In the past year ...
Enhancing Water Availability Engagement
Submitted 23-January-2025
Aquatic ecosystems include rivers, stream, lakes, ponds and wetlands as well as the riparian areas on their periphery. These landscape features capture, store, release and convey the water that falls as snow and rain. They are critical for sustaining life in a watershed and provide nature-based functions and services including resiliency to floods and droughts, erosion prevention, sediment capture and transport, recharge of groundwater aquifers, water purification, productive vegetation and important habitats for fish and wildlife. Man-made reservoirs and canals store and convey water but fail to provide other nature-based services. The health of aquatic ecosystems is a measure of how sustainably we live in a watershed.
[...] The suggestions that follow focus on water and watershed management that strives to ensure sufficient water is available at the appropriate times to maintain and restore healthy, functioning aquatic ecosystems.
1. Enhance headwaters storage and yield using nature-based approaches. This includes managing land use to support aquifer recharge and protecting and restoring wetlands including beaver pond complexes.
[...]
2. Determine science-based environmental flows* that will support healthy and resilient aquatic ecosystems. Require collaborative basin water management planning that defines instream flows needed for protection of the aquatic and riparian environment, including protecting biodiversity, and corresponding limits on water available for allocation. Publicly communicate instream flow needs determinations for specific river reaches.
[...]
3. Establish water available for the aquatic ecosystem through a legislated Water Conservation Objective (WCO) under approved water management plans for all basins. Implement through placing WCO conditions on all water licenses and dam operations, real time monitoring of instream flows, enforcing compliance with WCO and regular public reporting on performance to achieve WCO.
[...]
4. Monitor indicators of aquatic ecosystem health to assess the effectiveness of WCO in protecting the aquatic environment and improve WCO if required.
[...]
5. Where Instream Objectives (IO) currently apply to dam operations and water licences replace them with Water Conservation Objectives for protection of the aquatic environment.
[...]
6. For allocation decisions where specific advice or objectives have not been developed or approved, follow guidance to achieve environmental flows provided by the Surface Water Allocation Directive (Alberta Environment and Parks 2021).
7. In basins closed to further allocation because of insufficient water available to achieve both licensed water withdrawals and environmental flows (e.g. South Saskatchewan River Basin) provide direction for flow restoration using an aspirational Water Conservation Objective and implement measures to achieve the WCO. Monitor progress.
[...]
8. In decisions regarding approval of water license allocations (new or transfers), of amendments to water licenses (e.g. reduced return flows) and of proposed new water management projects require assessment of potential impacts on instream flows and achievement of WCO. Consider impacts with predicted climate change and cumulatively with other allocations (existing and proposed). Include assessment of potential impacts of change in land use associated with new allocations and water management projects.
[...]
9. Avoid use of interbasin transfers to address water availability issues given potential serious ecological, economic and social impacts. Continue to focus on water management planning within basins that recognizes basin-specific limits on water availability.
10. Broaden opportunity for public engagement in decision-making processes regarding water allocation and water management projects. Expand participation beyond the narrow definition of “directly affected” to all legitimate interests (including environmental and recreational).
11. Improve transparency and public access to data collected by government on river flows. For individual rivers or reaches provide Instream Flow Needs and Instream Objectives data and the methods used to determine them, along with historical information on how the methods have changed over time.
For the complete submission, click ... here.
Coal: If Trout Could Talk
Lorne Fitch, P.Biol.
Published 22 January 2025 in The Lethbridge Herald
In the coal saga there’s more to mine than the mountain. Despite protestations of due diligence and highest engineering standards, every coal mine in the Eastern Slopes has had spectacular environmental failures and most of them on a regular basis. This is a function of topography, engineering failures and an inability to incorporate the effects of weather events into mine design. If ever there was a lesson about future mines, all one has to do is review past mines.
Pit wall collapses, settling pond failures, conveyance system upsets and mine road washouts are the most visible evidence of problems. But it is the liberation of a witches brew of toxic chemicals that creates legacy issues. Selenium, antimony, cobalt, lithium, manganese, molybdenum, nickel, strontium, thallium, uranium and many others are released for decades by the weathering of the shattered caprock overburden.
