furthermore, the only bounds on the discretion to allow an inter-basin water transfer is that it must be done “for the purposes of human health, raising animals or public safety needs” (Water Act, s 107(2.1)(b)(ii)). These are broad categories indeed that potentially capture many scenarios. At what point is an inter-basin water transfer justified for the "purposes of human health, raising animals or public safety needs"? Is maintaining status quo water usage enough, even if the status quo involves water wastage or poor water management decisions? Is the entirety of municipal water use a matter of human health or public safety, or are there some aspects of municipal water use that are actually wasteful and thus should not be used to justify an inter-basin water transfer but rather should be addressed through improved water management? Without a definition of an “emergency related to water”, these bounds on discretion are not specific enough. And note that although the amendment does not specifically include industrial or commercial purposes it does not specifically exclude them either. They are not excluded by application of the statutory interpretation maxim expressio unius est exclusio alterus – “when one or more things of a class are expressly mentioned others of the same class are excluded” (Merriam-Webster.com Legal Dictionary). This legal maxim only applies to the same class of items or things. For example, a prohibition against spraying birch, maple, or elm trees would not prohibit spraying other hardwoods. But “human health, raising animals or public safety needs” do not form a class. They are disparate matters so the expressio rule does not apply. Accordingly, an inter-basin transfer could be ordered to address an industrial or commercial water shortage in an emergency provided that it is for a human health, raising animals, or public safety needs purpose. For example, a shortage of water for fracking or carrying out steam assisted gravity drainage processes in a drought might qualify if the purpose for a transfer is sufficiently tied to human health or public safety.

As well, there are not clear limitations on the duration of an inter-basin water transfer order. The provision states that Cabinet may authorize the Director to make an inter-basin water transfer only for the duration of an emergency, and it states that the Director may authorize such a transfer for a specified period of time. Does the “duration of the emergency” mean that an inter-basin water transfer order can only last as long as the emergency situation in fact, or does it mean the length of the emergency as determined in Cabinet’s discretion? Is the “specified period of time” meant to overlap with the period of the emergency or does this mean the Director’s authority lasts throughout the emergency situation but that they can make an order that outlives the emergency (but no longer than its end date as specified in the order)?

[...]

Inter-basin Transfers, Why be Concerned? Ecological, Economic, and Infrastructure Concerns

There is a dearth of scientific observation on the ecological impacts of inter-basin water transfers. As such, precaution is imperative.

However, the existing literature does provide that inter-basin water transfers may have physical, chemical, hydrological, and biological implications for both the donor and recipient basins. River basins have distinct characteristics, including acidity, turbidity, temperature, and chemical content of water, as well as the various species that reside within and near the aquatic environment. Inter-basin transfers result in the mixing of these distinct waters, leading to changes in chemical balance and habitat characteristics, and easing the movement of organisms that promote the introduction of invasive species and the spread of disease. More specifically, inter-basin water transfers may to lead to:

…the loss of biogeographical integrity, the loss of endemic biotas, the frequent
introduction of alien and often invasive aquatic and terrestrial plants and animals, the
genetic intermixing of once separated populations, the implications for water quality,
the frequently drastic alteration of hydrological regimes, the implications for marine
and estuarine processes, climatic effects, and the spread of disease vectors, amongst
many others.

The effect on hydrology is also important. Inter-basin water transfers can cause salinization and
aridification in the donor basin, while increasing water availability in the recipient basin, affecting groundwater levels. The change in water availability may stress both the water-reliant communities in the donor basin and the drought-tolerant communities of recipient basins, with the potential to permanently alter these ecosystems. Wetlands can be vastly altered by diversions. (Dieu Tien Bui et al, “Effects of inter-basin water transfer on water flow condition of destination basin” (2020) 12:1 Sustainability 338). Addition of water in the recipient basin may also cause salinization and water-logging of soils, thereby increasing erosion and channel scouring and destabilizing sediment in the receiving watershed, depending on the volume of transfer and the timing of the withdrawal. (Meghan Beveridge, Piping Water Between Watersheds: An Analysis of Basin-to-basin and Sub-
basin-to-sub-basin Diversions in Alberta, (Alberta: Water Matters, 2008) 8). For example, in
Australia, “transfers have increased both salinity and turbidity of all receiving waters in the
Adelaide/Whyalla region,” (B. Davies et al).

Greater sedimentation affects aquatic habitat and increases demands on water treatment. Water transfers may also be a source of increasing concentrations (reduced dilution) of salinity, metals or nutrients in donor basins due to diminished flowrates, as well as in receiving basins that may traditionally have lower agro-industrial loadings. In Brazil, it was observed that changes in the nutrient concentrations due to water transfers caused “accelerated algae growth in part of the receiving reservoirs and increased algal bloom risks.” (Hanlu Yan et al, “A Review of the Eco-Environmental Impacts of the South-to-North Water Diversion: Implications for Interbasin Water Transfers” (2023) 30 Engineering 161)

Higher concentrations of dissolved solids, pollutants, or nutrient loadings will have impacts on
human populations and industries that rely on sources of clean water. Even modest changes caused by inter-basin water transfers may have incremental and other cumulative impacts on water quality, habitat, and aquatic health on both a localized and system-wide basis (U.S. Army Corps of Engineers, “Potential Aquatic Ecological Impacts of Interbasin Water Transfers in the Southeast West-Central and South-Central Study Areas” (1996)).

