Summary of Public and Stakeholder Consultations: Sept – Oct 2013

Background
Technical
Reports

Public and
Stakeholder
Consultation

IWMP
Development

 

Glossary
of Terms

 

Written and oral responses from the online Response Form, stakeholder workshops, and a small number of emails from individuals were combined and are summarized below. Additional information can be found here:

General

  • Recommendations need a timeline
  • “Water is what unites us in the world” vs. “Whiskey is for drinking and water is for fighting”

Surface Water Quantity

Headwaters protection

  • Concerned that 50% of the water comes from the headwaters - why are we not focusing on protection of the headwaters - Buffalo pasture enhancement programs (burning, aggressive logging) grazing leases for cattle (overgrazing)

Flooding and drought

  • Re: flooding or drought – nothing is very clear that particular practices will conclusively cause severe flooding or drought
  • Inundation study being done this year (1 in 100 year flood impact); conducted by Government of Alberta

Water licences, water users, and allocation

  • Are there any water users that are exempt from allocation limits? – No
  • Inadequate resources to monitor licences/users
  • Users need to take more responsibility for their own actions

Water Conservation Objectives (WCOs)

  • Need more consultation on water conservation objectives (WCOs)

Hydraulic fracturing

  • Re: hydraulic fracking water use – has there been any reference made to total removal from the hydrologic cycle and its impacts?

Climate change

  • Climate change is accelerating the hydrologic cycle – i.e., more water is making its way inland, fracking water use impacts are not expected to be severe
  • People like to engage the river, but they don’t like it so much when the river engages them (i.e., flooding impacts)
  • Flood frequency return periods is a linear model (e.g., “Pacific decadal oscillation” – 30-yr cycle), every extreme event will change the observational record

Instream Flow Needs (IFN)

  • Concern with instream flows (re: fish)
  • Need “critical levels” to trigger cutbacks

Awareness

  • Newsletters – but could use more media
  • Need to use Twitter

Conservation

  • Idea: charge a levy on water licenses

Groundwater Resources

Hydraulic fracturing

  • Are we ignoring the risk of high pressure, high volume fracks pushing saline water into usable / potable water zones? - Certain zones are more active than others, not all flow systems are the same, e.g., Paskapoo formation - age-dating (radiogenic isotopes) to measure groundwater... at depths of 50m to 150m the age is 50,000 to 2 million years old . . . with some deeper formations it is registering at many millions of years old

Recharge

  • In 2005, very large recharge event in Okotoks (approx. 6 m), ever since has been slowly declining - decadal, in Calgary and southern part of the province (in wells) general increasing water levels to 1997, decreasing to 2002, increasing levels since then

Climate, climate change, weather

  • Correlation between climate cycles and groundwater? Yes, historic variability is important to understand (e.g., “Palliser variability” - periods of extreme drought impacting human settlement / development)

Monitoring

  • Re: monitoring wells, can we identify weaknesses in groundwater monitoring?
  • There have been efforts to monitor groundwater in Alberta where higher density activity has been occurring, Provincial Groundwater Atlas has been created in Alberta; can benefit from additional monitoring wells

Research

  • Need to understand cumulative effects of multiple wells (e.g., where individual users drill own wells)

Activities in the groundwater/surface water interface (hyporheic zone)

  • Sand and gravel mining impacts

What Are Organizations Doing?

