Water, Water, Everywhere
Comments regarding proposed EID Snake Lake Reservoir Expansion EIA proposed Terms of Reference (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)
Environmental Impact Assessment 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)
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)
6 December 2023
Comments regarding proposed EID Snake Lake Reservoir Expansion EIA proposed Terms of Reference
The EIA Terms of Reference focuses assessment of environmental impact to the direct effects of construction of Snake Lake Reservoir, referred to as the “Project”. Not mentioned is expansion of ~5,000 irrigation acres that is proposed in conjunction with expansion of Snake Lake Reservoir. This proposed increase in irrigated acres on the assessment role of the Eastern Irrigation District and associated ongoing activities are integrally linked to proposed reservoir expansion and impacts will be necessarily incidental. Expansion of irrigation acres should be included in the definition, description and impact assessment of the project.
To read the complete submission click ... here.
Published 11 April 2023 in The Calgary Herald:
More Irrigation in a Dry Land with Shrinking Rivers?
The substances most essential in life are the ones we consistently overuse. In arid southern Alberta, water is limited, yet we treat it as though it was abundant.
Southern Alberta’s rivers are currently unhealthy, mostly because of an overallocation of water for irrigation agriculture. Sufficient water at the right time is essential to keep ecosystem processes functioning, fish alive, riparian areas green and creating opportunity for other users, now and in the future.
Our profligate, blinkered use of water is related to a trifecta of factors. A frontier attitude toward resource use has led to irrigation being allocated half of average river flows. Persistent lobbying efforts for irrigation expansion has jumped ahead of reason. Lastly, and key to this discussion, is climate change, which is shrinking the flow in southern Alberta rivers and creating hotter, drier weather.
There is, as well, the usual human hubris. Pretending that we don’t live in an arid climate, that water is abundant and that we can continue to grow an economy based on crops produced by artificial rain from irrigation sprinklers, clouds our thinking.
For the complete article, click ... here.
December 22, 2022
Re: Review comments on Proposed Terms of Reference, Environmental Impact Assessment Report, for St. Mary River Irrigation District Proposed Chin Reservoir Expansion Project
Southern Alberta Group for the Environment (SAGE) is a non-profit organization based in Lethbridge whose mission is to serve as a leading voice for a healthy and environmentally sustainable community. For over 35 years SAGE has worked to protect and restore rivers and watersheds in the Oldman River basin and beyond. SAGE researches environmental concerns and issues and writes letters, briefs and articles to inform the community, including elected decision-makers. SAGE members have been active participants in multi-stakeholder efforts to improve water management including the work of the Oldman River Basin Advisory Committee to develop the South Saskatchewan River Basin Water Management Plan (2006), the Oldman River Basin Water Quality Initiative and the Oldman Watershed Council. SAGE engages in regulatory and appeal processes when it is the only responsible avenue available to influence key decisions affecting environmental sustainability.
We have reviewed the Proposed Terms of Reference, Environmental Impact Assessment Report, for St. Mary River Irrigation District Proposed Chin Reservoir Expansion Project posted on Nov 15, 2022 to Environment and Protected Areas website. We provide the following written comments for your consideration to assist in achieving a comprehensive assessment of project impacts that will provide a solid basis for a public interest determination by the Natural Resources Conservation Board.
To read the entire letter, click ... here
November 10, 2022
Letter: Environmental Impact Assessment of the “historic expansion of Alberta irrigation” including Chin Reservoir, Deadhorse Coulee Reservoir and Snake Lake Reservoir
"We are responding to Minister Guilbeault’s recent decisions that three proposed irrigation reservoir projects that are part of the larger project do not warrant designation under the Impact Assessment Act because existing legislation and processes provide a framework to address potential adverse effects within federal jurisdiction (...). We have reviewed IAAC analysis reports for the three projects and have identified gaps and uncertainties to be addressed if the Minister’s rationale for decision is to be realized."
To read the entire letter, click ... here.
The River of Unfulfilled Expectations
Lorne Fitch, P. Biol.
Alberta’s big rivers, the Peace and Athabasca, flow north, away from people. The North Saskatchewan and South Saskatchewan rivers, along with their tributaries the Red Deer, Bow, and Oldman rivers, flow east through the Alberta heartland, delivering essential waters to most of the province’s population. As one travels further south the demand for water escalates in concert with increasing aridity. So the expectations for the Milk River, the one furthest south, are the greatest.
The poor Milk River has never lived up to people’s expectations. This likely started with President Thomas Jefferson’s Corps of Discovery in the early 1800s. Jefferson sent Lewis and Clark out on an exploration of his Louisiana Purchase, essentially the Mississippi/Missouri watershed. Among other things, their instructions included determining whether there was a connection with the Saskatchewan drainage and the long established and lucrative fur trade route of the Hudson’s Bay Company.