Hidden in the labyrinth of the Benga environmental impact assessment report for the proposed Grassy Mountain mine is a cryptic note on the analysis of selenium in the flesh of trout from Gold and Blairmore creeks. Selenium concentrations in the trout were significantly higher than those adopted by both BC and Alberta to protect fish populations from collapse. This is despite the fact selenium concentrations in these streams was lower than guidelines. This never came up in the Joint Review Panel hearing although there was evidence enough to damn the project.
Contamination of fish isn’t restricted to the Crowsnest watershed. Evidence from other watersheds with coal strip mines show similar results for elevated selenium concentrations in fish, including the coal industry’s much promoted reclaimed mine pit lakes.
This isn’t restricted to fish. Bighorn sheep living on reclaimed coal mines in the Coal Branch of Alberta have selenium concentrations in their tissue higher than any other place in North America.
Native cutthroat trout used to exist in East Crowsnest Creek and the headwaters of Crowsnest Creek, beneath the Tent Mountain coal mine. Very high selenium concentrations from the mine spoil, coupled with excessive sediment loadings to these streams is implicated in trout disappearance.
The selenium guideline values adopted by past BC and Alberta governments were not proposed by armchair eco-terrorists. They were developed after multiple fish populations collapsed after exceeding these values. They are a warning – there is a limit to the amount of selenium pollution fish populations can absorb before they disappear.
Trout aren’t just the quarry for a few anglers. They speak to us on the impacts of coal mining. Trout form our distant early warning indicators and are the bellwethers of danger. To ignore their message is to ignore our peril.
A fundamental message from the selenium contamination of trout is we need to look beyond what is found in the water, to how it bioaccumulates up the food chain, to levels of significant health concern. It wouldn’t hurt to remember that we are at the top of the food chain.
Yes, these are some of the things to mine in our deliberations over coal mining in the Eastern Slopes. We might also reflect on the misinformation and distortion from congenital corporate liars. There are municipal councillors with their eyes firmly fixed in the rear view mirror of time and coated in the fairy dust of illusionary economic benefits. Overseeing this is an “arms length” regulator manipulated by political puppet masters.
Arrayed against this are the clearly articulated wishes of the majority of Albertans who are passionate about a mine-free Eastern Slopes. Alberta recently went through a review of coal policy by an independent panel. This panel was responsible for the largest public engagement process in Alberta‘s history to define a path forward for coal. Their recommendations have yet to be implemented.
Lastly, we have recently witnessed, from the minister of Energy, Brian Jean, a muddled, barely coherent “clarification” of coal policy to the Alberta Energy Regulator. The letter was issued in the midst of an ongoing AER hearing into a coal exploration application and it opens a question of whether Jean was trying to fetter that process.
Jean’s retreat from the wishes of Albertans effectivity winds the clock back, reinstates exploration permits, opens up new exploration, including construction of new roads that will erode for years. Nothing else has changed, including the continual leaching of selenium into East Slope rivers, no timely, effective reclamation of coal exploration roads and Albertan’s frustration with the intransigence and lack of spine of the UCP government.
Utah Phillips was a folk singer and philosopher who once said, “The Earth is not dying—it is being killed. And the people who are killing it have names and addresses.” If it isn’t evident by now, the names with the UCP government are writ large on this public policy failure to protect the Eastern Slopes.
*
Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a past Adjunct Professor with the University of Calgary. He is the author of Streams of Consequence: Dispatches From the Conservation World and Travels Up the Creek: A Biologist’s Search for a Paddle.
15 January 2025
To: Minister Joseph Schow, Minister of Tourism and Sport
Bill 35 All Season Resorts Act
It is unfortunate that the All Season Resorts Act (Bill 35) was hastily moved through government in November 2024, as it might have been better informed by consultation with Albertans.
The notion that the designation of currently protected provincial parks, provincial recreation areas, wilderness areas, ecological reserves, natural areas or heritage rangelands may be rescinded on the recommendation of the Minister of Tourism and Sport to make way for an all-season resort contradicts the preamble that evokes environmental standards to “ensure that the province’s land is conserved and responsibly managed for the benefit of present and future generations.”
