Oki, Bonjour, Good morning Rob Miyashiro

I am writing to you as a resident of Lethbridge, to inform you that I am among those that are concerned regarding the over-allocation of water in the South Saskatchewan River Basin and the recent amendments by the government of Alberta to the Water Act.

The South Saskatchewan River Basin is a closed basin and the ecosystem can be described as stressed. Sometimes in the summer, the river flows in southern Alberta are less than the minimum flow objectives that are limits for aquatic ecosystem health that could otherwise sustain fish, aquatic biodiversity, cottonwood forests, riparian ecosystems, recreation, tourism, and the dilution of stormwater and wastewater.

I want to echo the Southern Alberta Group for the Environment (SAGE) that expressed concerns regarding the proposed expansion of inter-basin water transfers and the increased discretion granted to the Minister under Bill 7:

Alberta Environmental Policy Series: Water – Southern Alberta Group for the Environment (SAGE)

The current scientific evidence can support the conclusion that there will be deleterious impacts to the donor and recipient river ecosystems: altered water chemistry, habitat disruption, the spread of invasive species, and the spread of diseases.

I am concerned that combining river basins and broadening ministerial authority is happening at the same time that environmental assessment requirements, watershed-level planning, opportunities for public consultation, and legislative oversight are being diminished. In my opinion, the decisions that affect rivers – upon which we all depend – should be made only after genuine consultation with Indigenous communities, and such decisions should be transparent to the public and informed by scientific expertise.

The removal of the 10% holdback on most water licence transfers is unhelpful in the context of prolonged drought and climate change. Holdbacks can contribute to the incremental restoration of instream flows in over-allocated basins. By deciding to eliminate them, the government of Alberta appears to prioritize short-term profit over the long-term endurance of river ecosystems.

The expanded transferability and flexibility of water licences increases my uncertainty. I suppose that irrigated acreage will expand and excessive industrial water use will increase, at a time when we reasonably expect the volume of river water to be depleted. Reduced return flows from irrigation will impact habitats in rivers, wetlands, and riparian areas.

In my opinion, the law should ensure instream flows that meet the needs of river life and indigenous grasslands. This baseline level of instream flow should be observed with some degree of certainty before any water allocations or transfers are permitted in closed basins. Water licences should continue to be defined as rights of use, not property rights, and aquatic ecosystem health should be prioritized (over profits or property) in water management decisions.

I urge you to advocate for:

• law to guarantee instream flows that can sustain river and riparian health;
• scientific water management and the quantification of cumulative effects;
• genuine consultation with Indigenous communities regarding water policies;
• the retention of water transfer holdbacks;
• the protection of indigenous grasslands and the watersheds of the Eastern Slopes of the Rocky Mountains;
• planning for water-related disasters and emergency preparedness
• and the prioritization of long-term ecological health over short-term exploitation of water as a resource.

The communities and ecosystems of Southern Alberta depend on healthy rivers. The river systems here are already degraded, but we should invest in the scientific restoration and management of them. Albertans must manage water responsibly, to be prepared for climate change-supercharged weather disasters and drought.

Please use your position to take action to protect the long-term health of river systems in Alberta.