When the party came to a fork in the Missouri River, Meriwether Lewis started up the muddy stream coming from the north. Realizing it was not the main stem he turned back. Lewis and Clark realized this was the stream the natives called “The river that scolds at all others.” As a description they said the stream was “about the color of a cup of tea with the admixture of a tablespoon of milk.” Hence the “Milk River.”
As was the case with all of the tributaries draining south to the Missouri, including the Milk, none linked to the Saskatchewan drainage and none would “furnish a practicable and advantageous communication with the Saskashiwan River.” So ended the expansion dreams and possible hegemony of the United States into what would become Canada.
As early settlers would develop impressions of prairie rivers, including the Milk, “they were hard to ford, destitute of fish, too dirty to bathe in, and too thick to drink.” And, even more distressing, sometimes they went dry. Dawn Dickinson, long a prairie resident, related an anecdote about her mother who had come from the green lushness of England to join her husband—a customs agent at Coutts, on the Alberta/Montana border—in the early years of the twentieth century. Writing home, she described her new home this way: “It has more rivers, and less water.” That was a succinct summary of the Milk River and its watershed.
As settlement of the Milk River watershed progressed, in both Alberta and Montana, the limitations of the river became evident. Tony Rees wrote in Hope’s Last Home, “But as a pure plains river, the Milk was utterly incompatible with booster visions of an agricultural Eden along its banks because it would often deliver its spring runoff in one great flood, only to run dry in midsummer.”
Prairie agricultural dreamers and schemers have always been tenacious and unwilling to accept the limitations of the landscape. Once the possible connections between the St Mary River and the Milk headwaters were realized, the slide rules were employed to plan for the capture and diversion of mountain runoff down the Milk to thirsty Montana farms.
This probably seemed elegantly simple to the Americans, but since the St Mary River was already tapped for irrigation in Alberta, this created a fair bit of consternation in Canada. Canadian officials might have observed, as Jack Benny, the comedian, later wryly pointed out, “Drink Canada Dry [the soft drink] is a slogan, not a command.”
It was a high stakes poker game, maybe one of chicken, and could have resulted in the complete diversion of St Mary River flows into the Milk. In an ultimate bluff, the Canadian reaction was to start construction of a canal, upstream of the town of Milk River, that would capture the diverted flow and direct it back north, returning the water to Canada. In time this would be called the “Spite Ditch.”
The bluff worked and this led to a more equitable water sharing agreement between the US and Canada. Later appraisals would indicate the canal may not have held water, due to extensive gravel seams. Teddy Roosevelt was the US president at the time of these negotiations and maybe, to paraphrase his famous quote on foreign policy of “Speak softly and carry a big stick,” the Canadian response was “Speak softly and dig a big ditch.”
The water sharing agreement did not quench the thirst for water in the Milk River watershed—it just delayed future desires. In recent times, those in the Alberta portion of the Milk have lobbied hard for storage, to expand irrigation and safeguard domestic supply. However, no matter how stridently the proponents argue, there is no persuasive economic argument to be made for reservoir development. The Milk River just cannot be bent to accommodate everyone’s desires for water.
Except seasonally, and enhanced by diversions from the St Mary River, the Milk flows though a dry land and water will always be limiting. This is apparent to us as our canoe grinds to a halt on a sand bar. A few more centimetres of water would float our boat, but we might as well ask for other miracles. Sometimes a float turns into a drag. But this is not the river’s fault.
Tempering expectations of clear sailing with other virtues of the river is essential. Aridity effectively limits the human footprint. It leaves large portions of native prairie and the green zone of riparian plants alone and largely intact. Traveling on the Milk River in Alberta is a step back in time, where wild space predominates. The lower Milk River flows through a canyon of deeply dissected coulees and steep, eroded walls. Blue grama grass and cactus give way to a thin thread of cottonwoods and willows. For much of the length of the Milk River, rattlesnakes, antelope, mule deer, ferruginous hawks, and common yellowthroats have a greater population density than do humans.
Despite periodically and seasonally drying up, except for isolated pools, remarkably the Milk River harbours 14 fish species. Three are species at risk: the St Mary River sculpin, western silvery minnow, and stonecats. The stonecat is the only fish species in Alberta that can hurt you, other than being lacerated by the sharp teeth of a northern pike. A poison gland at the base of the first few rays of the pectoral fin can produce a wasp-like sting if the fish is improperly handled.
All prairie creatures, aquatic and terrestrial have come to an accommodation with aridity, water shortages, and the range of variability in their environment. None of these species have unfulfilled expectations about the Milk River and its watershed. Maybe we can learn from that.
Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a former Adjunct Professor with the University of Calgary.
26 October, 2022
International St. Mary and Milk Rivers Study Board
I am writing on behalf of Southern Alberta Group for Environment to suggest that an on-stream dam on the Milk River in Alberta is not a feasible infrastructure option and that your resources are better focused on studying options for changes in administrative procedures. At the Town Hall meeting hosted by the International St. Mary and Milk Rivers Study Board in the town of Milk River on October 24, it appeared that members of the Study Board may be unaware of the Milk River Basin – Preliminary Feasibilty Study conducted in 2003 to investigate on-stream and off-stream water storage options in the basin. I am attaching a copy of the draft report.