Surely, our ‘world-class environmental standards’ would embrace the maintenance, if not the expansion and restoration of the eastern slopes, natural grasslands, wetlands and rangelands. Installing all-season resorts in protected areas will diminish habitat for species at risk, disrupt wildlife with greater numbers of visitors, and increase linear disturbances that lead to ecological damage. Furthermore, the language of the Act is troubling as it appears to limit, if not bypass, environmental review processes that might normally be expected for significant changes in the land-use of protected lands. Environmental review is meant to evaluate if the negative impacts of development are in the public interest – it is not a barrier to overcome.
Our final concern is the absence in the Act of any measures of disruption and any mention of assigned responsibility for mitigation once it is recognized as being required through environmental monitoring. The Ministry of Tourism and Sport does not have the capacity for environmental monitoring or assessment that would be required to protect our natural areas.
We understand that this act was proclaimed on December 5, 2024, despite a profound lack of public consultation or consideration of the environmental impacts of ill-defined notions of All Season Resorts. We are extremely disappointed with the Act and hope that the Government of Alberta will properly monitor and mitigate negative impacts to the environment. It should be said that ecological damage = social and economic damage when considered in the longer term and is not in the public interest.
SAGE Submission for 10-year Review of South Saskatchewan Regional Plan
1 December 2024
The Southern Alberta Group for the Environment (SAGE) has been a leading voice for a healthy and environmentally sustainable community in Lethbridge and region since 1984. SAGE was an active participant in the public consultations that eventuated the South Saskatchewan Regional Plan (SSRP).
The SSRP articulated strategic directions for policy action that included the management of air quality, conserving biodiversity, promoting the efficient use of land and advancing watershed managements among others. Sustainability goals suggest the stewardship of land and resources to ensure current needs are met without compromising opportunities for future generations. In other words, the SSRP promises responsible social, environmental and economic decisions that consider the best interests of future generations. We take this sustainability goal as the primary imperative, with a strategic direction of mitigating and adapting to climate change.
The following points are intended to help guide the SSRP Review currently being conducted by the Government of Alberta:
For the full document, click ... here.
Provincial By-election 2024: Open Letter on Environmental Policy in Alberta
Since 1984, Southern Alberta Group for the Environment (SAGE) has advocated for a healthy and environmentally sustainable community. SAGE has actively participated in municipal and regional planning, and has advocated for the protection and restoration of headwaters, the maintenance of instream flows required for aquatic health and biodiversity, and the preservation of native grasslands. The organization has also informed the public on home energy performance, waste management, and emerging issues like microplastics in the environment.
There are a few issues that are important for the future of Lethbridge and region that can be affected through provincial policy and legislation:
- Prioritize the protection of headwaters from pollution. The two main challenges are: 1) proposed coal mining which will contribute to selenium levels that may exceed allowable levels for drinking water (as currently being experienced in Fernie and Sparwood), and 2) linear disturbances from forestry, industrial and recreational activities leading to accelerated soil erosion into river and streams that negatively impacting habitat for species-at-risk (indicators of a healthy aquatic environment). Healthy rivers represent an irreplaceable source for social and economic flourishing in the region.
- Prioritize the maintenance of evidence-based Instream Flow Needs (IFNs) in water management. The current system of allocating water from our rivers must acknowledge flows that sustains aquatic and riparian health. Schemes for the expansion of on- and off-stream storage in southern Alberta ignore the observed and anticipated decline in precipitation and snow-pack due to climate change. Furthermore, expanding irrigation acres without adequate water supply represents lost economic opportunities (stranded investment) and threatens the loss of valuable native grasslands that support biodiversity and species-at-risk, carbon sequestration, and drought resistance in the region. Water management modelling must be assessed for source flows from headwater tributaries and the impacts of climate change, and native grasslands must be preserved.
- Municipal governance should allow for independent decision-making to manage urban sprawl and encourage higher energy performance in the built environment. [...]
- Create an airshed for Lethbridge & region that will measure, monitor, evaluate and respond to high levels of air pollution including NOx, SOx, ground-level ozone, ammonia, methane and particulate matter.
- Continue to promote and expand the Extended Producer Responsibility (EPR) program to improve the management of recyclable materials, and place more emphasis on ‘responsibility’ which encourages manufacturers to better design-for-disassembly and chose materials that are more recyclable or biodegradable. [...]
- Encourage planning for food security. [...]