  • Flood-proofing, drought-proofing
  • Monitoring stations – but accessibility of data and dissemination needs a lot of work
  • Reports produced – but need more interactive information / web tools
  • Water temperature gauges in the river
  • Fish and Game – advocating for fish, fish habitat and spawning areas
  • Town of Bentley
    • Stormwater retention pond installed
    • Drilled additional well
  • City of Red Deer
    • Ongoing investment in water and wastewater infrastructure
    • City of Red Deer Environmental Master Plan
    • Flood plain mapping
    • Water / creek monitoring study
    • Wet pond / engineered wetlands (stormwater treatment)
    • Stormwater outflow quality study
  • Red Deer River Municipal Users Group
  • Water rate change to conservation model
  • Leak detection
  • Church
    • Focus on spirituality of water
    • Church camps on water
  • Education and awareness
    • School education programs (outreach)
    • Communicating connectivity of water
  • Alberta Lake Management Society (ALMS)
    • Drafted a guideline for lake management planning
    • Actively working with three lake groups for implementation (Mayatan Lakes, Pigeon Lake [lake monitoring study to set protocol], Wabaman Lake)
    • Working directly with AESRD on Lake Watch program
  • First Nations connectivity to water
  • Acknowledge and encouraging efforts to protect water
  • Sylvan Lake
    • Planning tools and models for risk assessment
    • Focus on lake water quality
  • Lacombe – Sylvan Lake Management Committee – cumulative effects management system
  • Lacombe County
    • State of Environment report
    • Developing management plan
    • Treated water pipelines
  • Municipalities
    • Conservation efforts
    • Working Well Program
    • Some communities have community stewards
  • Natural Resources Conservation Board (NRCB)
    • Risk analysis and approvals, livestock operations
  • Surface and groundwater in relation to confined feeding operations
  • AESRD
    • Summary of policies and programs on surface water quantity
    • Hot-spots analysis (quantity demand)
    • Groundwater policy design
    • Dickson Dam – water quantity / assured water supply / winter flows / store and release / quantity increase water quality / lake stabilization / reservoirs / pumphouses / duck habitat / minimum flows based on instream flow study (16m3/sec minimum flow in RD River) above Medicine Lake and Little Red Deer rivers/ reduce downstream (pre-release) impacts / apportionment (increase to meet requirements for Saskatchewan) / “possible” cottonwood rejuvenation through controlled release
  • Suncor – Rimbey area wells 2500 m3 fracks reduce needs volume and fresh technology improvements
  • Website tool in development based on BC model - North East Water Tool (NEWT)

How Can We Work Together?

  • More communication in a clearer way
  • Tie importance of Water for Life
  • Ask locals what info would be most useful to help implement
  • Data not at right level to help local municipalities / organizations to implement; need more specific local info
  • Committee that is a multi-stakeholder watchdog (not partisan / political team) to see if plans are being implemented and, if not being done, they bring it to the attention or relevant groups
  • Annual review of key metrics
  • Short / medium / long-term reviews
  • Advocate to province for key actions
  • Set definitive timelines in management plan and follow up on these
  • Plan needs to be implemented in a non-partisan, engaging manner
  • Six key actions:
  1. Many sectors and partners working on connectivity / education / awareness of water issues (e.g., church camps, Fish & Game, municipalities)
  2. Advocacy for aquatic environment and sustainability, including follow-through on report recommendations
  3. Monitoring, flood-proofing, drought-proofing, planning – disseminating information
  4. Need more information available to more people (e.g., use of technology)
  • Need a coordinated, tangible achievement regarding implementation
  • More interface between province, stewardship groups, and municipalities
  • Pick one project and get on with it
    • E.g., detain water above Dickson Dam
  • What to do in future water shortage scenarios
  • Work at it - “heads down, butts up”

Detailed Technical Comments

Introduction and Context

1. Section 2.1.1 Environmental Indicators (could mention that AESRD 2012 refers to these as condition and pressure indicators). Table 1 - examples from this table could be condensed or the entire table could be removed.

2. Section 2.1.2 Programmatic and Social Indicators are referred to as response indicators in AESRD 2012.

3. Page 6, 2nd paragraph, there are 15 (not 14) defined sub-watersheds in the Aquality, 2009 SOW report.

4. Pg 9 and 17 - could add terms blue and green water and POE to the glossary section

Surface Water Quantity

General

5. Section 3.1.12, page 37, 2nd bullet and elsewhere is a bit misleading on the possible effect of forest harvest on peak flows (floods) and droughts. Literature cited (and in the general scientific knowledge) is talking about the mean annual peak flow (1:2) or slightly bigger (e.g. 1:5 see Figure 13 – pg 30), not large floods. There is some debate in the literature, but none of this is discussed in this report. Guillemette cited by the authors is a nice summary — see picture from the paper — refers to "bankfull" generally assumed to be 1:2 or slightly larger depending on the stream. Also, note that these are very small research watersheds not large river systems. The general rule of thumb is about 30% or less of a watershed in a young stage will make it hard to measure changes to the stream flow in very controlled research settings. Above the 30% there is extreme variation (see figure) and the level of hazard from forest harvest (or wildfire and insects) on the hydrology is generally estimated with professional opinion, available data, modelling or other methods.