Alberta Environment assigned the work to Klohn Crippen Consultants Ltd. in association with Mack, Slack & Associates Inc., AXYS Environmental Consulting Ltd., Marv Anderson and Associates Ltd., and Hart Water Management Consulting. Three alternatives for dam configurations were considered at the Forks Site in the Twin River Natural Area previously identified as the preferred on-stream storage site by PFRA in 1986. In addition five off-stream storage sites were evaluated. A draft report of the results of the feasibility study was completed in October, 2003; however a final report was not made publicly available.
As you will see, key findings in the draft report are:
1) Technical Issues:
Construction of an on-stream dam at the forks of the Milk and North Milk River would present a number of technical issues including:
- Weak bentonite layers with low residual strengths in the bedrock foundation underlying the dam embankment.
- Significant potential for seepage in pervious alluvial and bedrock formations.
- Risk of seepage through and erosion of glaciofluvial sands on the south upland, at the auxiliary spillway, along the reservoir shoreline adjacent to the dam.
- Risk of reservoir seepage through the buried preglacial valley south of the site.
- Large amounts of borrow will be required.
- Local sources of riprap are not available.
2) Environmental and Historical Resources:
- The Milk River is the only river in Alberta that is part of the Missouri River drainage and makes for a unique fish fauna assemblage. There are 28 fish species, of which six are provincial Species of Concern and three are now federally listed SAR (St. Mary shorthead sculpin, western silvery minnow and stonecat). A dam would displace fish, create a barrier to fish migration and modify flows that are essential to their biology.
- Riparian areas along the rivers provide important habitat for wildlife, including migration corridors. Riparian areas are susceptible to detrimental effects due to changes in the river flow regime.
- Native grassland habitats would be impacted. Thirteen wildlife species present in the area are listed federally as endangered, threatened or of special concern. The Forks is within key Pronghorn antelope winter range.
- There is a high concentration of Indigenous sites, including a Medicine Wheel.
3) Economic Analysis:
Benefit-Cost ratio was 0.53 for on-stream storage at the Forks Site and 0.29 - 0.37 for the off-stream sites considered. Net Present Values were negative and Internal Annual Rate of Return ranged from 1.77% to 1.9% per annum, lower than a discount rate of 5%. To be economically viable B/C ratio should be greater than 1, NPV positive and IRR equivalent or better than discount rate.
4) Project Implementation
EIA will be required (federal-provincial) as well as Indigenous consultation
Equus Consulting Group held two public workshops, Mar 17 & 18, 2003 in Lethbridge and Milk River inviting comment on the feasibility study Terms of Reference. Southern Alberta Group for Environment (SAGE) made a submission to the Lethbridge Workshop with suggestions, concerns and questions regarding the storage feasibility study. I attach that for your information as our concerns about a dam on the Milk River continue to be relevant.
Please don’t hesitate to contact me if you have questions.
Minister's Response to request for Environmental Impact Assessment regarding Chin Reservoir expansion:
Reasons for Decision: https://iaac-aeic.gc.ca/050/evaluations/document/144264
IAAC Analysis Report: https://iaac-aeic.gc.ca/050/documents/p83562/144265E.pdf
Irrigation Expansion Project
Request for Action
The Alberta government has announced a $1 Billion irrigation expansion project – the largest irrigation expansion in our history.
However, this appears to be proceeding without consideration for environmental impacts.
SAGE is one of several concerned parties working to have an Environmental Impact Assessment conducted.
The three reservoirs so far proposed as part of the program raise concerning questions about how the health of Southern Alberta’s rivers will be impacted, especially as reaches below major dams and diversions are already depleted by high levels of water diversion for irrigation agriculture.
Potential impacts of irrigation expansion on native grasslands, species-at-risk, soils, and greenhouse gas emissions are also of concern.
The three reservoir projects are listed on the Impact Assessment Project Registry and are accessible at the following links:
Once listed, the federal Environment Minister Steven Guilbeault has 90-days to respond with his decision on whether or not these projects should be designated for an environmental impact assessment. Public concern is a consideration in the Minister’s decision.
Please consider writing a letter to express your support for federal impact assessment of the 3 projects; Deadhors Coulee Reservoir, Snake Lake Reservoir, and Chin Reservoir.
Reasons for requesting federal impact assessment of the projects include:
- To identify potential impacts of increased off-stream storage and intensification of irrigation water use on flows in the Oldman River and its southern tributaries, in the Bow River and Highwood River and in the South Saskatchewan River mainstem into Saskatchewan. Ecosystems, including fish and cottonwood forests, in river reaches below irrigation dams and diversions are already stressed from high levels of water withdrawal.
- To identify potential environmental impacts of irrigation expansion (15%) on native grasslands, prairie species at risk, soil quality, groundwater & greenhouse gas emissions.
