Recently Approved Alberta Solar Project Will Threaten World’s Second Fastest Land Mammal
March 25, 2024
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The Alberta Utilities Commission (AUC) issued its decision on the Aira Solar Project located south of Medicine Hat yesterday, allowing the project to proceed. This project is one of several renewable energy projects placed in southeastern Alberta, along an internationally important migratory route for Pronghorn.
Aira Solar is the latest of several renewable energy projects on a commonly used pronghorn migration route, impeding pronghorn movement and risking their survival. Map was presented as evidence to the AUC by Cliff Wallis.
Many populations of pronghorn rely on migration to survive, avoiding the heavy snows and harsh winters by moving south, and returning to graze the new spring shoots. The development of fences, highways and, most recently, wind and solar generators, is threatening their traditional migration routes. AWA supports renewable energy development, although not at the expense of Alberta’s wild lands and wildlife.
“Numerous wind and solar projects are either built, proposed, or being considered in southeastern Alberta, but no cumulative effects study has been done to determine the impacts of these facilities on biodiversity,” says Cliff Wallis, AWA Director, “The Aira Solar Project will place 42 km of 2 m high chain link/barbed wire top fence within a known international migration corridor for Pronghorn. At a time when some neighboring landowners are upgrading their fences to be wildlife friendly, this project’s Pronghorn-proof fences will butt right up to the wildlife friendly fences.”
Given the potential impacts of the project on an internationally important migratory route for Pronghorn, Alberta Wilderness Association (AWA) is calling upon the Alberta Government to pause this project until a cumulative effects assessment is completed for southeastern Alberta. A cumulative effects assessment is sorely needed to understand the environmental impact of all the solar, wind and other industry and urban developments occurring in southeastern Alberta.
The AUC decision to allow this project, in concert with other renewable energy developments in the surrounding area could have significant impacts on pronghorn migration. Minister Neudorf’s policy guidance to the Alberta Utilities Commission of February 28, 2024 is not up to the job of protecting Alberta’s environment and our wildlife. Given the strict restrictions imposed for some renewable projects around parks and “pristine viewscapes,” the AWA is seriously concerned that an international migration corridor for a sensitive species remains unprotected by the new policy. The Aira Solar Project is also located within 3.3 km of Red Rock Coulee Natural Area, a provincially legislated protected area.
Background
On March 21, the AUC issued their decision on the Aira Solar Project and Moose Trail 1049S Substation (Decision 27842-D01-2024), a project located on approximately 4,480 acres (1,813 hectares) of private, cultivated land in the County of Forty Mile No. 8. The power plant will place approximately 1,155,766 solar panels on this land, surrounded by fencing. This region is along a known route for pronghorn migration, and the placement threatens pronghorn movement.
With respect to Pronghorn, the AUC decision states:
“57. The Commission observes that AEPA assessed the risk to wildlife from the project fencing as moderate, given that the proposed fence design may create risks for wildlife movement, entrapment, or collision. However, AEPA determined the project poses an overall low risk to wildlife and wildlife habitat. AEPA did not specifically mention pronghorn in its report.”
“59. The Commission recognizes that the general project area (being the mainly cultivated project land and the surrounding native grassland) supports pronghorn migration. The Commission acknowledges that pronghorn have been observed on project lands and that once developed, the fenced-in areas of the project will block pronghorn and other ungulates from crossing project lands. This must be weighed against considerations that: (i) project fencing is required for safety and security reasons; (ii) the project is primarily sited off of native grasslands; (iii) native grassland is typically preferred by pronghorn; and (iv) the presence of native grassland adjacent and surrounding the project is expected to continue to support pronghorn migration activity.”
“60. The Commission accepts the evidence provided by C. Wallis and recognizes that fencing, linear development and habitat fragmentation will have probable impacts on pronghorn populations and the effectiveness of these east-west corridors is subject to monitoring and adaptive management. The Commission accepts that installing unfenced corridors to provide east-west access across the project is an acceptable attempt to mitigate potential impacts to pronghorn, however, the effectiveness of this mitigation has not been extensively documented.”
Despite the risks, the Alberta Utilities Commission decision accepts the proponent’s mitigation and commitment to install wildlife cameras and document the success of the proposed corridors in allowing pronghorn movement through the project. The proponent has also agreed to make this data publicly available. However, as the AUC decision notes, the effectiveness of providing corridors through the project area is unknown, and pronghorn avoid areas of human development, including solar generators.
This decision is not what Cliff Wallis, who submitted evidence to the hearing as a professional biologist, recommended in his report for this proceeding. He recommended not to approve the project but, that if the project was approved:
“Defer work on this project until a cumulative effects assessment for southeastern Alberta, including impacts on Pronghorn, is completed and conservation policy developed and implemented. This is critical in the ongoing absence of a Biodiversity Management Framework with measurable thresholds under the South Saskatchewan Regional Plan.”
In his report for the proceeding, Wallis noted the importance of the landscape in this area:
“1. Various parts of the project lands or immediately surrounding area have been identified as significant or important wildlife habitat:
- intact native grassland and Southeast Alberta Conservation Offset Pilot area for restoration in the South Saskatchewan Regional Plan;
- high value landscape by the Prairie Conservation Forum;
- environmentally significant areas and an area of wildlife sensitivity (high risk) for renewable energy projects by the Government of Alberta;
- target landscape for the North American Waterfowl Management Plan;
- an internationally important migratory route for Pronghorn by wildlife researchers; and
- an internationally significant landscape in a study of the Northern Glaciated Plains of North America by Cottonwood Consultants.
“2. The Aira Solar Project will create an additional barrier to Pronghorn movement in an area that is important for Pronghorn on a continental scale.”
Fences are one of the greatest barriers to pronghorn migration. In recent years, the use of “wildlife-friendly fencing,” which uses a higher, smooth bottom wire, has been adapted in some regions that allow pronghorn to pass. The Aira Project will use impenetrable barbed wire and chain-link fencing, further reducing pronghorn movement.
There is no remedy in the AUC decision that explains what will happen if pronghorn are found to be affected by the project. The science behind the proposed mitigation – creating an additional opening through the project and setting up wildlife cameras – is untested and adds about 6 km of Pronghorn-proof fence to the original proposed 36 km of fence.
As AWA submitted during the AUC inquiry into the ongoing economic, orderly and efficient development of electricity generation in Alberta, “Power plants should not be permitted in environmentally significant areas (as defined and mapped by Alberta), Key Biodiversity Areas (as mapped by KBACanada), Important Bird Areas (as defined by BirdLife International) and should avoid High Value Landscapes (as defined by ABMI and mapped by PCF).” This project fails to follow these suggestions, and endangers sensitive pronghorn populations.
The AWA is of the opinion that the Aira decision reflects a systemic failure of Alberta Environment and Protected Areas (AEPA) to identify and protect critical Pronghorn migration habitat within the regulatory environment for renewable energy development. These migration corridors are not considered in the Wildlife directive for Alberta solar energy projects, nor are they being protected under the new regulations aimed primarily at protecting farmland and “pristine viewscapes.”