Low flows are generally thought to increase because of reduced transpiration in harvested areas. There are some exceptions — forest areas cleared in chinook prone areas is one. Also, large-scale land conversion (i.e., forest -> agriculture –> rural land –> urban) could result in shifting of the flood freshet due to changes in flow paths. As they point out this may reduce low flows and effect extremes, but just forest harvesting and re-growth will likely result in more water on a site during extremes (droughts), I.e., increased recharge.

Section 4.8.5 on page 79 should just have the first line — i.e., the forestry section does not pose a risk to groundwater resources. The rest of the section is hypothetical, and extremely far reaching. In general, trees use and intercept water, by removing or killing them there is more water on a site to infiltrate, increasing groundwater recharge – see caveats to that statement above.

The idea of spills from the forest industry posing a risk to groundwater resources is a bit strange. At least with modern spill response standards, it may have been a problem in the past. I suppose designating refuelling sites away from sensitive recharge areas or close to surface water (e.g., not in riparian) is not a bad idea, However, this hardly seems like a hazard, especially given the level of energy extraction in the area. These statements lead to recommendations on page 93. At the very least expanded to include other activities that use "equipment" in the watershed: Ag, energy, etc. I would expect that they pose the same level hazard to groundwater resources.

I am generally in agreement with the above comments. Talking to my colleagues who have been studying forest hydrology in western Canada, my sense is that the effects of logging on stream flow and groundwater recharge are highly complex and site-specific. It is dangerous to draw a generalized conclusion from the literature and apply it to a particular watershed. It may be wise to keep a speculative tone of the report.

6. There was a box describing a transfer situation where Conoco was going to transfer water to the Water Trust for instream flow protection. The application was refused because only the government can hold water licences for instream protection. The decision was appealed and heard last March (I think that was the date). The Minister made Her decision last week and upheld the department’s refusal to accept the application because the Water Act states only the government can hold a licence for a Water Conservation Objective licence, which this application was by definition. You can read the issue and decision on the Environmental Appeals Board site.

7. Re: flooding or drought - nothing is very clear that particular practices will conclusively cause severe flooding or drought. Robert Sanford and Dr. John Pomeroy have done extensive research in this area; need to look closer at these documents.

Issues

8. If measures (legislation, enforcement, and citizen awareness) are not taken to protect riparian areas so that they are left in an undisturbed state all of the above will have worse impacts. At least defined setbacks could be instituted to give some measure of undisturbed riparian area on the shorelines of water bodies.

9. Industry impact such as deforestation at headwaters creating flooding. Need to manage headwaters to protect riparian habitat as having high water/flooding is causing riparian loss, leading to decrease in fish spawning areas.

10. The antiquated water licensing system we use in Alberta is an issue. First in line, first in time is a terrible policy and government needs to find the courage to fix it. Allocations should be done on a more modern approach that is need, value, and science based.

11. Seven of ten years ago the river was flowing considerably higher in Drumheller; this seriously impacts recreational activities in the summertime — kayaking, fishing, and canoeing. Rumour is the dam is holding water back for the Gleniffer Reservoir.

Goals/Outcomes

12. Section 3.5, Table 11: #3 doesn't make much sense to me. I just don't get it. #7 is too weak — "aim to conserve" pre-flow conditions — we can do better than that. #8 and #9 need more details in order to say they are acceptable; what will these look like? #10 I don't like "enhanced" would prefer a stronger word; this knowledge area is so critical and really the key to making good decisions.