And what about inter-basin water transfer infrastructure? Inter-basin transfers convey water from one river basin to another using non-natural means, such as pipelines, aqueducts, or canals. Infrastructure may also include dams and reservoirs to maintain water levels in donor basins. Depending on the distance and elevation change between the point of abstraction and the location the water is discharged into a different basin, large pumping systems could be required. Depending on the type of emergency being responded to, long pumping distances could be required, and the discharge locations would likely be upstream at higher elevations. If you consider the volume of water being moved and the upstream elevation change, pump size would be significant. Large pumping systems require significant amounts of electrical energy with related operating costs and greenhouse gas emissions. Infrastructure of this type would require long-term planning to build and would necessarily require the anticipation of the emergency. Long-term planning and construction for an emergency would suggest, contradictorily, that the emergency is anticipated and, therefore, preventable through water management.

What happens to the infrastructure once the emergency is over? Although the Water Act gives
Cabinet and the director considerable discretion regarding emergencies, certainly the underlying intention is that once an emergency ends so do emergency measures. Do emergency inter-basin transfers then cease? Are pipelines, aqueducts, canals, pumping stations, and other infrastructure decommissioned and removed and the land, ecological, and water body disturbances and impacts reclaimed? Or do the inter-basin transfers conveniently remain, having been executed without the benefit of planning, environmental assessment, public participation, Indigenous consultation and accommodation, approvals, and so on? As biologist Lorne Fitch cautions “these temporary diversions could have an annoying propensity to become permanent” (McKay).

[...]


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Consider the River in Watershed and Water Management
Cheryl Bradley, September 2024

Thank you for inviting me to this event that recognizes World Rivers Day, the 22nd of September 2024. World Rivers Day, launched by the United Nations in 2005, is a day to celebrate rivers and create greater awareness of the need to better care for our water resources. For me every day is rivers day.

Since moving to this province in 1971, I have had the good fortune to live, work and play along the prairie rivers of southern Alberta. My current hometown of Lethbridge straddles the Oldman River. I am mindful that the water I drink and wash-in comes from the Oldman, and for that I am grateful. For over five decades now, the Oldman, Bow, Red Deer and South Saskatchewan as well as Milk rivers have captivated my soul as I paddled their waters, hiked their coulees and camped in the shade of their riparian forests.

Prairie rivers are not just conduits of water. They are dynamic systems that since deglaciation twelve thousand or so years ago have evolved to integrate our region’s geology, landforms, climate, soils and lifeforms.  Through my graduate research on cottonwoods in the early 1980s and from subsequent observations I grew to understand and appreciate the interrelationships of river flows, channel morphology and life in aquatic and riparian ecosystems.  Cottonwoods have evolved to take advantage of spring floods, settling on new river bars created by shifting channels and growing their roots apace with declining flows. Mature cottonwoods stabilize river banks while sheltering songbirds, other wildlife and even humans. Eventually as the channel moves, old trees collapse into the river providing sheltering habitat for fish and other aquatic life during summer drought and spring floods. And so the cycle continues.

There are many such stories of intricate interconnection woven into river ecosystems. It troubles me that all of this has been put at risk by just over 100 years of human intervention.

The rivers I will consider in my talk today are the main tributaries of the South Saskatchewan River in Alberta - the Bow, Oldman and Red Deer. The Bow and Oldman Rivers join at Bow Island to become the South Saskatchewan River and contribute 40% each to its flow. The Red Deer is the smallest tributary and last to join, near the Saskatchewan border, contributing on average almost 20%.

The source of water for the Bow, Oldman and Red Deer rivers is mostly - 80% - snow and rain falling in watersheds of the Rocky Mountains and foothills where it runs off or percolates through groundwater into headwaters streams.  Kevin Van Tighem’s presentation a week ago conveyed the importance of maintaining and enhancing natural storage capacity in headwaters by discontinuing land uses that diminish capture of snow and rain and encouraging practices and natural processes that restore and maintain water retention and quality.

Although prairie watersheds, dominated by grassland and parkland, contribute very little to river flow, still the integrity of their ecosystems is critical for sustaining ample, clean water and is not immune from the impacts of human use.

Over the last century our settler society has changed river flows and triggered a wave of downstream ecological effects on prairie river ecosystems, altering everything from channel form and fish & wildlife habitat to water quality. We sought, and continue to seek, steady supply of water from rivers for household use, irrigation agriculture, hydro-electric power, industrial development and golf courses. Just as water is essential for a river’s survival and well-being, it is fundamental to our individual survival and our society’s well-being. However, wise words from those that know water and rivers better than me advise caution.

Roland Hall, professor of hydro ecology at the University of Waterloo states:

“The transition from water abundance to scarcity can occur within a human generation, allowing little time for society to adapt.”

Luna Leopold, a leading US geomorphologist and hydrologist states:

“…the management of water resources cannot be successful as long as it is naively perceived from an economic and political standpoint”…“Water is the most critical issue of our lifetime and our children’s lifetime. The health of our waters is the principal measure of how we live on the land”.

I want you to also hold in your mind a key difference in how we talk about river flow. Flow monitoring on river reaches altered by dams and water diversions measures actual flow. Natural flow is what would be in the river without our tinkering. Natural flow for a reach needs to be estimated using calculations that remove the effects of man-made infrastructure. During this presentation I will differentiate between actual flow that is measured and natural flow that is estimated.