- Support action plans that lead to improved resilience: infrastructure, climate emergency measures, incentives for water-conservation practices, and rebates for upgrades that reduce energy consumption. An urban forest strategy [...]
SAGE encourages our provincial decision-makers to direct policy and legislation towards the preservation of a healthy environment. Sustainable social and economic benefits are derived from ecological integrity – that is, clean water, clean air, healthy soil, reduced greenhouse gas emissions and robust biodiversity.
Click here for the full letter.
Grassland Preservation in Lethbridge
Letter to the University of Lethbridge
1 November 2024
The University of Lethbridge Business Corporation (ULBC) is in the process of conducting a market analysis that will guide the South Campus Development of approximately 100 acres owned by the University (1). Part of the area proposed for housing development has been identified in the City of Lethbridge Environment & Historic Resources Strategy as natural grasslands (2). The Strategy states: “It is rare to find undisturbed native grasslands in Lethbridge. These remaining patches of native grassland must be preserved. Sites that are disturbed native grasslands often require significant intervention and management to restore native species and to ensure the health of these regions does not worsen. Natural grasslands are rapidly declining and there need to be processes put into place so that the remaining areas are preserved” (p.92). Furthermore, according to the State of the Prairie Technical Report by the Prairie Conservation Forum, native grassland in the Lethbridge Plain declined 8% during the period 1990-2010, the greatest amount of change in the Grassland Natural Region of southern Alberta (3).
The fragmentation and loss of grasslands abutting the coulees may lead to decreased biodiversity, including species-at-risk, and may negatively impact drought resilience, soil stability and consequently a loss of carbon sinks which help mitigate climate change.
We expect a high standard of business development, professional practice and environmental stewardship from the University of Lethbridge, given its commitment to biodiversity and conservation in the curriculum, and as a leader in science-based decision making. It is standard professional practice to apply Alberta government guidelines for conservation of native grasslands in decisions regarding industrial development applications. In addition, professional practice expects the application of provincial guidelines and directives to minimize the impact of land-use activities on wildlife (4).
As such, the Southern Alberta Group for the Environment (SAGE) would request that the University of Lethbridge expand its market analysis to include an environmental assessment. Avoidance of losing native grasslands is the preferred approach – it appears to be possible to proceed with about three-quarters of the development and leave the native grassland portion without surface disturbance.
Unfortunately, native grasslands continue to be lost to industrial, agricultural and urban development in Alberta. It is important that their preservation be prioritized. We look to the University of Lethbridge to make principled decisions for its South Campus Development.
1 https://ulbcorp.ca/projects/
2 https://www.lethbridge.ca/media/3ruh5jhv/environment-and-historic-resources-strategy.pdf
3 https://albertapcf.live-website.com/rsu_docs/state-of-the-prairie-summary-document_final.pdf
4 https://www.alberta.ca/land-conservation-and-reclamation-guidelines-for-native-grasslands
https://www.alberta.ca/wildlife-land-use-guidelines
For the complete letter, click ... here.
October 28, 2024
Dear Minister Loewen and Minister Schulz,
[RE: Grizzly Bear Hunting]
Nature Alberta is a non-profit organization dedicated to the greater appreciation and conservation of Alberta’s natural environment. We serve as a hub for 50 grassroots nature clubs across the province and collaborate with many more community partners. We are a member organization of the provincial Endangered Species Conservation Committee and are obligated to recommend to the Minister of Environment and Protected Areas regarding the status of Alberta species and appropriate management responses. On behalf of our 1,747 members, and the 1,057 members of 9 nature organizations undersigned, Nature Alberta urges you to immediately reverse the Wildlife (Grizzly Bear - Ministerial) Amendment Regulation that permits hunting of Ursus arctos (Brown (Grizzly) Bear), a Threatened species.
For the complete letter, click ... here.
Microplastics
Submitted to The Lethbridge Herald, 1 November 2024
WasteLess.ca recently hosted a film titled Plastic People on the topic of microplastics. Microplastics are defined as pieces of plastic smaller than 5 mm. Microplastics much smaller than this, however, are being found in, well, everything. Imagine dividing the edge of a dime into 1000 slices – that is a micrometer. Invisible to the eye, microplastics are being found in plants, in animals, in the soil, in the water, in the air and in us. In our own bodies, microplastics are being found in our reproductive systems, our blood, within individual cells, in our brains – everywhere researchers look. The truth is we are only beginning to discover the extent of this pollution and the resulting ecological and health impacts. If you think this is bad news, you are right.