13. Section 3.5, Table 11: Goal 3 is an outcome not a goal.

14. Section 3.5, Table 11: Outcome 5 - I'm trying to understand what is meant by the choice written as " Surface and groundwater supply and demand integrated to optimize options " If that means SW and GW should be considered as one water (diminishing one - diminishes the other) then I agree strongly- but if answering "agree" means I am agreeing that the GW volume is somehow guessed at so that it is business as usual at the water taking point- then I disagree strongly. There has been no GW mapping and GW resources are unknown at best and should not be a convenient excuse to keep draining the water basins.

15. Outcome 6: The choice " Land uses in basin aim to conserve hydrology and minimize risk of increased peak flows." I strongly agree with the aim to conserve hydrology by utilizing existing natural capital (preserving gravel aquifers and protecting riparian areas as erosion control) but if by minimizing the risk of increased flows it is meant that I agree with engineered dams, reservoirs and open ponds I strongly disagree.

16. All sectors should be encouraged to apply water conservation techniques (not just all industries as stated in outcome # 6)

17. Outcome 9: Also choice " Build flood control structure in select . . ." again this is a false management technique that creates losers downstream and decimates fish ecology- also a known. Strongly suggest restricting reducing flows and activities that negatively impact fishery and other ecology health and function be top of choice. Strongly suggest climate change allowance and threats be taken into account in BMP.

18. Outcome 9: Do not build flood control! Move inappropriate developments out of flood hazard areas.

Indicators

19. Section 3.6, Table 12: Indicator#1 - should mention that the temporary closure was set at 550,000 dam3 so a review of the allocation limit could be conducted. Indicator #3 - Check the WCO for this, I believe it should state that If flows are above the 20th percentile, no more than 55% of the natural flow can be taken (not 15% as stated in the outcome) - It would be useful to identify which of the indicators have baseline data/information available (it is not very useful to focus on indicators that can not currently be monitored/measured)

20. 540 (550) dam3 would trigger temporary suspension of new licences . . . 600 is the new trigger

21. These Indicators will monitor the status of the watershed as a whole. In drought conditions, the rate of change in water use would provide a more sensitive measure of relative use. All water uses are not the same. Ranking based on economic return per million cubic metres would improve the basis for rationing and/or for allocation.

22. "Industries aim for 30%”? Industries must be required, monitored and enforced upon - otherwise there will be the "economic excuse file" and nothing more done. 30% for Industry is minimal. Alternate systems should be encouraged (or mandatory?)

Recommendations

23. There needs to be more community involvement but there seems to be a lot of apathy or the public is so busy they have no time. It takes longer, but the information needs to be in the school system all the way from K to12 and further. Not just lip service but dedicated courses through programming.

24. Section 3.7.3.3 Municipalities prohibit new development in flood-prone areas is subjective because as we know with the increased flows from the headwaters, the sediment is filling in what used to be the main channel of river. This displaces more water and expands the flood zones out. It would be more beneficial to implement a program to ensure the capacity in flow zones is maintained as well as strict development plans.

25. Your data suggest that supply/demand ratio is, and will continue to be, favourable so the RDR watershed should be able to accommodate some population expansion without reducing flow to the regulated minimum. However, for decision-making purposes, a projection of future water demand based on expected and/or planned-for growth would be a valuable addition to the report.

26. Some recommendations are already being implemented and should be acknowledged (e.g., water conservation plans by several sectors).

27. It would help to have a prioritized list, with the most important recommendations to consider (i.e., ones that have the highest likelihood of being implemented and the most effect on the watershed).

28. I believe building restrictions should be in place in high water table areas. For example, in Springbrook, there should not be any basements! If basements are built, they should only be in the ground a few feet and soil built up around the structure to ensure drainage. This is not what has happened in the last five years! This year, I've seen a few houses built that way. A little late . . .

29. There needs to be a committee that is a multi-stakeholder watchdog (not partisan / political team) to see if plans are being implemented and, if not, bringing it to the attention or relevant groups.

