ENGO Letter to Government Highlighting Concerns regarding Proposed Alberta Irrigation Expansion Project
March 31, 2021
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
Partnership 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
Jennifer Nitschelm, Director, Irrigation Secretariat, Agriculture and Forestry, email@example.com
Vicky Kress, ED Alberta Irrigation Districts Association, firstname.lastname@example.org
Mark Bennett, ED Bow River Basin Council, email@example.com
Shannon Frank, ED Oldman Watershed Council, firstname.lastname@example.org
Marilou Montemayor, ED Southeast Alberta Watershed Alliance, email@example.com
AMEC. 2009. South Saskatchewan River Basin in Alberta Water Supply Study. Available here.
AMEC. 2014. Water Storage Opportunities in the South Saskatchewan River Basin in Alberta. Available here.
Alberta Irrigation Districts Association. 2019. Report on Proposed Irrigation Storage Reservoir Ranking. Available here.
Alberta Irrigation Projects Association. 2010. Irrigation Sector Conservation, Efficiency, Productivity Plan 2005-2015. Available here.
Alberta WaterSMART. 2016. Climate Vulnerability and Sustainable Water Management in the South Saskatchewan River Basin, Final Report. 129 pages. Available 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.
Bonsal B. et al. 2020. Historical and Projected Changes to the Stages and Other Characteristics of Severe Canadian Prairie Droughts (2020) 12:12 Water 3370.
Byrne J. et al. 2006. Current and future water issues in the Oldman River Basin of Alberta, Canada. Water Sci. Technol (2006) 53 (10): 327-334. Available here.
Jiang et al. 2017. Historical and potential changes of precipitation and temperature of Alberta subjected to climate change impact: 1900–2100 (2017) 127 Theoretical & Applied Climatology 725.
Pentney A. and D. Ohrn. 2008. Navigation from history into the future: the Water Management Plan for the South Saskatchewan River Basin in Alberta. Canadian Water Resources Journal 33:4, 381-396. Available here.
Schindler D.W. and W.F. Donahue. 2006. An impending water crisis in Canada’s western prairie provinces. PNAS 103 (19) 7210-7216. Available here.
Scott C.A. et al. 2014. Irrigation efficiency and water-policy implications for river basin resilience. Hydrology and Earth System Sciences, 18, 1339-1348. Available here.
Note: According to the Alberta Government technical fact sheet and the Canada Infrastructure Bank (CIB) project description, funding for the project is through a partnership of the Alberta Government ($244.5 million) and CIB ($407.5 million). Irrigation districts, non-profit corporations enabled under the provincial Irrigation Districts Act, are proposing to contribute $163 million.
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)
Key findings regarding risks to the aquatic environment due to water allocations include:
Overview regarding Aquatic Environment (p. 3)
Summary of Water Allocations Report (p. 8)
Summary of Instream Flow Needs Determination (p. 14)
Summary of Riparian and Aquatic Condition Report (p. 16-18)
Lalonde K. et al. 2005. Southern Alberta’s Watersheds: An Overview. Prairie Conservation Forum Occasional Paper Number 5. (here)
Alberta Environment (June 2007). Aquatic and Riparian Condition Assessment of the South Saskatchewan River Basin. (here)
Assessment of the aquatic (water quality, hydrology) and riparian condition of all main-stem river reaches in the South Saskatchewan River Basin were assessed. Results for reaches below irrigation dams and diversions include:
Oldman Watershed Council (2010). Oldman River State of the Watershed Report Summary (2010) (here)
The following risks to the aquatic environment due to current allocations were identified.
Southern Tributaries Sub-Basins (p. 9-10)
Oldman River Mainstem (p. 12-13)
Recommendations and Best Management Practices (p. 14-15)
Bow River Basin Council (2010). Bow River State of the Watershed Report Summary (here)
Degradation of the aquatic ecosystem was identified in several reaches of the Bow River and its tributaries. Findings contained in the identifying risks to the aquatic environment in the mainstem Bow River due to current allocations include:
Alberta Government. (2014). Bow River Phosphorus Management Plan: Taking Action to Manage Phosphorus Together. (here)
This strategic plan was developed to address sources of phosphorus in the Bow River between the Bearspaw Dam and Bassano Dam. It is being implemented by a multi-stakeholder committee. A maximum loading of 370-490 kg/day has been identified to protect aquatic life. Regular monitoring shows acceptable phosphorus thresholds have not recently been crossed but a growing population, intensification of land use and alteration of flows may cause phosphorus levels to trend upward requiring more proactive management.
Alberta Government (2014). South Saskatchewan Region Surface Water Quality Management Framework: for the mainstem Bow, Milk, Oldman and South Saskatchewan Rivers (Alberta). (here)
The Framework, mandated to support the South Saskatchewan Regional Plan, monitors long-term cumulative changes in water quality. Baseline is 1999-2009 monitoring results. The Framework sets surface water quality triggers and limits for 15 indicators measured at nine monitoring stations. Indicators are total ammonia, chloride, nitrate, total nitrogen, total dissolved phosphorus, total phosphorus, sulphate, sodium adsorption ratio, specific conductivity, total dissolved solids, turbidity, pH and Escherichia coli. Secondary indicators are mercury, selenium, 2,4-D, dicamba, methylchlorophenoxyacetic acid and mecoprop. Annual reports on status of water quality are prepared. Reports are available April 1 – March 31 for six years (2014-2020).
Results of long-term monitoring of water quality over three to four decades were briefly summarized. Long-term network sites included: Bow River at Carseland, Cluny and Ronalane; Oldman River at Brocket, Lethbridge and Highway 36; and, South Saskatchewan River at Medicine Hat. Key points regarding water quality prior to 2010 follow.
Alberta Government (2014-2020). South Saskatchewan Region Surface Water Quality Management Framework: Annual status of water quality reports.
2014-2015 status of surface water quality (here)
2015-2016 status of surface water quality (here)
2016-2017 status of surface water quality (here)
2017-2018 status of surface water quality (here)
2018-2019 status of surface water quality (here)
2019-2020 status of surface water quality (under review by AEP)