- To assess cumulative effects of irrigation expansion along with other human developments and climate change on water availability & sustainability of communities, including indigenous communities, in the South Saskatchewan River Basin.
Your letter can be addressed to:
Impact Assessment Agency of Canada (email@example.com)
cc. ECCC Minister Steven Guilbeault (ec.ministre-minister.ec@
Are Prairie Rivers at Risk?
Irrigation and the Future of Southern Alberta’s Rivers.
AWA Spring 2022. (PDF)
Shall We Gather at the River?
April 2022. (Video)
How much water is needed to keep a river healthy? Understanding Instream Flow Needs
In naturally dry regions such as southern Alberta, rivers provide a critical supply of water. Ever increasing human demands on this precious resource have natural consequences and limits. It is urgent that we understand what flows are needed to keep rivers healthy and functioning. Instream Flow Needs (IFN) are streamflows required to be left flowing in the channel to preserve river function.
Our demand for river water is highest during the growing season for irrigation agriculture, but continues year-round to supply ever-increasing domestic and industrial uses. For more than 100 years we have engineered dams and diversion systems to utilize river flows in the South Saskatchewan River basin. We store spring flood water in reservoirs to supplement lower summer flows to use later downstream and to dilute waste effluent year-round. As a result, we have substantially altered natural flows and triggered a wave of downstream ecological effects on river health; involving everything from channel form and wildlife habitat to water chemistry.
Concerns about the effects of declining river flows on water quality and fish in southern Alberta led to assessment of instream flow needs beginning in the early 1970s. These IFN assessments initially identified a single minimum flow required to dilute pollution and achieve acceptable water quality, known as an Instream Objective (IO). This spurred improvements to wastewater and runoff management by municipalities and industry.
IFN 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. These fish rule curves, developed using the Tennant or Tessman method, became a consideration in making decisions about new water licenses primarily in headwater rivers and streams.
Declining poplar forests along prairie rivers led to research in the 1980s and 1990s that linked dams with seedling failures. These trees time their seed release to have seedlings sprout on wetted river banks high enough to escape being washed away and low enough for their roots to keep contact with the gradual retreat of the water table. After high spring floods, the Oldman Dam (built in 1991) has been operated to gradually ramp flows down to encourage seedling survival.
The conservation value of natural stream flow variability became widely recognized in the late 1990s. An integrated IFN for fully protecting the aquatic environment was defined in the 2000s to inform water management planning within the South Saskatchewan River Basin. It integrates seasonal requirements for water quality, fish habitat, riparian vegetation and channel maintenance processes – all key attributes of river health. The resulting flow regime would amount to about 80% of natural flows during times of moderate to high flow and natural flows during times of low flow.
Unfortunately, when these fully protective IFN are compared to what is actually allowed to flow in lower reaches of our basin, the conclusion is that our river health is in a state of long term decline due to over allocation. Extensive scientific assessments of aquatic and riparian condition confirm this.
The South Saskatchewan River Basin Water Management Plan (approved 2006) acknowledged this dire situation by closing the Bow, Oldman and South Saskatchewan River Sub basins to new water allocations and setting a Water Conservation Objective (WCO), defined under Alberta’s Water Act (2000) as the amount of water necessary for the minimum protection of a natural water body or its aquatic environment. WCO for main stem reaches has been somewhat arbitrarily set at 45% of natural flow or the already defined minimum Instream Objective (IO) +10%. This WCO, although woefully inadequate for protecting river health, is at least a recognition of a danger threshold. Unfortunately, we already fail to meet WCO during the growing season in dry years like 2021.
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 river is over allocated based on historic flows 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.
Alberta Environment (June 2003). South Saskatchewan River Basin Water Management Plan Phase Two: Background Studies: finding the balance between water consumption and environmental protection in the SSRB. (here)
Lalonde K. et al. 2005. Southern Alberta’s Watersheds: An Overview. Prairie Conservation Forum Occasional Paper Number 5. (here)
Alberta Government (August 2006). Approved water management plan for the South Saskatchewan River Basin (Alberta). (here)
Alberta Environment (June 2007). Aquatic and Riparian Condition Assessment of the South Saskatchewan River Basin. (here)
Bow River Basin Council (2010). Bow River State of the Watershed Report Summary (here)
Oldman Watershed Council (2010). Oldman River State of the Watershed Report Summary (2010) (here)
Alberta Government (2014). South Saskatchewan Region Surface Water Quality Management Framework: for the main stem Bow, Milk, Oldman and South Saskatchewan Rivers (Alberta). (here)
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. Available (here.)
Harwood A.J, D. Tickner, B.D. Richter, A. Locke, S. Johnson and Xuezhong (May 2018). Critical factors for water policy to enable effective environmental flow implementation. Frontiers in Environmental Science 6, Article 37. 7 pp.