Significant decline in natural annual flow has occurred during the period of record (several decades) for major rivers in the SSRB reflecting the effects of changing climate.  Declines range across watersheds from relatively modest to 20%.  Predictions of trends in natural annual river flow under changing climate are plagued with uncertainty, ranging from more to less than present. It is generally agreed among scientists that there will be changes in streamflow timing. Peak flows will occur earlier in the spring. Summer flow will decrease substantially.  Floods and droughts will be more extreme.

Since water licences first were granted in the 1890s, almost two-thirds - 62% - of the mean natural annual flow in the South Saskatchewan River in Alberta has been allocated for use.  The Bow and Oldman, as well as the South Saskatchewan sub-basin, were closed to new allocations in 2005 each with total water licence volume at 70% of mean natural annual flow. In other words, in a year of historical average snowfall and precipitation in these basins, 20% more water is allocated for withdrawal than for remaining in the river.  Licensed allocation is fixed regardless of weather, so in wetter than average years it is lower than 70%.  In drier than average years the proportion of flow allocated for withdrawal is higher than 70%.

More than two years in a row with lower than average runoff in the headwaters risks water shortage for licensed human use in the Bow and Oldman basins. Storing water in reservoirs buffers shortage to some extent, but eventually there is insufficient water to fill existing reservoirs. This was the situation for the Oldman and St. Mary reservoirs early this past spring after two to three years of below average precipitation in the headwaters.  Without effective efforts to reduce current levels of allocation, as well as water use, and to ensure sufficient water for the rivers, water managers in these basins will frequently be relying on prayers for rain.

The Red Deer River has a much lower level of allocation than the Bow and Oldman amounting to about one-fifth - 18% - of historical mean natural annual flow at its mouth.  Residents in this subbasin, and the river itself, are in a much better position to be resilient to changing climate.

In the Red Deer subbasin, unlike for the Bow and Oldman, water licences continue to be granted for new purposes. An allocation limit was set for the Red Deer River in the SSRB WMP (2006). The limit - 600 million cubic metres - amounts to about one-third – 35% - of mean natural annual flow historically. A temporary closure will occur at 550 million cubic metres allocation. Current allocation of 296 million cubic metres amounts to about half that limit. Recently MD Acadia & Special Areas have made application for a licence to withdraw 170 million cubic metres annually from the lower Red Deer River for the proposed East Central Alberta Irrigation Project. If the water license is granted total sub-basin allocation will rise by 60% approaching the limit on volume of water licences set in the SSRB WMP.

Irrigation agriculture is by far the biggest user of water in SSRB. As of 2017, approximately three-quarters - 72% - of the surface water volume allocated from rivers is for irrigation agriculture, varying from 87% for the Oldman sub-basin, 70% for the Bow sub-basin to 22% for the Red Deer sub-basin. The proportion of allocation for irrigation agriculture in the Red Deer sub-basin will rise to 80% if the East Central Alberta Irrigation Project proceeds.

The high level of human water use compounded by effects of a warming climate has resulted in actual annual flows measured at 40% below long-term historical average where the South Saskatchewan River enters Saskatchewan. Actual summer flow in the Oldman River at Lethbridge declined approximately 60% during the period 1912-2003 because of large diversions upstream into seven irrigation districts. In the South Saskatchewan River at Saskatoon, downstream of the Alberta border, actual summer flows have been reduced by 84% since the early 20th century in large part due to storage and withdrawals for irrigation agriculture in both Alberta and Saskatchewan. ­This situation prompts me to parody the title of a 1989 film, “Honey, we shrunk the rivers!” And we continue to shrink them.

My husband, biologist and author Lorne Fitch, opines “water in southern Alberta is confused from being given so much direction by humans”. Not only volume, but also the pattern of river flow is altered by our meddling. The Bow, Oldman and Red Deer Rivers and their tributaries are regulated by multiple dams, reservoirs and water withdrawals. There are 14 on-stream reservoirs in southern Alberta including the Oldman Dam reservoir, the Bassano reservoir on the Bow River and Glennifer Reservoir formed by the Dickson Dam upstream of the city of Red Deer. In addition there are 32 off-stream reservoirs to store water diverted from rivers through over 8,000 km of canals and pipelines.  Reservoirs have flooded approximately 57,000 ha (570 km2) of river and stream valley habitat. Deviation from natural river flow regime caused by all these dams and diversions is characterized by lower summer flow as well as by reduced peak flow in spring (except for extreme flood events).

Concerns about the effects of altered river flows on water quality and fish in southern Alberta led to assessment of instream flow needs beginning in the early 1970s. These assessments initially identified a single minimum flow – termed Instream Objective - required to dilute pollution and achieve acceptable water quality. Definition of legislated Instream Objectives spurred improvements to wastewater and runoff management by municipalities and industry.

Instream Flow Needs assessment evolved through the 1980s to consider not only base flows that would ensure adequate temperature and oxygen levels for fish survival during low flow periods, but also a pattern of flows, that would maintain suitable habitat for individual fish species at various stages in their life cycle - spring flushing flows for example. These Fish Rule Curves became a consideration in making decisions about new water licenses primarily in headwater rivers and streams where native trout reside.

Research in the 1980s and 1990s found maintaining a natural range of variability in river flows below dams and diversions applies not only to survival of fish but also to riparian forests. Results showed that spring flooding is needed to create suitable beds for tree seedling establishment and with decline in flow gradual enough for roots to maintain contact with the dropping floodplain water table. A maximum limit of 2.5 cm per day drop rate was determined. The operation plan for the controversial Oldman Dam (completed in 1991) includes gradual ramping down of flows after high spring floods to encourage seedling survival.

