SAGE is a leading voice for a healthy and environmentally sustainable community.

Oki.  We respectfully acknowledge that SAGE meets on the traditional lands of Piikani, Kainai & Siksika, members of Siksikaitsitapi (Blackfoot Confederacy) and the homelands of Métis Nation of Alberta, Region III.  We are grateful for their keeping of these lands and waters - past, present & future.

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26 June 2024

City of Lethbridge, Climate Adaptation Strategy and Action Plan

To:       Governance Standing Policy Committee

The Southern Alberta Group for the Environment (SAGE) has appreciated the opportunity to participate in the City of Lethbridge’s Climate Adaptation Strategy and Action Plan.

The Municipal Development Plan acknowledges that “Climate change is expected to be the most significant environmental issue in the coming years. In addition to creating challenges for ecosystem adaptation, a warming climate will bring changes that can affect the water supply, agriculture, power and transportation systems, the natural environment, cultural and heritage sites, and human health and safety. … Mitigating, responding to, and adapting to the impacts of climate change, including constraints on water and increased severe weather, will become increasingly important” (p.184).

This is an important direction for policy-makers in our collective efforts to prepare Lethbridge for the impacts of climate change on how we live, work and recreate. For success, a robust adaptation plan is vital – the health of the natural environment, the effectiveness of our economy, and social cohesion are all in play.

The multi-stakeholder planning process was very well organized and presented, with a comprehensive evaluation of climate impacts on labour productivity, building performance, public health, and infrastructure damage from extreme weather events. The most important outcome from these analyses is that there is a real cost to inaction. In other words, there is tangible return-on-investment for adaptation interventions that protect our community.

Another important perspective is that this is not directly a mitigation plan that relates to various international protocols. It is an adaptation plan that prepares Lethbridge for anticipated impacts, and offers long-term actions to preserve a livable future.

We cannot express strongly enough how important this project is for Lethbridge. Successful implementation of adaptation goals will have profound impacts on our economy and our social well-being. SAGE encourages the Governance Standing Policy Committee to support the Climate Adaptation Strategy and Action Plan.

30 May 2024

Long-term Affordable Housing:
Bill 18 Provincial Priorities Act, Bill 20 Municipal Affairs Statutes Amendment Act

Dear Hon. Ric McIver, Minister for Municipal Affairs,

The Guardian (9 May 2024) asked the question: ‘What are the most powerful climate actions you can take?’ From the leading experts queried, the fourth top response was to reduce home heating and cooling emissions. SAGE agrees, and would add that this also speaks to affordability.

Infrastructure Canada data indicates that the average expected useful life of a single detached home in Alberta is 65 years. The data collected was based on social and affordable housing assets in both urban and rural settings. This means that a home built today is expected to still be part of the building stock in 2090. We know that, between now and 2090, there are expectations that greenhouse gas emissions be reduced to net-zero. We have to ask ourselves: Are we building homes today for yesterday’s climate? And is this affordable in the long term?

It appears, in the absence of robust public discussion, that the Provincial Priorities Act (Bill 18) is designed to restrict Municipalities and other provincial entities to enter agreements with any other entity without prior approval from the Government of Alberta. One might imagine this approval process could include grants from corporate sponsors or the Government of Canada that are directed to the reduction of greenhouse gas emissions. If, say, climate change mitigation and adaptation were not a priority for the Government of Alberta, much needed funding for municipalities and public research may or may not be allowed. Such gatekeeping of the public good may unintentionally restrict our collective ability to explore and innovate solutions for energy transition, building performance and, ultimately, long-term affordable housing.

Similarly, the proposed Municipal Affairs Statutes Amendment Act (Bill 20) limits the ability of municipalities to require “non-statutory studies as requirements for building and development permits.” Again, ‘non-statutory studies’ is a loosely defined category, but could include performance modelling for homes that are expected to meet higher standards as established by a municipality.

One of the motives expressed by the Government of Alberta for components of these Bills was to ‘standardize’ building in the province to make it more ‘affordable’. The standard would be the National Building Code, which (though being updated) currently sets a performance standard that will not only fail to achieve greenhouse emission targets, but also leave the homeowner with an unaffordable liability if energy prices continue to rise.

For the complete letter, click ... here.