30. Oldman River Dam has experimented with different operating procedures. Should investigate experimenting with operating procedures at Dickson Dam.

31. Section 3.7.3.4 Reusing Municipal Waste Water for industrial uses - what is the incentive to do this for industrial usage? What is the benefit for the watershed when the net volume doesn't change?

32. Why aren't municipalities getting credit for what is returned to the natural flow of the river?

33. Education of Drumheller residents is constantly needed to explain to people how the Dickson Dam operates and functions and why. There's a lot of misinformation about the impact of dam operations (e.g., death of Cottonwood trees along the river's edge). RDRWA should play a role in explaining the operations of the Dickson Dam.

34. Need more resources to monitor licences and users

35. Water licence opportunities should be managed adaptively with the opportunity to complete field level IFN studies to support licence applications. The studies and subsequent applications should be approved if they can demonstrate no adverse effects to the aquatic environment.

Groundwater

General

36. Section 4.7 Water quality data from private wells are reported, compiled and used routinely to monitor local groundwater resources.

37. Section 4.4 Figure 31: What does the tick mark for each year indicate? January 1 or June 30? The format of the horizontal axis needs to be changed, so the reader can clearly understand the seasonal trend.

38. Section 4.9, 1st Para, 4th line: Climate does not vary from year to year. By definition, climate refers to a long-term average (typically for 30 years) of meteorological condition. Once cannot talk about inter-annual variability of climate.

Issues (4.13)

39. Hydraulic fracking should be an issue. Re: hydraulic fracking water use - has there been any reference made to total removal from the hydrologic cycle and its impacts?

40. We need to know down to a finer scale where recharge and discharge of groundwater take place so that these areas are more effectively protected.

41. Generally speaking, water is not destroyed by usage, though it certainly gets contaminated. The aim should be to look at reducing/eliminating the contamination. For groundwater, the case is different, for in many areas it is “paleowater.” It is not being recharged from surface and will run out. The oil industry does not, normally need drinking water quality water, but looks for the cheapest source of water for well injection. This needs to change!

42. Section 4.13 Alluvial aquifer protection should be an issue.

Goals/Outcomes

43. Section 4.14, Table 4: Groundwater Goals 4 and 5 should be Outcomes. "Understanding" is a prerequisite for meeting the water protection and conservation goals and not an end in itself, as in: "we will meet these goals . . . by understanding . . ."

44. 4.14, Table 4: Outcome #4 - what does this mean? Who's providing the assistance?

45. Goal 4, Outcome 14: Saline groundwater use as an alternate to fresh water use for industry development should be exempt from groundwater licensing requirements, as this is an un-usable water source for most activities.

46. Outcome #11 - The WCO should account for groundwater contributions to the Red Deer River so this may not need to be included as an outcome.

Indicators

47. Section 4.15, Table 5: Focus more on indicators that can currently or easily be monitored or assessed (indicators that cannot be monitored could be moved to section 3.7 (Management Implications and Recommendations) Additional indicators:

  • # of landowners who have participated in the Working Well program (could set a target to have 10% increase in participants by a certain date (e.g., 2016)
  • # of rural municipalities that have programs and policies in place to support proper well abandonment

48. Section 4.1.5 Drawdown in aquifers will vary throughout the region and acceptable % drawdown may vary based on recharge potential of the aquifer. Regional monitoring needs to be risk-based, place-based and science-based.

49. Section 4.1.5 I wouldn't waste limited consultant resources on attempting to apply climate models to estimate future precipitation. Expert judgment is that those models are worthless. A sparse network of monitoring wells in major aquifers will have limited value unless it responds to drawdown by users. Collection, consolidation and analysis of water quality information and well test response data from licensed well operators would make more sense.

50. Too many of these targets are a best guess based on limited data. I can't agree with them until we get more information. All of our efforts should be focused there.