In the early 2000s, an integrated Instream Flow Need for fully protecting the aquatic environment was defined to inform water management planning within the SSRB. IFN recognizes the conservation value of natural stream flow variability. Rivers are naturally dynamic. IFN integrates seasonal requirements for water quality, fish habitat, riparian vegetation and to maintain channel form and function – all key attributes of river health.  The resulting flow regime would amount to about 80-85% of natural flows during times of moderate to high flow and natural flows or higher during times of low flow to dilute pollution from municipal and industrial wastewater treatment plants.

When these fully protective IFN are compared to what is actually allowed to flow in lower reaches of prairie rivers, the conclusion is that aquatic and riparian ecosystems are in declining condition. Reaches of the Bow and southern tributaries of the Oldman River - St. Mary, Belly and Waterton Rivers - below major dams and diversions are assessed as under particular stress from lower-than-natural flows. As a result the lower Oldman and South Saskatchewan Rivers downstream experience chronic low-level stress for aquatic ecosystems. Extensive scientific assessments of aquatic and riparian condition in 2003 and 2007 confirmed long term decline in river health due to over allocation of water.

The Approved South Saskatchewan River Basin Water Management Plan acknowledged this dire situation when it closed the Bow, Oldman and South Saskatchewan Subbasins to new water allocations in 2005 and set a Water Conservation Objective (WCO).  WCO is defined under Alberta’s Water Act as

“the amount of water necessary for the minimum protection of a natural water body or its aquatic environment”.

WCO for mainstem reaches in SSRB was arbitrarily set at 45% of natural flow or the already defined minimum Instream Objective (IO) +10%.  This was not science-based but rather a reflection of how much unallocated water might remain for aquatic ecosystems in these prairie river reaches. For the Red Deer River WCO was also set at 45% of natural flow with IO defined as 16 m3/sec upstream of the confluence of the Blindman River to Dickson Dam (i.e. upstream of Red Deer) and 10 m3/sec below the Blindman confluence.

Unfortunately, WCO conditions apply only to licences issued after 1 May 2005 and to some older licences which have provisions for retrofitting in-stream flow requirements. Many licence holders are not required to discontinue diversion in order to achieve the WCO in river reaches downstream of their withdrawal point. 

In the Oldman and Bow sub-basins, water required to meet licensed demand and WCO exceeds predicted natural flow in many years and particularly during the irrigation season in years with below average precipitation. In the Red Deer subbasin, there is still generally sufficient water supply to meet both licenced water demand as well as WCO because of the lower proportion of allocated natural flow.

In the last few years headwaters precipitation has been well below normal causing government to issue water shortage advisories across the South Saskatchewan River Basin. In Spring 2024 a Stage 4 drought was declared and four voluntary water-sharing agreements (Memoranda of Understanding) were negotiated among 38 major water users for the Red Deer River, the Bow River, the southern tributaries of the Oldman River (Waterton Belly and St. Mary rivers) and the mainstem of the Oldman River-South Saskatchewan Rivers. Two of the four water-sharing agreements were, and still are, activated including those for the Southern Tributaries and the Oldman River- South Saskatchewan River. Late spring rain brought relief to the Bow and Red Deer subbasins and drought-sharing agreements are not currently activated.

MOUs are not legally binding.  Their overall purpose is to voluntarily change the legal rule of first in time, first in right (FITFIR), which favours the interests of the irrigation districts (IDs), to an allocation rule that favours all other interests at the expense of ID interests. MOUs include statements about maintaining minimum instream objectives that are misleadingly referred to as ‘environmental flows’. Unfortunately these minimum IOs have become targets and there is no evidence that ecological health of rivers will be sustained. One water manager quipped “if the minimum wasn’t good enough it wouldn’t be the minimum”.

Under the MOUs over the past irrigation season, irrigation districts reduced the volume delivered per acre and municipalities implemented measure to reduce water use by 5-10%. Nonetheless dam managers captured and diverted into canals and off-stream reservoirs nearly all of spring peak flow. River flows downstream were flat-lined at minimum Instream Objective. This is not a healthy situation for rivers. Predicted increased drought risk for irrigated crops with higher temperatures and evaporation under climate change, and hence increased water demand from irrigation districts, will further exacerbate the situation in years to come. 

Water Conservation Objective for river reaches in the SSRB - 45% of natural flow or Instream Objective (IO) +10% - although woefully inadequate for protecting river health, is at least a recognition of a danger threshold and provides direction and opportunities to increase in-stream flows and improve the aquatic environment. Unfortunately a recent (July 2024) performance audit by Alberta’s Auditor General found that “the Department of Environment and Protected Areas

  • has no water conservation objectives in most basins
  • does not know if existing water conservation objectives are working
  • lacks robust processes to monitor water pressures, assess risks, and decide when water conservation objectives are needed
  • has ineffective processes to approve licences and monitor compliance, such as not enforcing licensee compliance with conditions.”

The Auditor General went on to identify consequences of not taking action:

“Failing to proactively identify the need for water conservation objectives, or to evaluate and update existing ones, increases the risk of water shortages. That could lead to higher costs, shortages of goods, and an inability to meet future water needs for people, businesses, and the economy. (p. 9)”

In a nutshell, the Auditor General implies that for our most precious natural resource – water – government management focuses on authorizing and facilitating withdrawal from rivers and little else.