Alberta Environment and Parks. (February 2019). Surface Water Allocation Directive. (here)
Poff, N. L., Allan, J. D., Bain, M. B., Karr, J. R., Prestegaard, K. L., Richter, B. D., Sparks, R. E., & Stromberg, J. (1997). The natural flow regime: A paradigm for river conservation and restoration. BioScience, 47(11), 769-784. https://doi.org/10.2307/1313099
To: Nathan Neudorf, MLA Lethbridge-East (Lethbridge.East@assembly.ab.ca)
Cc: Shannon Phillips, MLA Lethbridge-West (Lethbridge.West@assembly.ab.ca)
Marlin Schmidt, NDP Environment Critic (Edmonton.Goldbar@assembly.ab.ca)
From: Braum Barber, Southern Alberta Group for the Environment (SAGE)
Re: Water Stewardship
SAGE would like to congratulate you on your new portfolio as the Parliamentary Secretary to the Minister of Environment and Parks for Water Stewardship.
There are three concerns that we have regarding water policy as being advanced by the UCP government in Alberta:
- The irrigation districts in southern Alberta in collaboration with the Canadian Infrastructure Bank and the Government of Alberta, are planning improvements in irrigation infrastructure, increasing off-stream storage, and increasing irrigated areas with the ‘saved’ water. There has been an absence of public transparency or opportunities for environmental assessment and independent review since the major irrigation expansion project was first announced in October, 2020. SAGE has concerns about the loss of native grasslands and wetlands, potential adverse effects on species at risk/biodiversity, and the environmental impact of four proposed off-stream storage projects. The seeming disregard of the evidence of declining in-stream flows due to climate change is particularly concerning. Low instream flow negatively impacts riparian and aquatic ecosystems in our rivers as well as future water security. It appears inconsistent to increase irrigated acres in a basin with rivers already overallocated and closed to new allocation, and already stressed with declining water availability. We suggest that water saved through infrastructure improvements should be left in the rivers to maintain adequate flows for river health and provide a buffer for future human water needs. SAGE recommends that the Government of Alberta designate this project for an environmental impact assessment so these issues can be fully addressed using best available science and modelling of river flows, and a determination made about whether or not the proposed irrigation expansion project in its entirely is in the public interest.
- The media has intimated that the UCP government continues their involvement in promoting surface mining coal projects along the Eastern Slopes by allowing transfers of coal leases between mining companies. As you know, the Grassy Mountain Coal Project has been rejected by the Alberta Energy Regulator and Joint Review Panel as not being in the public’s best interests. The Tent Mountain Coal project has been designated for review by the federal Minister for Environment and Climate Change and poses the same risks to our water as the Grassy Mountain Coal Project.
It is clearly necessary that global emissions from the burning of fossil fuels be reduced to minimize climate disruption; eliminating coal emissions is a priority. As importantly, the likelihood of surface and groundwater contamination from coal mining operations risks not only biodiversity loss, but is a threat to existing industries downstream including irrigation and livestock operations.Water stewardship should consider protecting the health of the environment, of community drinking water, and the foundation of our local economy.
The threat of water contamination (including selenium) should instill grave concern. As a recent Golder report has stated (State-of-Knowledge on Selenium Treatment Technologies, 2020): “Despite numerous installations, selenium treatment technologies have not reached full maturity and should still be regarded as developmental.” A precautionary approach to decision-making is fundamental to protecting our water from long-term contamination.
- Related to the last point, it is essential that Canada develop a more robust national policy on water and fisheries. The federal government has proposed new regulations to reduce the harm of contaminated wastewater from coal mines on fish and fish habitat. It has been widely reported that Alberta and three other provinces are coordinating efforts to diminish the effectiveness of these regulations. Alberta is in a good position to end coal production within its borders while coal-fired electricity generation is phased out. The minimal economic benefits provided by existing coal mining operations in the province are negated when factoring in environmental and social impacts. As Parliamentary Secretary to the Minister of Environment and Parks for Water Stewardship, negotiations with the federal government on regulations should be more supportive of protecting out water, biodiversity and the environmental integrity of our region.
In summary, these three issues are interrelated. Water stewardship means: supporting strong federal legislation that protects our water; protecting our water from the threats of industrial contamination from coal mining in the province; and protecting the integrity of the natural environment upon which our tourism, recreation and our agricultural economy rely. Comprehensive land-use planning and cumulative effects management are strongly recommended to ensure the abundance and availability of clean water. Water is the lifeblood of southern Alberta and there are limits to its use and misuse.
We would be pleased to meet with you at your convenience to discuss these matters.
Water Management a Key Issue in Municipal Election
Published 09 October 2021 The Lethbridge Herald (link)
Candidates for election to municipal office in southern Alberta are well advised to consider the future of water use for the communities they represent and for the environment. A summer of rapidly melting glaciers, extreme heat, little to no rainfall, and low river flow resulted in water shortage advisories, declared states of agricultural emergency, cut-off of water to irrigators, and curtailed recreation experiences for canoeists and fishers. More drought stress is predicted as climate changes. Nonetheless work is proceeding on the “single largest irrigation expansion in Alberta’s history” in the absence of public consultation and environmental impact assessment.
