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AWA Statement of Concern: Fortress Water Trucking Proposal

August 6, 2019

August 6, 2019

Hon. Jason Nixon
Minister, Alberta Environment and Parks
#323 Legislature Building, 10800 – 97 Avenue NW
Edmonton, AB  T5K 2B6
Via e-mail: aep.minister@gov.ab.ca

Regulatory Approvals Centre
Alberta Environment and Parks
5th Floor, South Petroleum Plaza
9915 108 Street
Edmonton, AB T5K 2G8
Via e-mail: aep.waapplications@gov.ab.ca

Fortress Mountain Holdings Ltd. Application No. 003-00037369, File No. 12562

Dear Minister Nixon and Water Act Regulatory Approvals Centre,

Alberta Wilderness Association (AWA) appreciates the opportunity to provide this Statement of Concern on the Fortress Mountain Holdings Ltd. (Fortress) water application no. 003-00037369, file no. 12562.

Founded in 1965, AWA works throughout Alberta towards the completion of a wilderness protected areas network, and for good stewardship of all lands that are the source of our clean water, clean air and wildlife habitat. With over 7,000 members and supporters in Alberta and across Canada, AWA helps Albertans learn more about wilderness and watersheds, and participate in opportunities to conserve them as a legacy for future generations.

AWA strongly opposes this Change of Purpose application for part of Fortress’ 1968  water license from Municipal (Urban Water Supply) to Commercial (Truck fill station & water hauling) purposes.

This license was issued to supply water for Fortress ski hill operations. We request that the 50 million litres per year that is clearly not needed for its intended original purpose remain in the mountain headwaters. It should not be permitted an entirely new, un-contemplated and environmentally inappropriate purpose.

Probable Use
Of its total water supply license of 98.678 million litres per year, Fortress is indicating a non-use of 50 million litres per year for its ski hill operations. It proposes to sell that unused portion to be trucked off-site, bottled/canned and sold.

Fortress has not publically provided a definite destination or bottled/canned product pending a finalized contract. We must comment based on the probable use of the water, because it is too late to learn this after a regulatory decision and the signing of a binding contract.

We understand Alberta Environment and Parks confirmed that Fortress’ application was to truck the water to a bottling facility in Calgary[1]. Fortress has stated that it opposes single use plastic, but it has also stated that once the contract is signed, it “won’t have anything to do with” the buyer[2]. So the packaging appears uncertain, especially in the longer term. We are referring to our concerns with this bottled/canned water, regardless of the exact beverage format, which will most likely be trucked from Fortress’ site to Calgary.

Impacts
Fortress has confirmed in a July 26 letter (attached) to the public that this trucked bottled water will be marketed for its ‘purity’. Existing municipal water supplies are of very high quality, whereas this bottled water will actually be worse for the environment. Its higher impacts include:

  • removing water from a small mountain stream flowing into a protected area in the Bow River basin headwaters;
  • greenhouse gas emissions to pump and transport thousands of truckloads per year of water that is already flowing naturally to Calgary; and
  • helping to promote bottled/canned water as ‘purer’ than high quality municipal drinking water, when we need to greatly reduce our overall packaging and waste.

AWA is opposed to removing water not needed for its original purpose for an un-contemplated and environmentally inappropriate purpose from a Kananaskis headwaters stream, which would otherwise flow into and benefit Galatea Creek in Alberta’s Spray Valley Provincial Park.

Mountain ‘headwaters’ lands receive snow, rain and melting glacier water that provide most of the flows of the Bow and other major Alberta rivers. During high flows, channels are formed and flushed, nutrients and sediment are transported downstream, riparian areas are changed and renewed. A portion of runoff and channel flows are absorbed into the ground to emerge later as the essential year-round ‘base flows’ to our rivers. During low flow periods, aquatic life can be limited by water scarcity. Mountain ecosystems are also especially vulnerable to the uncertainties posed by climate change[3]. Considering these factors, this water that is not needed for its contemplated purpose should not be extracted and sold.

While 50 million litres per year is not a large flow in the overall Bow River watershed, on principle we must oppose the precedent of very poor re-allocation choices of our limited Bow basin water resources. In the 50 years since the Fortress water license was issued, much has changed. The Bow’s future water supply has substantial risks:

  • the Bow River basin is now closed to new surface water licenses – regardless of how small – because of over-allocation concerns, both for aquatic ecosystems and prior rights holders.
  • even without factoring in climate change, there is now strong scientific evidence that pre-20th century droughts in the Bow River basin were much more severe than the flow levels experienced in the 20th century, which formed the period of record when most Bow River basin water licenses were issued[4];
  • there are even greater risks of severe droughts in the Bow with the predicted disappearance of most Rocky Mountain glaciers by 2100[5], and with other climate-change affected flow risks in the future;

Managing these cumulative effects for future generations and the health of aquatic ecosystems requires responsible allocation decisions of Bow waters, no matter how large or small the license.

Water Act and Original License Purpose
We are mindful of Condition 4 on Fortress’ 1968 water license: “The rights and privileges hereby granted are subject to periodic review and to modification to ensure the most beneficial use of the water in the public interest and more particularly to ensure preservation of the rights of other water users.”

This license was issued in 1968 for a particular use, timing and location. The Water Act ‘deemed’ historic licenses and made them permanent under their original terms. If a diversion for a new purpose in terms of use, time and space occurs, that should be by a new license. In AWA’s view, the Director should not be granting a paramount and priority diversion to what is essentially a new diversion.

AWA believes that this new, un-contemplated proposed use by Fortress is well within the discretion of the Alberta government to dis-allow in the public interest. We request that Fortress’ proposed change of purpose be dis-allowed, and that the non-used water remain in the Kananaskis-Bow headwaters tributary of Galatea Creek.

Sincerely,

ALBERTA WILDERNESS ASSOCIATION
Carolyn Campbell
Conservation Specialist

cc: Thomas Heath, Managing Director, Fortress Mountain Holdings Ltd.

Click here for Pdf version and attachment

[1] Kananaskis water could be headed to bottling facility in Calgary, Rocky Mountain Outlook, July 24, 2019.

[2] Fortress Managing Director Tom Heath quoted as: “We’re looking to sell the water. What the buyer wants to do with us, it could be, God only knows, it could be bottled water, but we won’t have anything to do with it. Think of us like an oil well. We are not a gas station.” In Water fight simmering over selling Fortress water for commercial use”, CBC, July 25, 2019.

[3] For example: “Mountains also respond rapidly and intensely to climatic and environmental variation, and are increasingly coming to be recognized by both social and natural scientists as ‘sentinels for change.’” Lael Parrott, Zac Robinson and David Hik in Alpine Club of Canada’s State of the Mountains Report, May 2018, page 2.

[4] For example: “Myths of abundant and stationary water resources have influenced water policy and management in western Canada. Data presented in this chapter demonstrate that water use, policy and management were established during a period of fairly stable and reliable water supplies as compared to preceding and projected hydrological regimes.” In “Upland Watershed Management and Global Change: Canada’s Rocky Mountains and Western Plains” by Dave Sauchyn, Michael Demuth and Alain Pietroniro. January 2008. Chapter 3 of Mountains, Valleys and Flood Plains: Managing Water Resources in a Time of Global Change, Rosenberg International Forum on Water Policy. Publisher: Routledge, Editors: A. Garrido, A. Dinar, pp.32-49.

[5]Rocky Mountains could lose 90 per cent of glaciers by 2100” Calgary Herald, April 7, 2015.

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