The 2006 Water Management Plan for the South Saskatchewan River Basin (Alberta) was approved by Cabinet after extensive consultation and was introduced as reflecting the views of Albertans for a “balance between protecting the aquatic environment and water allocation of rivers”.  Twelve years later, in 2018, a review of implementation of the WMP was completed by Basin Advisory Committees for the four subbasins. Their review confirmed that many of the Plan’s recommendations had been implemented. For example, water transfers and holdbacks in subbasins closed to additional allocation were being approved. However “little progress had been made to restore and protect the long-term health of the aquatic and riparian environment”. WPACs found that “Water supply for economic growth, municipal growth and other needs has not been matched with aquatic environment requirements.”

Nonetheless, in fall 2020, the ‘largest one-time investment in Alberta’s history to expand irrigation’ was announced.  The investment totals $933 million comprised of a grant from the GoA (30%), a low-interest loan from CIB (50%) and investment by ten irrigation districts (20%). The Alberta Irrigation Modernization program (AIM) proposes 92 infrastructure modernization projects, three new off-stream reservoirs and 95,000 ha of expanded irrigation – that amounts to an 18% increase within irrigation districts.  Irrigation Districts assert expansion will occur using water saved through infrastructure efficiency improvements. Rivers do not get a share of these water savings even though there is substantial public investment in operating, maintaining and improving irrigation infrastructure.

Furthermore, in 2021 responsibility for operation, maintenance and assessment of provincially owned water management infrastructure such as dams and diversion canals was transferred from Alberta Environment to the new Department of Alberta Agriculture and Irrigation. Current direction for water management in southern Alberta is towards maximizing use of water for economic growth, primarily irrigation agriculture, with little consideration of impacts on rivers or overall environmental impact, such as potential loss of native grasslands and Species at Risk habitat from expansion of irrigated acres.

There are currently at least seven proposed water management projects involving dams, reservoirs and diversions in various stages of review regarding engineering design, cost and environmental impacts. The primary purpose of these projects is to support water supply for expansion of irrigation agriculture. Included are the three new or expanded off-stream reservoirs within irrigation districts, Ghost Reservoir expansion upstream of Calgary, Eyremore dam on the Bow River downstream of Bassano, the Ardley Dam on the Red Deer River 35 km east of Red Deer and the East Central Irrigation Project which would withdraw water from the Red Deer River near Bindloss.

Collectively these projects would flood dozens more kilometres of river and stream valleys in southern Alberta (more than 8,000 ha) and alter aquatic and riparian ecosystems for many more kilometres downstream.  Approximately 270,000 ha of irrigation expansion would result with potential impacts on quality of surface and groundwater as well as on GHG emissions, soils, native grasslands and species at risk. Water lost through evaporation from reservoirs and canals (~70 cm/year) would increase significantly. Alberta would be at increased risk of failing to pass half of natural flow and a minimum of 42.5 m3/s to Saskatchewan, as required under the Master Agreement on Apportionment.

Total cost to implement these projects would be at least $5 billion, not including inevitable cost overruns. It is proposed cost be largely borne by all Alberta taxpayers to benefit those who profit from irrigation agriculture. Irrigation agriculture does contribute to the economy of southern Alberta, but how much is enough and when do costs outweigh benefits? Is this the future we want for ourselves and our rivers, that water, our most precious natural resource, be primarily exported as processed foods?

Conservation and environmental interests including organizations of which I am part have been working together since spring 2021 to get consideration of the river in proposed water management projects. We are feeling rebuffed; our voices of concern for the rivers are not welcome by those with visions of economic, and political, gain from their support of expanding irrigation to fuel a growing food processing industry.

What we have learned about management of aquatic ecosystems in southern Alberta echoes the conclusions of the Auditor General and does not instill confidence that ecological integrity is being restored or protected.  Here are a few of our findings so far.

  • Public access to relevant information is lacking. For example, a May 2022 request to Alberta Agriculture under the provincial Freedom of Information and Privacy Protection Act for information on AIM program agreements between the GoA, CIB and Irrigation Districts remains unfulfilled. This two-and-a-half year delay leads us to conclude FOIP is broken. A request to CIB under the federal Access to Information Act for similar information was denied.

Our letter to the Prairie Provinces Water Board regarding their role in assessing proposed projects for implications to the Master Agreement on Apportionment has gone unanswered.

  • Although gross water diversions from rivers into irrigation districts is measured by government, individual irrigation districts are responsible to report on return flow to the river and water use within the districts, as well as on water saved from irrigation efficiency improvements. Irrigation District reporting and that of other irrigators is largely based on estimates, not actual metred measurements as occurs within urban municipalities. The lack of government oversight on use of this lion’s share of water allocation (4  billion cubic metres per year) is troubling.

We are concerned that expansion of irrigation acres and intensification of water use is and will result in the paradox of irrigation efficiency – a situation in which more efficient technology results in more, rather than less, water use. This has been demonstrated to occur in other semi-arid regions of the world where irrigation agriculture occurs. The potential consequences for already over-allocated rivers, and for the well-being of our society in the long term, are troubling to contemplate.