Microplastics in our bodies can impact our health in three basic ways: simply having a piece of plastic in your blood or in your brain may cause health problems. The second source of concern are the additives in plastics that are known to leach out – pigments, plastizers, stabilizers, fire retardants: ‘forever chemicals’ associated with a myriad of potential health impacts. And the third source is the fact that plastics attract other chemicals in the environment – herbicides, pesticides and many other synthetic chemicals – which are brought into the body with the plastic, like a Trojan horse bearing toxic gifts.
Plastics generally do not disappear once they are in the environment. They just break down and become harder to clean up as they degrade into smaller and smaller bits. And this is the conundrum as we continue to produce (and dispose of) 400 metric tonnes each year. Like all pollution it is much easier and cost-effective to prevent its release to the environment than to try to clean it up later. One could look to selenium from coal mining or greenhouse gas emissions as examples of this. And though these are considered ‘wicked’ problems, doing something better is always better than doing nothing at all. So, what can you do?
Plastics are an important engineering material – strong, lightweight, chemical resistant, tough. They are useful in durable goods, but maybe not so necessary as disposable goods. One of the easiest ways to reduce the amount of microplastics in the environment is to stop using single-use items like plastic bags, cutlery, straws, etc. You might think this is inconsequential, but about a third of plastic production (140 million metric tonnes) is directed to single-use products. That’s almost 40 lbs for each person on the planet each year! Only 1% of single-use plastics comes from recycled products.
It is likely that the largest source of microplastics from the home is from laundry. Synthetic fibres from our clothing break down and are washed away with the wastewater (eventually re-entering the environment as waste sludge or effluent water after treatment) or they are blown outside with the dryer air. What you can do is choose clothing with natural fibres when you can; use full washer loads with minimum laundry soap and set on gentle; and hang your clothes to dry. Millions of microfibers are released in each load of laundry – these simple practices may reduce this number by 70%.
The film, Plastic People, referred to the microplastics in each of our bodies. But we are also plastic people in that we have become so dependent on the material over the past 70 years. Knowing about the consequences of microplastics pollution should encourage us to use this important material more deliberately.
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. ...
For the rest of the presentation, click ... here
October 10, 2024
[This post was originally published on ABlawg.ca]
The Alberta Emergency Statutes Amendment Act, 2024 Surges Executive Powers under Water Act
By: Brenda Heelan Powell, Arlene Kwasniak, Braum Barber, and Ruiping Luo
For the pdf version, click here.
26 June 2024
City of Lethbridge, Climate Adaptation Strategy and Action Plan
To: Governance Standing Policy Committee
The Southern Alberta Group for the Environment (SAGE) has appreciated the opportunity to participate in the City of Lethbridge’s Climate Adaptation Strategy and Action Plan.
The Municipal Development Plan acknowledges that “Climate change is expected to be the most significant environmental issue in the coming years. In addition to creating challenges for ecosystem adaptation, a warming climate will bring changes that can affect the water supply, agriculture, power and transportation systems, the natural environment, cultural and heritage sites, and human health and safety. … Mitigating, responding to, and adapting to the impacts of climate change, including constraints on water and increased severe weather, will become increasingly important” (p.184).
This is an important direction for policy-makers in our collective efforts to prepare Lethbridge for the impacts of climate change on how we live, work and recreate. For success, a robust adaptation plan is vital – the health of the natural environment, the effectiveness of our economy, and social cohesion are all in play.
The multi-stakeholder planning process was very well organized and presented, with a comprehensive evaluation of climate impacts on labour productivity, building performance, public health, and infrastructure damage from extreme weather events. The most important outcome from these analyses is that there is a real cost to inaction. In other words, there is tangible return-on-investment for adaptation interventions that protect our community.
Another important perspective is that this is not directly a mitigation plan that relates to various international protocols. It is an adaptation plan that prepares Lethbridge for anticipated impacts, and offers long-term actions to preserve a livable future.