The $815 million agreement among eight irrigation districts, the UCP government and the Canadian Infrastructure Bank to expand irrigation agriculture by 15 per cent in the Bow and Oldman river basins was announced in December 2020 as a done deal. The project will construct a few hundred kilometres of pipelines (mostly replacing existing canals) and four new or expanded reservoirs (one that is undisclosed), and add 206,000 acres of new irrigation, the location currently unknown. Construction of pipelines and land acquisition for reservoirs are already underway.
Water for the expansion is purported to come from water use efficiency improvements within existing licences. Even so, the project is an intensification of water use in basins that are already over allocated, closed to new water licences, and lack effective measures to protect the health of rivers.
Given that the irrigation sector holds licences to withdraw over half of mean natural annual flow and over three-quarters of licenced water allocation in the Bow and Oldman River basins, major expansion has ramifications for current water users and for potential future uses of water as well as for accommodating Indigenous water rights.
Environmental interests are asking for impact assessment including cumulative effects assessment and basin-wide instream flow modelling to understand the implications of the project for health of rivers as well as for native grasslands and species at risk, including lake sturgeon.
There are economic sustainability questions as well. Does it make sense for the economic future of southern Alberta to put all of our water resource eggs in one basket, that of irrigation agriculture?
The prairies are a semi-arid environment and given predictions of climate change, how sustainable is expansion of an industry reliant on abundant water to grow crops and process food, the products of which are mostly for export?
We do not want to repeat the experience of communities in the southwest United States currently subject to disruption from deep cuts in water supply because of prolonged drought that has diminished the Colorado River. It is important we learn from that experience and plan for resiliency in managing our precious and limited water resources.
Municipal elections provide opportunities for candidates to identify key issues and listen to the views of constituents about those issues in preparation for making informed choices once in office.
The future of water management in southern Alberta is a key issue.
Informed, collaborative conversations among a broad array of interests are needed now, before this major irrigation expansion project proceeds further and climate change forces a reckoning.
Nathan Neudorf's letter muddies the waters.
Published 19 08 21 The Lethbridge Herald (click here)
I agree with MLA Nathan Neudorf’s opening statement in his Aug. 13 column from the Legislature that “in southern Alberta water truly is one of our most precious resources, and its safety, protection, and allocation are a key priority for all of us.” Unfortunately, the rest of his column muddies the waters.
The column fails to clarify that the Oldman River Basin Water Allocation Order (Order) its name does not apply to the entire Oldman River Basin but only to a reserve of 11,000 acre feet of water upstream of the Oldman reservoir from the upper Oldman, Castle and Crowsnest rivers. Water was reserved under the Order in 2003, just prior to closure of the entire basin to further water licences, as compensation to municipalities in the headwaters for flooding of agricultural land and other impacts from construction of the Oldman River dam.
MLA Neudorf is correct that approximately 84 percent of water reserved under the Order is not yet licensed. The column alleges a “perceived inequality” given that industrial users can access only 1.3 per cent of the water, all of which is currently used, and irrigation users can access 85 per cent, only 14 per cent of which is being used.
This situation is the result of choices made by residents in headwaters municipalities for the best use of the allocation available to them. Government’s proposal to set aside 20 per cent for “aquatic environmental needs” is tokenism and lacks a scientific rationale.
Current water shortage advisories on the Upper Oldman River, Pincher Creek and Castle River indicate that, regardless of purpose, allowing withdrawal under the Order of additional hundreds of acre feet of water each year from headwater tributaries, as would be required for proposed coal mines, will be problematical.
Contrary to MLA Neudorf’s assertion that “a significant portion of Oldman River water has not been accessed over the past 30 years”, the 9,229 acre-feet of water remaining unallocated under the order is insignificant given that two hundred times that amount – 1,800,000 million acre feet – is licensed for use in the Oldman River Basin.
Approximately two per cent of allocation within the entire basin is for commercial and industrial purposes and three per cent for municipal purposes while over 85 per cent is for irrigation agriculture. In dry years such as the current one almost the entire agricultural allocation – 60 per cent of the mean natural flow at the mouth of the Oldman River – is being diverted to irrigate hay and annual crops. Mr. Neudorf does not represent this situation as an inequality but instead touts the “$815 million investment to increase our irrigation system” in the Oldman and Bow River basins. Thirty per cent of the investment is a provincial grant and 50 per cent is a loan from the Canada Infrastructure Bank.
What flow is left for fish and other aquatic organisms and for the health of rivers when current water licences are accommodated? According to the South Saskatchewan River Basin Water Management Plan, our rivers must get by on 45 per cent or less of natural flow in drier-than-average years such as this one, not with ecological justification but because water licences totalling over two-thirds of mean natural flow had been granted before a decision was made to stop issuing licences in 2006. This situation could be described as over-allocation, a failure to define science-based environmental flows and proactively set limits on water diversions.
