From: Janet & Charles [
May 29, 2016
Springbank Off-Stream Reservoir Project Canadian Environmental Assessment Agency Canada Place 9700 Jasper Avenue, Suite 1145 Edmonton, AB T5J 4C3
Subject: Project #80123 – Springbank Off-Stream Reservoir Project
I am writing to express my support for a full federal environmental assessment of the proposed Springbank Off-Stream Reservoir Project (SR1).
As a resident of Rocky View County who lives south and slightly east of the proposed SR1 project, I believe I will be both directly and indirectly affected by this project. I also believe that there are a number of significant environmental issues that should be addressed in a federal environmental assessment, only some of which have been even partially addressed by the Alberta government’s analysis of this project to date.
If the SR1 project is built it will result in the permanent loss of over 6800 acres of heritage agricultural land that has been productively used for cattle grazing and hay and grain production since the late 1800s. During all of that time economically important agricultural activities have happily co-existed with significant wildlife populations.
Unlike the alternative flood mitigation project at MacLean Creek where existing recreational uses could continue relatively unchanged in non-flood years, the SR1 project will permanently alter the landscape and remove its land from both productive human and wildlife activities. SR1 will produce a vast open pit wasteland in the midst of some of Alberta’s most scenic and environmentally important prairie grasslands.
There are many other environmental issues that clearly justify a federal environmental assessment. I will touch upon only a few of these in my letter.
I would caution the CEAA to view with skepticism the Alberta government’s assurances of an absence of environmental impact from the changes to Highway 22 that are an essential component of the SR1 project. The Project Description submitted by the Alberta government asserts that elevating Highway 22 will have no adverse impacts because it will occur within the already disturbed road allowance. While this may or may not be true for its impact on native plant life, it is unquestionably false with respect to wildlife. There are significant wildlife corridors that cross Highway 22 between the Elbow River and the Trans-Canada Highway – the section of Highway 22 that will be elevated as part of the SR1 project. Raising the roadway will undoubtedly disrupt these important wildlife corridors.
The proposed area for the SR1 project is underlaid by at least two or three major pipelines. None of the material presented to date by the Alberta government provides any information or costing on how these pipelines will be safely dealt with if the SR1 project goes ahead. It seems reasonable to assume that the pipelines would have to be relocated – they will not have been designed to bear the weight of the volume of water anticipated to be held by the SR1 reservoir when in use. However, Alberta’s costing for the SR1 project does not appear to recognize this or the potential environmental impact of any necessary relocation.
As someone who lives downwind from the SR1 project, I am particularly concerned about the environmental and health implications of the massive silt residues that will be left behind in the SR1 reservoir after a flood. The Project Description submitted by the Alberta government makes only passing reference to this issue. It provides no information on how it would deal with them. This leaves me extremely concerned that the intent is to simply ignore the environmental and health impacts of these residues. After a flood, the residues left behind would dry and blow across the landscape, smothering plant life as they resettled and irritating residents’ breathing by dramatically increasing particulate matter in the air. This would continue for a significant period of time until all the silt build-up had dispersed. This would be damaging enough if it were only true river silt. However, there will almost certainly be pathogens swept into the flood waters that will be mixed with the copious quantities of silt.
As I indicated at the start of my letter, I have included only a few examples of the potential environmental impacts related to the SR1 project. I believe that these, plus the many other environmental issues that I have not highlighted, clearly warrant a federal environmental assessment of this project. Any massive relocation of a major river bed, even if only on a sporadic and temporary basis has dramatic environmental impacts. The SR1 project is being pushed ahead far too quickly, without any evidence of a thorough and consistent analysis or costing of it and its alternatives. A federal environmental assessment would at least ensure that the potential and serious environmental impacts from the SR1 project will be carefully identified and evaluated.
I sincerely hope that the CEAA will conclude that it should undertake an assessment of this project. It badly needs an impartial review.
Yours sincerely,
Janet Ballantyne
Copies sent to: The Right Honourable Justin Trudeau, Prime Minister of Canada The Honourable Catherine McKenna, Minister of Environment and Climate Change The Honourable Ralph Goodale, Minister of Public Safety and Emergency Preparedness The Honourable Jim Carr, Minister of Natural Resources The Honourable Lawrence MacAulay, Minister of Agriculture and Agri-Food The Honourable Amarjeet Sohi, Minister of Infrastructure and Communities The Honourable Carolyn Bennett, Minister of Indigenous and Northern Affairs John Barlow, MP Foothills Rachel Notley, Premier of Alberta Shannon Phillips, Alberta Minister of Environment and Parks Brian Mason, Alberta Minister of Transportation & Infrastructure Oneil Carlier, Alberta Minister of Agriculture & Forestry Cam Westhead, MLA Banff Cochrane Leela Sharon Aheer, MLA Chestermere Rocky View Chief Roy Whitney-Onespot, Tsuu T’ina Nation Rocky View Councillors