June 22, 2017
Clearwater County Attn: Eleanor Pengelly Development Officer 4340 – 47th Avenue Box 550 Rocky Mountain House, AB T4T 1A4
RE: Proposed Leavitt Gravel Pit (NW13 – 37 – 6 – W5)
Dear Ms. Pengelly,
Trout Unlimited Canada is a national conservation charity that is science-based and volunteer-driven. Partners and volunteers are paramount to the numerous successful river restoration projects we implement every year. Our work protects and enhances water quality, water flow, and aquatic community health. TUC is proud of the critical role our organization has played in the protection of Canada’s natural resources for over 40 years and the value of this work to the lives of Canadians.
We recently became aware of the above referenced Proposed Development within Clearwater County by Border Paving Ltd. to develop and operate a wet/dry gravel pit and associated activities including end pit lakes, near the headwaters of the North Raven River (Stauffer Creek).
The North Raven River is known as one of the most stable and valuable spring-fed trout fisheries in central Alberta. It is estimated that approximately 2,500 anglers visit the region every year. This brings revenue to local communities in gear purchases, fuel, lodging and other tourism-related dollars which depends on this healthy river and its sustained, constant and cold groundwater flows. It is ultimately a highly sustainable, renewable resource that will continue to provide social and economic benefits as long as it is maintained.
Trout Unlimited Canada, along with Alberta Conservation Association and Alberta Fish and Game Association are co-owners of the nearby Stainbrook Springs Conservation Site (SW19-37-05-W5) and the Leavitt Conservation Site (NW17-37-5-W5). Stainbrook Springs and Leavitt, located along the North Raven River, were purchased and are managed to protect the numerous headwater springs which are vital for maintaining the stable, coldwater flows into the North Raven River that support this fishery. Our organization, members, partners, and supporters have invested millions of dollars and countless hours of volunteer time and effort to restore and protect this fishery and this is widely considered an impressive success story in terms of stream restoration and sportfishery improvement.
We are concerned about potential impacts from gravel extraction on the groundwater resources that feed the North Raven River. In their application package, Border Paving’s drainage map shows surface water flows off the property towards the northeast; groundwater very likely flows in the same direction. Excavations below the water table in such close proximity to the headwater springs could seriously impair the health of the system by negatively affecting the water quality and flow. The potential impacts
Trout Unlimited Canada
(403) 221-8360 1 (800) 909-6040 180-2880 Glenmore Trail SE, Calgary AB, T2C 2E7
from the proposed gravel pit would be absolutely counter to the gains made by years of dedicated conservation and restoration efforts.
An additional groundwater study should be completed by Border Paving before a development permit is considered. A hydrogeological study should show the volume, temperature, and direction of groundwater in relation to the North Raven River.
Additionally, the location of the proposed pit between the Clearwater River and North Raven River, and proximity to the Clearwater River could increase the risk of a flood event resulting in an inter-basin transfer from the North Saskatchewan River basin to the Red Deer River basin through the North Raven River. This has been identified as a concern in the past, particularly following flooding in 2005 and 2007.
Please feel free to contact us if you require further information including scientific papers on the impacts of aggregate extraction below the water table. We look forward to your response on this issue.
Sincerely,
Lesley Peterson, B.Sc., P.Biol. Provincial Biologist, Trout Unlimited Canada
CC:
Clearwater County Staff: Marshall Morton - Director, Public Works
Clearwater County Council: Reeve: Honourable Mr. Patrick Alexander Councillor Mr. Jim Duncan Councillor Mr. Kyle Greenwood Councillor Mr. Curt Maki Councillor Mr. John Vandermeer Councillor Ms. Teresa Laing Councillor Mr. Earl Graham
Alberta Conservation Association – Mr. Todd Zimmerling, President and CEO
Alberta Fish and Game Association – Mr. Martin Sharren, Executive Vice President
Alberta Environment and Parks – Terrina Perley
Trout Unlimited Canada
(403) 221-8360 1 (800) 909-6040 180-2880 Glenmore Trail SE, Calgary AB, T2C 2E7