Climate change is likely to exacerbate risk of shortage for fish and maintaining water quality and riparian habitats, not to mention for junior licence holders in the Oldman River Basin. In addition, there is a lack of monitoring and enforcement of licensed diversions to ensure the current less-than-satisfactory objectives for instream flows are being met.
A recent report by four Watershed Planning and Advisory Councils in the South Saskatchewan River Basin, including the Oldman Watershed Council, concludes “More needs to be done to restore and protect the long-term health of the aquatic and riparian environmental water supply for economic growth, municipal growth and other needs will need to be matched with aquatic environment requirements.”
Mr. Neudorf applauds efficiency improvements in irrigation and I agree. However, hundreds of millions of dollars in public funding has enabled these improvements over several decades and I question his implicit assumption that all of the saved water should go to expanding irrigated acres. It reflects a bias that water is only “precious” if it can be used to grow a crop – but water flowing in a river has value also.
The story of how irrigation agriculture developed in southern Alberta is a complex one, as is the story of how those decisions affect rivers today. Public scrutiny of proposed irrigation expansion is obscured behind a murky veil of confidential deals with irrigation districts and the Canada Infrastructure Bank.
If “water is our most precious resource and its safety, protection, and allocation are a key priority for all of us” then I suggest government initiate a public conversation about the impacts of proposed irrigation expansion and about reserving some of the saved water (paid for out of the public purse) to sustain our rivers and for society’s future needs.
Simplistic and muddy narratives such as Mr. Neudorf’s do not help find clarity on decisions that will sustain irrigation and other uses of water as well as the health of our rivers.
March 31, 2021
The Honourable Devin Dreeshen Minister of Agriculture and Forestry Government of Alberta
Sent by e-mail: AF.firstname.lastname@example.org
The Honourable Jason Nixon Minister of Environment and Parks Government of Alberta
Sent by e-mail: AEP.email@example.com
The Honourable Jonathan Wilkinson Minister of Environment and Climate Change Government of Canada
Sent by email: Jonathan.Wilkinson@parl.gc.ca
The Honourable Catherine McKenna Minister of Infrastructure and Communities Government of Canada
Sent by e-mail: Catherine.McKenna@parl.gc.ca
Mr. Ehren Cory, Chief Executive Officer Canada Infrastructure Bank
Sent by email: firstname.lastname@example.org
Stephen Mathyk, Regional Regulatory Assurance Manager
Alberta Environment and Parks
Sent by e-mail: Stephen.Mathyk@gov.ab.ca
Re: Concerns regarding Proposed Alberta Irrigation Expansion Project Parternship of Alberta Government, Canadian Infrastructure Bank, Irrigation Districts
We are writing to state our concerns about a recently announced project to upgrade irrigation district infrastructure, build new and expanded storage reservoirs and increase irrigation acres within eight irrigation districts in the South Saskatchewan River Basin of southern Alberta. We are asking that this monumental project be subject to environmental assessment, regulatory review and opportunities for public and indigenous consultation and input. We are requesting that subsidies for efficiency improvements that Government deems to be in the public interest are accompanied by agreements on the use of freed-up water to assist in meeting societal goals for realizing instream flow needs and improving river health.
We understand hundreds of millions of dollars of provincial grants and federal loans to irrigation districts are involved as is the future use of a scarce and valuable public resource in a semi-arid region - water. We are concerned about potential environmental implications of the proposed project particularly on stressed aquatic ecosystems. The apparently secretive process being used to define the project and financing agreements is of concern in that it may preclude consideration of opportunities to support healthy ecosystems and human needs through shared stewardship.
It has been well understood for at least two decades that the health of rivers in the Bow, Oldman and South Saskatchewan sub-basins of semi-arid southern Alberta downstream of major irrigation supply dams and diversions is compromised by significantly reduced flows and altered flow regime as well as by impacts of growing population and intensifying land use (Schindler and Donahue 2006, Byrne et al. 2006, Pentney and Ohrn 2008). Several studies of the health of aquatic ecosystems have been undertaken to inform water and watershed management planning. These studies are listed and key points summarized in Attachment 1.
Irrigation agriculture is a major cause of stress on aquatic ecosystems due to water withdrawals from rivers and through pollution of runoff from cropland and return flows. The irrigation sector holds licences to withdraw over half of mean natural annual flow and over three-quarters of licensed water allocation in the Bow and Oldman river basins (Basin Advisory Committees 2018). Increased warming with climate change through its effects on evaporation, evapotranspiration and winter snowpack will continue to contribute to declines in river flow and on health of aquatic ecosystems if we do not take action to maintain and restore them (Jiang et al. 2017, Bonsal 2020).
