Surface Water Quantity and Groundwater Resources


Public and


of Terms


In April 2013, the Watershed Alliance engaged O2 Planning + Design, working in cooperation with Integrated Sustainability Consultants and LimnoLogic Solutions to develop the third Background Technical Report on Surface Water Quantity and Groundwater Resources.

The final report is now available for download.

Download the FINAL report (11 MB PDF)

Download the maps (15 MB PDF)

A Technical Team was assembled for the third report, which consisted of some members of the IWMP Technical Advisory Committee supplemented by additional team members with expertise in relevant areas. Technical experts come from government, industry, conservation, consulting and academia. The Technical Team provided advice to O2 Planning + Design during the development of the report.

During September and October, 2013, a public and stakeholder consultation process was held including two workshops — one in Red Deer and one in Drumheller. There was also an online Response Form. For more information on the consultation process please visit the Public and Stakeholder Consultation page.

During the public and stakeholder consultation process, overall response to the report was very positive.

A number of important technical comments were put forward at workshops and in the online Response Form. O2 Planning + Design, authors of the report, members of the Technical Advisory Committee and Technical Teams, and the IWMP Project Management Unit reviewed the comments and provided advice to O2 on whether they should be considered for inclusion in the report or not. A total of 32 comments were assessed and the rationales for including or not including them in the report are summarized below. You can download the "Table of Comments" (PDF) here.


Rationale for accepting or not accepting in report

  1. Section 2.1.1 Table 1 - examples from this table could be condensed or the entire table could be removed

Accepted. Table removed

  1. Section 2.1.1, 2.1.2 - AESRD refers to environmental indicators as condition and pressure indicators, and programmatic and social Indicators are referred to as response indicators

A footnote was added to make this reference. The indicator labels are the same as what were used in the previous Background Technical Report.

  1. Add blue and green water and POE to glossary


Surface Water Quantity

  1. 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.

Accepted. Section was rewritten.

  1. 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.

The report talks about the need to account for return flows in licensing system decisions but not about revising “first in time, first in right.” In the Government of Alberta’s recent public consultation called “Water Conversations,” it was stated that there were no plans to change the water allocation system. However, a review of the system is currently being conducted.

  1. Seven or 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.

The water level and flow data do not seem to support this idea. There is considerable confusion around the role of the Dickson dam on the Red Deer River and the report recommends more education in this area.

  1. 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; Goal 3 is an outcome not a goal; 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"

Accepted. Many of the goals and outcomes in this table were rewritten and reworked.

  1. There has been no groundwater mapping and groundwater resources are unknown at best and should not be a convenient excuse to keep draining the water basins.

Not accepted. While some shortcomings are recognized in the recommendations of the report, there has been considerable work on groundwater in the watershed.

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


  1. 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.

Accepted. This outcome needs to be taken in the context of the previous outcome. Some rewording was done here.

  1. 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.


  1. 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.

Accepted. Recommendations with respect to the need for public education were added to the report.

  1. Section 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.

Accepted. Wordings were changed so that it is absolutely clear that the determination of flood-prone areas would be based on best (most up-to-date) available data.

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

Accepted. New text was added so it was clear that many recommendations are already being implemented although it goes beyond the scope of this report to document all examples of implementation. In addition, at the start of the BMP sections, it now states, “BMPs in this section are already covered in greater detail in many of the regulations and operating practices that agriculture, oil and gas, forestry, and other industries are required to follow.”

  1. 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).

Not accepted. It will be the role of the Integrated Watershed Management Plan (IWMP) to do this prioritization.

  1. 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.

There will likely be such a committee during the development and implementation of the IWMP.

Groundwater Resources

  1. 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.

Accepted. Section was rewritten and reduced in length.

  1. 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. One cannot talk about inter-annual variability of climate.

Accepted. Section was reworded.

  1. Section 4.13. Hydraulic fracking should be an issue.

Accepted. It was already an issue in bullet 2.

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

Accepted. It was already covered as an issue in bullet 4, but some rewording was done to make it clearer.

  1. 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.

This issue is already covered in Section 4.13.

  1. 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 . . .” Outcome #4 - what does this mean? Who's providing the assistance? 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

Accepted. This section was reworded in a number of places.

  1. 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:
  • Number 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)
  • Number of rural municipalities that have programs and policies in place to support proper well abandonment

Accepted. Both suggested indicators were added to the table of indicators and targets.

  1. 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.

Not accepted. The planning process must proceed with the data available. Over time, with the addition of new information, changes can be made to the targets.

  1. 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.

The report already has a number of recommendations to gain a better understanding of hydraulic fracturing. The previous two background reports also made similar recommendations. Hydraulic fracturing is likely both a research and a communications issue.

  1. Section 4.16.5. 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” - bullet 2)

Accepted. Most of these statements were reworded.

  1. Section 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.

Not accepted. The statement was reworded for clarity but recommends that fracking could proceed with proper risk assessment.

  1. Section Development of aggregate in sensitive areas should be prohibited.

Accepted. Statement was reworded.

  1. Section The recommendations on aggregate have to be very much strengthened.

Accepted. A number of statements were reworded to be clearer and stronger.

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

Not accepted. The Working Well program is already available in all jurisdictions throughout the watershed. A recommendation was added to better promote the program.

  1. 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?

Not accepted. This sort of analysis would be better suited to when the final integrated watershed management plan is developed.

  1. Upon reviewing the BMPs directed towards industry, it seems there may be a role that this report or the WPAC can play in providing awareness of the regulations/operating practices that industry is mandated to follow. Though we are supportive of the direction of the BMPs you have stated, there is some concern that when the report is read by the public the recommendations will be perceived as areas that aren’t currently regulated or do not have associated operating practices already in place. It would be beneficial to frame the discussion in the report around recommended BMPs (currently in the report) and current regulations/operating practices that are already in place that support your recommendations. Below are some examples of current industry practices/regulations that directly support the BMPs you have recommended.

Accepted. At the beginning of the surface water quantity BMPs and at the beginning of the groundwater BMPs, we have added a box with the following: “Many of the recommended BMPs in this section are already covered in greater detail in the regulations and operating practices that agriculture, oil and gas, forestry, and other industries are required to follow.”



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