May 8, 2024

Dear Minister Schulz, Minister Sigurdson, Minister Loewen and Minister McIver

Re: Managing irrigation expansion to protect native grasslands and associated biodiversity

Recent proposals for over 100,000 hectares (250,000 acres) of irrigation agriculture expansion within the South Saskatchewan River basin have raised several concerns about environmental impacts, including potential loss of native grasslands.

Native grasslands are valued by Albertans as habitat for a broad diversity of plants and animals, including over two dozen species at risk. Southern Albertans benefit greatly from the ecological goods and services native grasslands provide such as water storage, carbon storage, erosion control, pollination and pest control. Native grasslands support ranchers in sustainable livestock production. Conversion of native grassland for expansion of irrigated cropland would compromise these invaluable and irretrievable assets.

In acknowledging the significant value of native grasslands, the approved South Saskatchewan Regional Plan 2014-2024 (Amended 2018) (SSRP) establishes a regional outcome that “Biodiversity and ecosystem function are sustained through shared stewardship”. Regional objectives specify that “Intact grassland habitat is sustained” and “Species at risk are recovered and no new species at risk are designated”.

Reservoir and other infrastructure development would flood native grasslands and/or impact habitat for species at risk at proposed project sites including Chin Coulee, Deadhorse Coulee, Snake Lake and potentially as part of the MD Acadia Special Areas project. Proponents of irrigation expansion assert that, in keeping with the direction established in the SSRP, expansion of irrigated cropland will occur on already cultivated parcels and not lead to conversion of native grasslands. However, legislation and policy governing decisions about expanding irrigation acres fail to support shared stewardship for sustaining native grasslands.

Gaps include the following that are described more fully in ENCLOSURE 1:
- Lack of a regulatory requirement in the SSRP prohibiting conversion of native grasslands to cropland on public land.
- Lack of regulatory and policy mechanisms for municipalities when implementing irrigation expansion projects (e.g. Special Areas, M.D. Acadia) to prevent loss of native grasslands on municipal and private land.
- Lack of land classification standards and land assessment criteria that preclude adding parcels of native grassland (and parcels of other ecological significance) to Irrigation Districts' assessment roles. Furthermore there is a lack of ability for an Irrigation District, under the Irrigation District Act (IDA) when making a decision about an application to add a private parcel to the assessment role, to deny approval on the basis that native grasslands or species at risk will be impacted.

For the complete letter, click ... here

Irrigation—When You’re In a Dry Hole, Don’t Dig Another
Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a former Adjunct Professor with the University of Calgary.

One definition of a consultant is someone who looks at your watch and tells you what time it is. The recently released consultant’s report— Adaptation Roadmap for the SSRB: Assessment of Strategic Water Management Projects to Support Economic Development in the South Saskatchewan River Basin— is a mirror reflecting back the aspirations of the irrigation lobby. In fact, it provides the answer—more dams and reservoirs—instead of dealing with some foundational issues.

When facing down drought that experts say may persist, moving from supply side management of water and dealing with water demand seems prudent. The real question is, when supply diminishes how to adapt to less water.

Adaptation doesn’t happen by building more reservoirs. If this is viable, we may be the first in history to outrun the impacts of a shrinking water supply. No one else has been able to perfect this magic.

Our rivers already have less flow in them and flows are expected to decline. Reservoirs don’t create water, they just store what is available, but waste much in the process. Evaporation losses are almost a metre of water per year from each. That’s water lost to the rivers.

When stuck in an irrigation growth paradigm, it doesn’t register there is a limit to such growth. The proposed result of this “study” is a classic case of “running faster and faster to stay in the same place.” There are already 56 reservoirs in southern Alberta dedicated almost wholly to irrigation. Will building 8 more be the answer? “Yes,” says the irrigation lobby, because it’s the perennial answer.

No matter how much lobbying is done, how many new dams and reservoirs are built, climate change cannot be outrun. Even if we bankrupt the province with all the suggested engineering hubris, to the suggested tune of 5+ billion taxpayer dollars, this adaptation roadmap could lead to a dead end.

Instead of more holes that may or may not be filled with water, a different path is required. Reluctance to deal with water demand creates a wicked problem that the sales pitch in the report fails to address. If you always do what you’ve always done (build more dams and reservoirs), you’ll always get what you’ve always got (increased demand and issues of water supply). It’s a cycle in which effort to solve a given problem results in aggravation of the problem or the creation of a worse one.