We understand the potential benefit of improving water use efficiency of irrigation agriculture by converting open canals to underground pipelines. However experience here and elsewhere is that modernization seldom alleviates the consequences of cyclic drought or frees water resources for river flows and the natural habitats they provide but instead increases resource use and reduces society resiliency (Scott et al. 2014). A case in point is the Irrigation Sector Conservation, Efficiency and Productivity Plan (2005-2015) by the Alberta Irrigation Projects Association (2010). It does not identify or adopt meaningful opportunities to benefit the environment. It does not identify water sources showing signs of stress. Progress is not being made to allocate conserved water to benefit aquatic ecosystems that have been assessed as degraded because of water withdrawals. Furthermore plans and decisions are being made to commit conserved water (and unused water) for expanding irrigation acres with a resulting further stress on aquatic ecosystems and less water available for future societal needs.
Also of concern to us is proposed increase of off-stream water storage. We are aware of water supply and storage evaluations for the South Saskatchewan River Basin (AMEC 2009 and 2014) that addressed a strategy of the South Saskatchewan Regional Plan (2014-2024) toward managing watersheds to “support healthy ecosystems and human needs through shared stewardship”. These studies did not recommend new storage development in the Bow and Oldman subbasins but rather suggested pursuing non-structural opportunities first. We are not aware that non-structural opportunities have been fully explored.
We are also aware of climate adaptation strategies defined for the South Saskatchewan River Basin through a collaborative process using the South Saskatchewan River Operational Model (Alberta WaterSMART 2016). Strategies, both structural and non-structural, focused on adapting to drought and flood and increasing resilience to climate change, not increasing risk to existing water users and the aquatic ecosystem as could occur with major expansion of irrigation in the Bow and Oldman subbasins.
A further concern is whether the identification of new or expanded off-stream storage reservoirs that are part of the announced irrigation expansion project arose from a recent ranking of on-and off-stream storage options by the Alberta Irrigation Districts Association (2019)? If so, this is of concern as the AIDA study focused on benefits to the irrigation sector. Broader environmental, social and economic considerations were not addressed.
We expect there will be fulsome impact assessments including cumulative effects assessments and regulatory review of the various components of the project for compliance with relevant legislation and approved water management and land use plans and policies. Legislation that may apply includes the federal Impact Assessment Act, Fisheries Act and Species At Risk Act and the provincial Environmental Protection and Enhancement Act, Water Act, Alberta Land Stewardship Act, Wildlife Act and Irrigation Districts Act as well as a variety of approved plans and policies including the South Saskatchewan River Basin Water Management Plan, the South Saskatchewan Regional Plan and the Alberta Wetland Policy. There may be implications for interprovincial sharing of water according to the Master Agreement on Apportionment. As well the Government of Canada and the Province of Alberta have a duty to consult First Nations and Metis. We would like assurance that shared financing of the project by federal and provincial governments and irrigation districts will not affect the objectivity of impact assessments and regulatory review, opportunities for public input and determination of public interest.
Since the brief Alberta government media release (October 9, 2020) announcing the “historic investment to expand irrigation” our attempts to obtain information about project components through contacts with staff of Alberta Agriculture and Food, Alberta Environment and Parks, the Canadian Infrastructure Bank, and the Alberta Irrigation Districts Association have been unsuccessful. We are told that negotiations are ongoing and confidential. However, consultation with legitimate interests must occur and we suggest that it is better to do this prior to formalizing funding agreements. For example, we are interested to ensure any government subsidies for efficiency improvements that Government deems to be in the public interest are accompanied by agreements on the use of freed-up water to assist in meeting societal goals for increased in-stream flows and improved health of rivers.
We would appreciate being informed about the proposed project and assessment and regulatory review process. We request receiving notification of opportunities for consultation and input on any applications for approvals by government (e.g. environmental assessment process, water licence applications, expansion of irrigated acres).
Cheryl Bradley – Director, Southern Alberta Group for Environment
Arlene Kwasniak – Professor Emerita of Law, University of Calgary, in individual capacity
Carolyn Campbell – Conservation Specialist, Alberta Wilderness Association
Maureen Bell – Executive Director, Water Conservation Trust Silvia D’Amelio – Chief Executive Officer, Trout Unlimited Canada Richard Schneider – Executive Director, Nature Alberta
Peter Duck – President, Bow Valley Naturalists
For full letter, including carbon copy recipients and references, please download the PDF:
Letter regarding Proposed Alberta Irrigation Expansion Project 2021
Albertans Want to Know How to Manage the Demand on Limited Water Resources
Published in Lethbridge Herald
13 May 2021
Editor: The UCP government’s “sector by sector approach to economic stimulus” (Lethbridge Herald 30 April 2021 MLA Neudorf presents party’s sector-based approach for economic recovery) is out-of-date, and out-of-step.
It is this narrow focus on promoting one industry absent a broader land use, environmental, social and public interest context that made Alberta a petro-state and has brought the current frenzy of opportunistic proposals for coal exploration and extraction in our Eastern Slopes.
Thankfully many Albertans think more broad