02 July 2025: Sent to the Environment and Protected Areas and Natural Resources Conservation Board
I understand the application for the Snake Lake Reservoir Expansion Project is being reviewed for completeness by both Environment and Protected Areas and Natural Resources Conservation Board. The joint April 14, 2025 Notice of Filing included posting of the EIA Report (31+ documents) on the EPA Current Projects webpage and the NRCB webpage for the project. I have reviewed these documents and have a few comments and questions about the completeness of the Project Description and Environmental Impact Assessment.
Project Purpose – Why is expansion of irrigated acres no longer considered an intent of the project?
Stated purpose of the project in application documents is to fully support 20,000 ha of existing irrigation during May to Aug through Snake Lake Reservoir storage rather than directly from Bassano Reservoir in order to increase resiliency to drought from predicted effects of climate change. However there is evidence that expansion of irrigation may also be the project intent. Elsewhere in the EIA there is a statement that EID is conducting soil testing for irrigation capability on EID-owned land and that the project will provide “indirect benefits” and “direct-from river water will be used elsewhere in EID. The Snake Lake Reservoir Project is part of a major irrigation expansion program announced in fall 2020 by GoA, Canada Infrastructure Bank and Irrigating Alberta Inc.. In an EID public meeting on February 10, 2021 held prior to a plebiscite on increasing EID’s expansion limit by 34,000 acres, five thousand new irrigated acres (2,025 ha) were specifically linked to expansion of Snake Lake Reservoir. At that meeting it was proposed that Capital Assets Charges on new irrigation acres would be used to pay the District’s share of an expanded Snake Lake Reservoir. An explanation of EID’s expansion plans and the part Snake Lake Reservoir plays in these is needed to provide complete rationale for the project.
Impact on Bow River flows and aquatic ecosystem – Assessment of impacts of the project on the Bow River is incomplete.
The EIA states“As there is an existing licence for water use that is not being revised or renewed for this Project, there will not be any new effects downstream of the Project on the Bow River.” Water to fill Snake Lake Reservoir will be diverted during higher spring flows and direct-from-river water will be used elsewhere in the EID as long as the ‘target’ IO of 11.3 m3/s is achieved downstream of Bassano Dam. There is not analysis of effects of the diversion on peak flow or frequency of minimum releases from Bassano Dam downstream. There is not acknowledgement of the degraded condition of the Bow River (and South Saskatchewan River) downstream of Bassano Dam or of Instream Flow Needs and Water Conservation Objectives determined as part of the Approved Water Management Plan for the South Saskatchewan River Basin (2006). Opportunities to improve achievement of WCO are not addressed.
Impact on Return Flows to the Red Deer River – Assessment of impacts on water quantity and quality downstream of the Project and effects on return flow to the Red Deer River is incomplete.
The EIA states the Project will not result in changes to quantity or quality of return flow to the Red Deer River because irrigated area and rate of irrigation use per acre downstream of Snake Lake Reservoir will not change. Total return flow to the Red Deer River from EID averages 101.6 million m3 or 20% of total diversion which is high compared to return flows for other irrigation districts in southern Alberta (~11%). An explanation for this high level of return flow is needed as well as any plans EID may have for improving efficiency by reducing return flow. The EIA acknowledges that there are exceedances of E. coli, total suspended solids, sulphate, total dissolved solids, total phosphorus, manganese, cadmium, various herbicides and pesticides in return flow downstream of Snake Lake Reservoir. Impacts, current and potential, of return flow on downstream users, including the proposed MD Acadia and Special Areas Irrigation Project, are not assessed nor are opportunities the Snake Lake Reservoir Expansion Project may provide for mitigating downstream impacts.
Impacts of Phase 1 of the Project, Excavation and Shipping of rock and gravel, are not fully assessed – Why are impacts of excavating 1 million tonnes of sand, gravel and riprap considered out of scope for the EIA?
Rock is proposed to be excavated from a quarry in the Little Bow River valley 105 km south near Turin (exact location not provided) and sand and gravel from EID’s Eyremore Quarry along the Bow River 28 km south of Snake Lake Reservoir. Assessment of impacts on the extraction sites are lacking, however GHG emissions (93,485 tonnes of CO2 equivalent per year over five years) are estimated for extraction and shipping. Explain the rationale behind the assertion that these large volumes of GHG emissions contributing to climate change are mitigated by improving water reliability for irrigators in the EID downstream of Snake Lake Reservoir.
Benefit/Cost Analysis – How can NRCB make an informed public interest decision without an economic analysis?
The project is considered by EID to be a “confidential matter” since the Project is “essentially privately financed” with 70% of financing ultimately provided by EID. However a grant from Government of Alberta covers 30% of the cost and taxpayers’ money comprises the low-interest loan from Canada Infrastructure Bank for 50% of the Project.
Thank you for consideration of these questions and comments. I look forward to a response on how these will be addressed in the Project review process.