We cannot express strongly enough how important this project is for Lethbridge. Successful implementation of adaptation goals will have profound impacts on our economy and our social well-being. SAGE encourages the Governance Standing Policy Committee to support the Climate Adaptation Strategy and Action Plan.
30 May 2024
Long-term Affordable Housing:
Bill 18 Provincial Priorities Act, Bill 20 Municipal Affairs Statutes Amendment Act
Dear Hon. Ric McIver, Minister for Municipal Affairs,
The Guardian (9 May 2024) asked the question: ‘What are the most powerful climate actions you can take?’ From the leading experts queried, the fourth top response was to reduce home heating and cooling emissions. SAGE agrees, and would add that this also speaks to affordability.
Infrastructure Canada data indicates that the average expected useful life of a single detached home in Alberta is 65 years. The data collected was based on social and affordable housing assets in both urban and rural settings. This means that a home built today is expected to still be part of the building stock in 2090. We know that, between now and 2090, there are expectations that greenhouse gas emissions be reduced to net-zero. We have to ask ourselves: Are we building homes today for yesterday’s climate? And is this affordable in the long term?
It appears, in the absence of robust public discussion, that the Provincial Priorities Act (Bill 18) is designed to restrict Municipalities and other provincial entities to enter agreements with any other entity without prior approval from the Government of Alberta. One might imagine this approval process could include grants from corporate sponsors or the Government of Canada that are directed to the reduction of greenhouse gas emissions. If, say, climate change mitigation and adaptation were not a priority for the Government of Alberta, much needed funding for municipalities and public research may or may not be allowed. Such gatekeeping of the public good may unintentionally restrict our collective ability to explore and innovate solutions for energy transition, building performance and, ultimately, long-term affordable housing.
Similarly, the proposed Municipal Affairs Statutes Amendment Act (Bill 20) limits the ability of municipalities to require “non-statutory studies as requirements for building and development permits.” Again, ‘non-statutory studies’ is a loosely defined category, but could include performance modelling for homes that are expected to meet higher standards as established by a municipality.
One of the motives expressed by the Government of Alberta for components of these Bills was to ‘standardize’ building in the province to make it more ‘affordable’. The standard would be the National Building Code, which (though being updated) currently sets a performance standard that will not only fail to achieve greenhouse emission targets, but also leave the homeowner with an unaffordable liability if energy prices continue to rise.
For the complete letter, click ... here.
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
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.
AWA: Bison Designation in Alberta
15 March 2023
Dear Minister Schulz and Minister Wilson,
We are writing to request your support for the reclassification of free-ranging bison as ‘wildlife’ under the Alberta Wildlife Act. This important change would recognize their vital role in the ecosystem, provide protection for wandering herds, and acknowledge the cultural and historic significance for Indigenous communities. Reclassification would also align Alberta with the neighbouring provinces of Saskatchewan and British Columbia, where bison are already recognized as wildlife.
American bison (Bison bison), also known as buffalo, iinnii (in Blackfoot) or Tatâga (in Stoney Nakoda), are a keystone species, critical to the health and long-term sustainability of ecosystems, particularly in the prairie region. Their movement, grazing, wallowing and other behaviours support the creation of distinct habitats, promoting plant and animal biodiversity and encouraging ecosystem resiliency. Unlike cattle, which are domesticated and an introduced species, bison evolved as a part of the grasslands and open woodlands of the boreal forest. The current classification of plains bison and wood bison outside designated Wildlife Management Units (WMUs) as domesticated livestock fails to recognize their integral role within the ecosystem.
[...]
Designating plains and wood bison as ‘wildlife’ under the Alberta Wildlife Act is long overdue, and is vital for effective management, conservation and recognition of bison on the Alberta landscape. As Minister of Environment and Protected Areas and Minister of Indigenous Affairs, your respective ministries have the responsibility to protect Alberta’s biodiversity and ecosystem health, and work towards meaningful reconciliation with Indigenous communities. Bison, as both a keystone species and strong cultural symbol, are crucial to maintaining ecological health and supporting Indigenous healing.
For the complete letter, click ... here.
The Zombie-like Nature of the Proposed Grassy Mountain Coal Mine
Lorne Fitch, P.Biol.