Proceeding with the exuberance of dam building, without a better understanding of the variances of climate change, may well create some enormous engineering white elephants. This also ignores where the water comes from. Our future is likely to be more rain but less snow. But it is slow snow melt that keeps our rivers flowing.

Headwater forests capture that snow, retaining some of it in shallow ground water storage for later release. With our expanding land-use footprint, especially logging, we are changing the way water is trapped, stored and released. This exacerbates floods and drought.

Our forested headwaters is the ultimate “reservoir” for water yet it merits no attention in this report. Funding upstream watershed restoration and security would seem to be the first thing to consider, not more dams at the downstream end.

The glib and disingenuous statement that more reservoirs would aid fish through better flows is a whopper of a “fish tale.” This didn’t happen with any past developments and won’t happen with any future ones. There isn’t even enough flow to consistently meet the lowest common denominator, an “administrative” instream objective, which does not protect fish and aquatic life.

This breathless endorsement for more dams and reservoirs isn’t adaptation but a blatant cheerleading proposal for irrigation interests with little in the way of benefits for Albertans, other than a hefty price tag.

With this report, the irrigation lobby confirm their “adaptation roadmap” will mean our rivers are good— to the last drop.

Shifting a dominant culture and narrative of engineering the landscape for irrigation agriculture to a new perspective of learning to do with less water is a tall order. Understanding what level of water use can be sustained while keeping our rivers from death are difficult but not insurmountable challenges.

What is urgently required is an independent, objective analysis by qualified professionals on the broader questions of how to adapt to a climate change future, perhaps the driest of perfect storms, not how to expand  irrigation.

The Zombie-like Nature of the Proposed Grassy Mountain Coal Mine
Lorne Fitch, P.Biol.
Published 05 March 2024 in The Lethbridge Herald

In the recent pronouncement from the minister of Energy that the proposed Grassy Mountain coal mine is still an “advanced project” one might conclude he believes in the living dead. Nothing it seems is ever dead, it just waits in a moribund condition for the kiss of life from a government out of touch with Albertans’ feelings about blowing the tops off mountains in the Eastern Slopes. Apparently this minister required a bit of remedial tutoring to be assured that Grassy Mountain is in the Eastern Slopes.

He may not have read the report from brave scientists in another government department who concluded the old mine and the one on Tent Mountain continue to spew toxic materials at levels that far exceed provincial and federal standards. I suppose that is, in his estimation, a reflection a mine couldn’t really be dead, if it continues to actively and negatively affect downstream water and water drinkers.

On the minister’s reading list should have been the results of the joint federal/provincial panel. The panel heard from dozens of experts who debunked all the Australian company’s claims of minimal impacts, successful mitigation plans (including dealing with selenium and other toxic chemicals), bountiful economic benefits and so on, ad nauseum. That information, the facts and evidence then allowed the panel to conclude this project was not in the public interest. None of the evidence has been successfully contested by the company.

The minister must have also overlooked or slept through the massive outpouring of concern from Albertans over the prospect of turning the Eastern Slopes into a series of black holes at the expense of watershed protection, biodiversity maintenance, recreational and tourism attributes and the very real specter taxpayers would be stuck with the reclamation costs (as is so very evident now with the petroleum sector).

Based on the extreme backlash, the Alberta government convened a “Coal Policy Committee” to advise it on coal issues. The extensive public engagement process found Albertans’ “top of mind” concern was the environmental impacts of coal mines. Two things stand out from the results of the consultation:

“Albertans have concerns about the regulatory process for coal activities.    Albertans are concerned that coal policies can be easily overridden when many thought  that these policies were legally binding.”

With this latest revelation about an about face on the status of Grassy Mountain those concerns still register large. The minister might consider this report required reading.

This situation resembles so closely an anecdote about W. C. Fields, an American comedian. He was an avowed atheist, yet was observed by a friend reading the bible on his deathbed. Asked why, Fields reply was “Looking for loopholes, looking for loopholes.” It would seem there have been an astounding number of loopholes sought yet all that have been through a judicial review have failed. Experts in law and policy point out the project is “legally dead.”

What else could explain the minister’s reluctance to drive a stake through the heart of this coal proposal and put it and Albertans out of our misery?

Lorne Fitch is a Professional Biologist, a retired Fish and Wildlife Biologist and a past Adjunct Professor with the University of Calgary.

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