  • Questions have not been satisfactorily addressed about water management models being used to justify irrigation expansion projects, including the South Saskatchewan River Operational Model. The large uncertainty when linked with climate models is particularly concerning. In addition consideration of environmental implications for rivers are not adequately integrated into the modelling process which has been dominated by irrigation agriculture expansion interests.
  • Monitoring for the condition of the aquatic ecosystem in prairie river reaches of the SSRB by EPA is inadequate. It currently includes a) streamflow monitoring at ~40 hydrometric stations, b) water quality monitoring at 13 mainstem sites and, c) water temperature loggers at handful of sites outside of the Eastern Slopes. There is not regular monitoring of aquatic invertebrates or fish or other indicators of health. Fisheries management drought response is restricted to reducing angling pressure if needed. The basic assumption appears to be that if minimum flows are maintained, biodiversity will be protected. This assumption needs to be tested, and current water quantity and quality problems addressed, prior to intensifying water use in the basin.
  • Needs of aquatic ecosystems are not being integrated with water management models in assessing proposed projects. Our requests for basin-wide cumulative effects assessment of projects proposed under the AIM program, as well as other proposed water management projects, have been denied by both federal and provincial levels of government. This piecemeal approach to impact assessment undercuts a vision of a future with whole healthy ecosystems.
  • The Natural Resources Conservation Board determines if a water management project (above a set threshold) is in the public interest. Full participation in an NRCB hearing restricted to ‘directly-affected parties’. Non-government environmental organizations are denied standing and relegated to providing written submission that may or may not be considered.

I will wind down this presentation with eight suggestions for improvements to water management that considers the river. 

  • Enhance headwaters storage and yield by managing land use in the Eastern Slopes to support aquifer recharge, to protect wetlands and to encourage beaver ponds.
  • Improve public reporting of relevant and reliable information not only on river flows (natural and actual), but also water allocation and water usage. Improve monitoring of licensee compliance with requirements such as allocation and withdrawal limits. Audit licensee-submitted water usage to ensure it is accurate and complete.
  • Implement a process to monitor and publicly report on condition of river ecosystems. Evaluate the effectiveness of existing WCO in maintaining/restoring health of aquatic ecosystems and revise WCO as needed. Change the SSRB WMP to allow retroactive application of WCO to all licences. Implement a process to monitor achievement of WCO and publicly report results. Address failures to achieve WCOs.
  • Use reliable predictive water management models, with acceptable levels of uncertainty, to understand future climate and streamflow. Adjust growth aspirations and water use practices accordingly based on risk assessment and application of the precautionary principle. Improve forecasting of flood and drought.
  • Implement a regional, basin-wide cumulative effects approach to water management planning and in review and approval of applications relevant to surface water management – an approach that includes current projects as well as ones being seriously considered.
  • Require robust environmental impact assessment of all proposed water management projects involving dams and reservoirs. Avoid project splitting by including assessment of necessarily incidental activities such as expanding irrigated acres needed to pay for investment in expanded storage infrastructure.
  • Public interest in ecosystem health is legitimate and needs to be considered in NRCB review and decision-making regarding public interest aspects of projects. Broaden definition of “directly affected” to include legitimate
  • Develop and implement processes for integrated transboundary management. Conflict with neighbouring provinces is not productive. The recently created Canada Water Agency is a step in the right direction although provinces seems reluctant to engage.

Some rivers in the world have been granted legal personhood, including Quebec’s Magpie River. This designation recognizes rivers have rights – the right to flow, maintain natural rhythms, support biodiversity, and human caregivers to seek redress for damage. Prairie rivers have none of these protections…yet. Recently the Manitoba Southern Chiefs Organization initiated a court action for Lake Winnipeg to be granted legal personhood. They want a voice for the lake in public hearings of the Manitoba Hydro Commission.

We are at an inflection point in water management in southern Alberta.  For our rivers to continue to support us and the whole ecosystem, we need to recognize our natural limits and stay in balance with ecosystem function. The signs are clear that we have already crossed the tipping point.  Our prairie rivers are over- allocated and climate change will only worsen the situation. We need to prioritize the value of at least conserving what is left of instream flows and recognize that we have reached the natural limit of our water supply and plan accordingly.

Organizers of this World Rivers Day 2024 event in Red Deer have asked presenters to address the question “Will Alberta and the Red Deer watershed have adequate water resources in 2050?” I do not have the answer to that question. However I do know the actions we take now to secure water for healthy rivers will be important to ensure that, by 2050, they are not completely diminished and our society along with them.

I welcome questions and discussion. 

Sources:

Alberta Environment. 2003 (June). South Saskatchewan River Basin Water Management Plan Phase Two: Background Studies: finding the balance between water consumption and environmental protection in the SSRB.

Alberta Environment. 2006 (August). Approved Water Management Plan for the South Saskatchewan River Basin (Alberta). 44 pp.

Alberta Environment (Augustus Archampong). 2007 (June). Aquatic and Riparian Condition Assessment of the South Saskatchewan River Basin. Water for Life. 16 pp.

Alberta Environment. n.d. Alternative Water Supply Storage & Management Methods: Adding Tools to Alberta’s Water Toolbox.

Alberta Environment and Protected Areas. 2024 (Aug 9). South Saskatchewan River Basin Forecast Water Supply and Demand Graph (March – Sept Volumes).

Alberta Irrigation Districts Association. 2019. Report on Proposed Irrigation Storage Reservoir Ranking.