Published 05 March 2024 in The Lethbridge Herald
In the recent pronouncement from the minister of Energy that the proposed Grassy Mountain coal mine is still an “advanced project” one might conclude he believes in the living dead. Nothing it seems is ever dead, it just waits in a moribund condition for the kiss of life from a government out of touch with Albertans’ feelings about blowing the tops off mountains in the Eastern Slopes. Apparently this minister required a bit of remedial tutoring to be assured that Grassy Mountain is in the Eastern Slopes.
He may not have read the report from brave scientists in another government department who concluded the old mine and the one on Tent Mountain continue to spew toxic materials at levels that far exceed provincial and federal standards. I suppose that is, in his estimation, a reflection a mine couldn’t really be dead, if it continues to actively and negatively affect downstream water and water drinkers.
On the minister’s reading list should have been the results of the joint federal/provincial panel. The panel heard from dozens of experts who debunked all the Australian company’s claims of minimal impacts, successful mitigation plans (including dealing with selenium and other toxic chemicals), bountiful economic benefits and so on, ad nauseum. That information, the facts and evidence then allowed the panel to conclude this project was not in the public interest. None of the evidence has been successfully contested by the company.
The minister must have also overlooked or slept through the massive outpouring of concern from Albertans over the prospect of turning the Eastern Slopes into a series of black holes at the expense of watershed protection, biodiversity maintenance, recreational and tourism attributes and the very real specter taxpayers would be stuck with the reclamation costs (as is so very evident now with the petroleum sector).
Based on the extreme backlash, the Alberta government convened a “Coal Policy Committee” to advise it on coal issues. The extensive public engagement process found Albertans’ “top of mind” concern was the environmental impacts of coal mines. Two things stand out from the results of the consultation:
“Albertans have concerns about the regulatory process for coal activities. Albertans are concerned that coal policies can be easily overridden when many thought that these policies were legally binding.”
With this latest revelation about an about face on the status of Grassy Mountain those concerns still register large. The minister might consider this report required reading.
This situation resembles so closely an anecdote about W. C. Fields, an American comedian. He was an avowed atheist, yet was observed by a friend reading the bible on his deathbed. Asked why, Fields reply was “Looking for loopholes, looking for loopholes.” It would seem there have been an astounding number of loopholes sought yet all that have been through a judicial review have failed. Experts in law and policy point out the project is “legally dead.”
What else could explain the minister’s reluctance to drive a stake through the heart of this coal proposal and put it and Albertans out of our misery?
Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a past Adjunct Professor with the University of Calgary.
We're Running Out the Clock on Caribou Population
Lorne Fitch, P.Biol.
Published in The Lethbridge Herald 16 February 2024
Great billows of smoke were used to hide battleships in wartime. Smokescreens are still employed, but to disguise a lack of meaningful activity, especially with the long-running battle to save caribou in Alberta. You can’t see the smoke, but it’s there in the form of caribou task forces, ostensibly tasked with saving caribou, but having the opposite intent.
The federal government, the last chance for species at risk, has told the province to produce and deliver on a plan to ensure caribou don’t go the way of the passenger pigeon. A recently released report, years late, shows little or no progress.
Caribou task forces were formed of concerned conservation groups and Indigenous Peoples plus the usual footdraggers of industry. In particular, the timber and energy industries are the ultimate gate-keepers, trying to run out the clock for caribou, as they maximize economic opportunity. They are abetted by timorous provincial politicians, who hide in plain sight, behind the smokescreen of these committees.
Caribou are running out of time. Or, time is running out of caribou. This species depends on mature to old growth forests. This is where lichens, the caribou’s main food source, are found. Mature forests don’t provide forage for moose and deer—the mainstay for wolves. When timber is harvested habitat shifts to benefit moose and deer and the logging roads, seismic lines, oilpatch roads and pipeline right of ways are perfect travel lanes for wolves. Caribou lose.
The pace of resource extraction in the northern foothills and boreal forest is at a stage where no caribou population seems safe and most are declining.
Biologists hold little hope if the present trend continues. In the face of this, industry denies, delays, detracts and deflects from any reasonable solution that would keep caribou on the land.