Recommendations

51. Section 4.16 General BMPs - specific sectors should be suggested for these BMPs where possible

52. There needs to be independent studies on the effects of hydraulic fracturing before there are regulations put in place. My understanding from sessions I've attended is that industry is the only one to have done any work on this and as they are paying for the study, the results may be slanted.

53. Some of the speculative risks can be covered off by industrial and municipal insurance bonds, or other financial instruments. That approach would get the immediate attention of the developer and require a front-end awareness of the potential for groundwater contamination and responsibility for remediation if damage is caused.

54. These questions and statements are futile. The “unless . . ." must be removed. The IWMP makes a recommendation, clarify what "near” means. The Industry itself can reject the recommendation if it feels the risk is nil. But they cannot! The industry and every professional engineer involved with it will say that it is not an exact science and there is some risk. You basically give the free reign to do what is cheapest and easiest for them. May as well not mention it; they will laugh at this. It makes the RDRWA, look really stupid. I assume that you will specify "higher risk.” If I were a company and reviewed the recommendations, there would be absolutely no clarity that my practices would be detrimental or low-impact to the watershed. You could add that RDRWA recommends that industry (oil and gas, forestry, industrial) will be self-regulating with the advice of RDRWA. (another “unless” - 4.16.5.4 bullet 2)

55. Section 4.15.5.3 I do not feel though that fracking should take place near existing or abandoned wells as the risk to groundwater is too high. And the impact to groundwater if fracking goes ahead won't be known until the aquifer is actually contaminated and therefore ruined.

56. Section 4.16.5.4 Development of aggregate in sensitive areas should be prohibited. It is historically and painfully obvious that there is no "mitigation" possible in flood plains when the erodible topography is permanently lowered and the end ponds are blinded off. Both mining-induced and natural riverbed migrations have disastrous impacts that follow the aggregate producer in the long term. Suggest that the phrase "unless they can be demonstrated that any mitigation employed will be successful and permanent" be totally removed, as these phrases are obviously industry-driven weasel words. It is utterly ludicrous to suggest that permanently lowering flood plain terrain, removing land cover and leaving end pit scar ponds could be mitigated in the short or long term. Hyporheic linkage will be destroyed. End pit ponds capture and hold contaminated waters and salts. Ensure evaporative losses and cost taxpayers millions when rivers assume them over and over. The impacts of gravel mining need to be spelled out and "mitigation" is a weasel word that leaves out proponent long-term responsibility and turns an absolute into a discretionary debate.

57. Section 4.16.5.4 The recommendations on aggregate have to be very much strengthened. "No Development" in flood plains must be defined to include any activity that lowers or reshapes the landscape, removes riparian or land cover and alluvial aquifer (gravel) and hyporheic connectivity because those described activities are counter to long-term, safe, secure, sustainable drinking water supplies and should be the intention of the IWMP.

58. Working well program should be extended to more jurisdictions.

59. Groundwater levels for municipalities need to have metrics included in the IWMP for those communities that rely on it for their water supply; future councils need this information to produce effective development plans.

Additional

60. It would be helpful to spell out terms where acronyms are used the first time in the report for the executive summary (e.g., POE). Define "unregulated" flows/tributaries either in the glossary or text of the report.

61. As we discussed briefly at the RD workshop, involving the municipalities and other decision makers in the reality of restricting activities with negative impacts would be a useful exercise. Specifically, with the recommended Goals and Outcomes as the rules of the game, I would like to see war-game opportunity to test the feasibility of applying more limitations and regulations on the regional economy. I also note that you have produced a substantial body of work with no (i.e., zero) reference to real world economics. As some point, that is where the competition will take place. Just as one example, will marginal use of Red Deer water for irrigation make economic sense in the future if there is a supply limit?

62. It should be a priority to determine whether the groundwater is surface recharge or not, (or what per cent of both), with usage based on this. Permission for development that includes groundwater should be based on the recharge rate, with water supplied from surface sources or development not permitted where only paleowater is available. Usage of surface waters that are drinkable or can easily be made drinkable should be restricted for industrial (well injection, fracking) usage, since often non-drinkable waters could be made available and used.

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