Alberta Irrigation Districts Association and WaterSMART Solutions Ltd. 2024 (March). Assessment of Strategic Management Projects to Support Economic Growth Final Report. 203 pp plus Appendices.

Auditor General of Alberta. 2024 (July). Surface Water Management Performance Audit Environment and Protected Areas. 20 pp.

Bankes, Nigel. 2024 (May 1). Alberta’s Water Sharing “Agreements”. University of Calgary Faculty of Law ABlawg.ca.

Basin Advisory Committees for the Bow River, Oldman River, Red Deer River and South Saskatchewan (sub-basin) River. 2018. Review of the Implementation of the Approved Water Management Plan for the South Saskatchewan River Basin.

Benson R.D. and Rood S.B. 2018. Bringing twentieth-century water projects into the twenty-first century: The case for revisiting dam operations in Alberta. Canadian Water Resources Journal 43:3 335-346.

CBC News. Mar, 6 2024. In this drought year, Alberta’s water allocation is under the microscope. Here’s what the data says.  https://www.cbc.ca/news/canada/edmonton/in-this-drought-year-alberta-s-water-allocation-is-under-the-microscope-here-s-what-the-data-says-1.7133575.

Clipperton G.K.. C.W. Koning, A.G.H. Locke, J.M. Mahoney and B. Quazi. 2003. Instream flow needs determinations for the South Saskatchewan River Basin, Alberta, Canada. 271 pp.

Klohn-Crippen-Berger. July 2024. St. Mary River Irrigation District Chin Reservoir Expansion Environmental Impact Assessment Summary (Vol 1) and Socio-Economic Assessment (Vol 3).

Lalonde K., B.  Corbett and C. Bradley. 2005. Southern Alberta’s Watersherds: An Overview. Prairie Conservation Forum Occasional Paper Number 5. 52 pp.

Rood, S., Samuelson, G.M., Weber, J.K., and Wywrot, K.A.  2005.  Twentieth-century decline in streamflows from the hydrographic apex of North America.  Journal of Hydrology, 306: 215-233.

Savage, Candace. 2024 (Aug) A prayer not a protest: The South Saskatchewan River is under unprecedented pressure. Now, a major irrigation project is set to expand. Canadian Geographic (Aug 02, 2024).

Schindler D.W. and W.F. Donahue. 2006. An impending water crisis in Canada’s western prairie provinces. Biological Sciences 103(19) 7210-7216.

Seneka M. and Z. Islam. 2014. Development of a Simple River Flow Quantity Index for Water Resources Management in Alberta. Paper presented to CSCE 2014 General Conference, Halifax.

Stantec Consulting Ltd. 2014. Red Deer River Basin Flood Mitigation Study Final Report. 211 pp.

Wood Environment & Infrastructure Solutions. 2020. Bow River Reservoir Options Phase 1: Conceptual Assessment. 99 pp. plus appendices

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Surface Water Allocation:

 

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Proposed Dams and Reservoirs:

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May 8, 2024

Dear Minister Schulz, Minister Sigurdson, Minister Loewen and Minister McIver

Re: Managing irrigation expansion to protect native grasslands and associated biodiversity

Recent proposals for over 100,000 hectares (250,000 acres) of irrigation agriculture expansion within the South Saskatchewan River basin have raised several concerns about environmental impacts, including potential loss of native grasslands.

Native grasslands are valued by Albertans as habitat for a broad diversity of plants and animals, including over two dozen species at risk. Southern Albertans benefit greatly from the ecological goods and services native grasslands provide such as water storage, carbon storage, erosion control, pollination and pest control. Native grasslands support ranchers in sustainable livestock production. Conversion of native grassland for expansion of irrigated cropland would compromise these invaluable and irretrievable assets.

In acknowledging the significant value of native grasslands, the approved South Saskatchewan Regional Plan 2014-2024 (Amended 2018) (SSRP) establishes a regional outcome that “Biodiversity and ecosystem function are sustained through shared stewardship”. Regional objectives specify that “Intact grassland habitat is sustained” and “Species at risk are recovered and no new species at risk are designated”.

Reservoir and other infrastructure development would flood native grasslands and/or impact habitat for species at risk at proposed project sites including Chin Coulee, Deadhorse Coulee, Snake Lake and potentially as part of the MD Acadia Special Areas project. Proponents of irrigation expansion assert that, in keeping with the direction established in the SSRP, expansion of irrigated cropland will occur on already cultivated parcels and not lead to conversion of native grasslands. However, legislation and policy governing decisions about expanding irrigation acres fail to support shared stewardship for sustaining native grasslands.

Gaps include the following that are described more fully in ENCLOSURE 1:
- Lack of a regulatory requirement in the SSRP prohibiting conversion of native grasslands to cropland on public land.
- Lack of regulatory and policy mechanisms for municipalities when implementing irrigation expansion projects (e.g. Special Areas, M.D. Acadia) to prevent loss of native grasslands on municipal and private land.
- Lack of land classification standards and land assessment criteria that preclude adding parcels of native grassland (and parcels of other ecological significance) to Irrigation Districts' assessment roles. Furthermore there is a lack of ability for an Irrigation District, under the Irrigation District Act (IDA) when making a decision about an application to add a private parcel to the assessment role, to deny approval on the basis that native grasslands or species at risk will be impacted.

For the complete letter, click ... here


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Irrigation—When You’re In a Dry Hole, Don’t Dig Another
Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a former Adjunct Professor with the University of Calgary.