The timber industry says, “Don’t worry, in 80 to 100 years there will be lots of caribou habitat.” This would be like assuring those in the conference room that oxygen isn’t available right now, but will be in a day or two. Perhaps it was a lack of oxygen that prompted the industry response. An energy representative replied that the pace of oil and gas extraction had to continue or else, “Where would the government get the financial resources for caribou habitat restoration?” These are not solutions, but rather hollow and disingenuous excuses.
In the sitcom, The Simpsons, Ned’s parents were beatniks, early precursors to hippies. In the care, raising and nurturing of Ned, they rejected the conventional norms and disciplines of parental authority and direction.
Ned developed symptoms of bad behaviour, beyond their control. In desperation they took him to a child psychologist. The doctor asked what they had tried to change Ned’s behaviour. Ned’s father, frustrated and desperate for help said, “We’ve tried nothing and we’re all out of ideas.”
This Simpson’s episode is a perfect metaphor for the lack of progress on caribou conservation.
This smokescreen doesn’t cover caribou, because there are so few left to disguise.
Politicians and the senior bureaucrats have forgotten who their “tribe” is—it is Albertans and not industry. That misplaced loyalty got us to where we are today with caribou. Utah Philips, folk singer, raconteur and anarchist, once said: “The Earth is not dying, it is being killed, and those who are doing the killing have names and addresses.” Their names and affiliations are writ large on the phoney caribou task forces and, in the background, those who set up these smokescreens to disguise their spineless behaviour.
Doing nothing is not a course of action. Instead, it is a flight from responsibility and accountability. It may be high time for the federal government to step in, to be the adults in the room.
The province and its industry allies seem intent on running out the clock on caribou to ensure no appropriate recovery action is taken. Shame on them.
Lorne Fitch is a professional biologist, a retired provincial Fish and Wildlife Biologist and a former Adjunct Professor with the University of Calgary.
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 major dams and diversions. Is irrigation expansion worth the increased risk to our rivers’ water quality, fish and cottonwood forests, not to mention other water users?
Two-thirds of the Oldman River’s natural flow in an average year is allocated for irrigation agriculture comprising eighty-seven percent of total volume of water licences. Five percent is licenced for industrial use and only two percent for municipalities. Eight irrigation districts hold the largest, most senior water licences dating back to 1899. Because of historical over-allocation, the basin is closed to new water licences. As river flow declines the proportion of water used for irrigation agriculture, will only increase. Rights to water, our most essential and limiting public resource, will be in more demand with population growth, economic diversification and settlement of indigenous rights. Is it reasonable to entrench one sector’s stranglehold on water rights and deny options to future generations for a diverse and environmentally sustainable economy?
MLA Hunter’s presumptions about irrigation expansion and increased storage paid for by government are premature and ignore the established need for environmental impact assessment and review by the Natural Resources Conservation Board to determine if the proposed projects are in the public interest. There has yet to be a full evaluation of costs and benefits. Are there implications for communities and land use in our headwaters? Are we witnessing undue influence by the agrifood industry over important land use and water management decisions that have repercussions for all of us who call the Oldman River basin home? It is reasonable and realistic to expect public scrutiny of these matters which MLA Hunter considers a done deal.
2 February 2024, Letter to Hon. Ric McIver, Minister for Municipal Affairs
Municipal Charter and Building Code Bylaw Authority
The Southern Alberta Group for the Environment (SAGE) opposes the proposed changes to the Municipal Charter regulation for the cities of Calgary and Edmonton, specifically the proposed removal of Section 7(2) of the Safety Code Act Amendments which currently reads:
(2) In the Safety Codes Act, in section 66, the following is added after subsection (3):
(4) Notwithstanding subsection (1), the City may make bylaws relating to environmental matters, including, without limitation, matters relating to energy consumption and heat retention, but only to the extent those bylaws are consistent with all regulations made under this section and section 65.01 and all codes declared in force by those regulations.
Canada has joined 120 nations in committing to net-zero emissions by 2050, including all G7 countries. Many responsible provinces and cities in Canada have also made net-zero commitments by supporting innovation designed to transform the energy-performance of the built environment, including residential homes.
Removing the ‘building code bylaw authority’, which allows a municipality to make bylaws regarding energy consumption and heat reduction, restricts the sort of innovation and technological progress required to reduce emissions related to the built environment.
For the complete letter, click ... here.