One definition of a consultant is someone who looks at your watch and tells you what time it is. The recently released consultant’s report— Adaptation Roadmap for the SSRB: Assessment of Strategic Water Management Projects to Support Economic Development in the South Saskatchewan River Basin— is a mirror reflecting back the aspirations of the irrigation lobby. In fact, it provides the answer—more dams and reservoirs—instead of dealing with some foundational issues.

When facing down drought that experts say may persist, moving from supply side management of water and dealing with water demand seems prudent. The real question is, when supply diminishes how to adapt to less water.

Adaptation doesn’t happen by building more reservoirs. If this is viable, we may be the first in history to outrun the impacts of a shrinking water supply. No one else has been able to perfect this magic.

Our rivers already have less flow in them and flows are expected to decline. Reservoirs don’t create water, they just store what is available, but waste much in the process. Evaporation losses are almost a metre of water per year from each. That’s water lost to the rivers.

When stuck in an irrigation growth paradigm, it doesn’t register there is a limit to such growth. The proposed result of this “study” is a classic case of “running faster and faster to stay in the same place.” There are already 56 reservoirs in southern Alberta dedicated almost wholly to irrigation. Will building 8 more be the answer? “Yes,” says the irrigation lobby, because it’s the perennial answer.

No matter how much lobbying is done, how many new dams and reservoirs are built, climate change cannot be outrun. Even if we bankrupt the province with all the suggested engineering hubris, to the suggested tune of 5+ billion taxpayer dollars, this adaptation roadmap could lead to a dead end.

Instead of more holes that may or may not be filled with water, a different path is required. Reluctance to deal with water demand creates a wicked problem that the sales pitch in the report fails to address. If you always do what you’ve always done (build more dams and reservoirs), you’ll always get what you’ve always got (increased demand and issues of water supply). It’s a cycle in which effort to solve a given problem results in aggravation of the problem or the creation of a worse one.

Proceeding with the exuberance of dam building, without a better understanding of the variances of climate change, may well create some enormous engineering white elephants. This also ignores where the water comes from. Our future is likely to be more rain but less snow. But it is slow snow melt that keeps our rivers flowing.

Headwater forests capture that snow, retaining some of it in shallow ground water storage for later release. With our expanding land-use footprint, especially logging, we are changing the way water is trapped, stored and released. This exacerbates floods and drought.

Our forested headwaters is the ultimate “reservoir” for water yet it merits no attention in this report. Funding upstream watershed restoration and security would seem to be the first thing to consider, not more dams at the downstream end.

The glib and disingenuous statement that more reservoirs would aid fish through better flows is a whopper of a “fish tale.” This didn’t happen with any past developments and won’t happen with any future ones. There isn’t even enough flow to consistently meet the lowest common denominator, an “administrative” instream objective, which does not protect fish and aquatic life.

This breathless endorsement for more dams and reservoirs isn’t adaptation but a blatant cheerleading proposal for irrigation interests with little in the way of benefits for Albertans, other than a hefty price tag.

With this report, the irrigation lobby confirm their “adaptation roadmap” will mean our rivers are good— to the last drop.

Shifting a dominant culture and narrative of engineering the landscape for irrigation agriculture to a new perspective of learning to do with less water is a tall order. Understanding what level of water use can be sustained while keeping our rivers from death are difficult but not insurmountable challenges.

What is urgently required is an independent, objective analysis by qualified professionals on the broader questions of how to adapt to a climate change future, perhaps the driest of perfect storms, not how to expand  irrigation.


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Assumptions About Irrigation Agriculture Expansion Called into Question
Cheryl Bradley, 24 Feb 2024

A recent article in the Lethbridge Herald (Feb 14) regarding designation of an AgriFood Processing Zone  contains assertions by UCP MLA Grant Hunter to Lethbridge County Council that irrigation districts are making decisions about expanding by 300,000 acres and that more water storage is being built, paid for by government and ratepayers, to support that expansion.  I suggest announcements of expanded irrigation and reservoirs to support more water capture and diversion at public expense are untethered from reality, reasonableness and public scrutiny.

The current drought throughout the Oldman River Basin is characterized by mountain snowpack well below long-term average, streams and rivers at minimum flows for aquatic life, and reservoirs, on-stream and off-stream, well below normal levels for this time of year. Models of climate change suggest more frequent and prolonged drought is our future. There is not enough water to fill existing reservoirs with just two years of below average mountain snowpack and precipitation. Is it realistic to build, at great public expense, more storage capacity that will remain unfilled in many years, provide more surface for water loss through evaporation and increase stress on rivers?

Irrigated area in the Oldman basin has increased at least 16% since restrictions on water allocation were first implemented by government three decades ago. Another 15% or more expansion is proposed, as indicated by MLA Hunter. Irrigation districts, supported by government, justify expansion within their current water licences based on calculations of water saved through improvements in irrigation infrastructure such as more efficient pivots on farms and replacing canals with pipelines. A growing body of research concludes that irrigation water use in semi-arid regions has increased despite claims of limits to allocation and improvements in efficiency.  In a ‘paradox of irrigation efficiency’ more water is withdrawn and applied as irrigators increase crop area and switch to higher-value, more water-intensive crops (e.g. potatoes, corn, hay). Summer flow in the Oldman River is already reduced by approximately 60% from natural levels in its lower reaches. Increased evapotranspiration from warming climate will place further stress on the Oldman River and its tributaries below maj