In June, the Canadian Environmental Assessment Agency (CEAA) submitted a 16 question information request (IR) to Alberta Transportation requesting more information relating to the Springbank Off-Stream Reservoir Project (SR1) Environmental Impact Statement (EIS).

Since then, two more IR packages have been submitted to Alberta Transportation, Part 2 on August 20 and Part 3 on August 31, which together with the first IR total 86 questions.

The questions are quite detailed and address a range of project concerns including climate change considerations, impact on wildlife, vegetation and soil, and water quality.

Notably, throughout each IR package, the questions emphasize the requirement to evaluate any and all effects on the physical and cultural heritage of Indigenous peoples including cultural experience, traditional use of land and resources, and impacts to Aboriginal and treaty rights. Some questions highlight areas where additional community knowledge and Aboriginal traditional knowledge is needed for a complete and accurate assessment.

There is a lot to read through, so we’ve summarized the questions from each IR package below.

A few questions that stood out covered the topic of Alternate Means, as the EIS Guidelines require the proponent to “identify and consider the effects of alternative means of carrying out the project”. For example:

• Given any Project updates, provide information on the comparison of MC1 and the Project, including costs/benefits.

• Describe how changes to the environment from the MC1 option would affect Indigenous health and socio-economic conditions, physical and cultural heritage, the current use of lands and resources for traditional purposes, or any structure, site or thing that is of historical, archaeological, paleontological or architectural significance.

• Evaluate whether the Tri-River Joint Reservoir of Alberta and the Micro-Watershed Impounding Concept are feasible alternative means of meeting the Project’s purpose. Consider potential environmental effects of each alternative in this evaluation.

SR1’s opponents have said, and may again say, that questions of this nature are themselves evidence that SR1 is a flawed project. This is not true. Questions of this nature through the regulatory process are expected as part of the project, as frustrating as they may be to getting on with the work that’s required to save lives, livelihoods and property. 

As we’ve said before, we understand that the MacLean Creek project (MC1) would pose many more regulatory challenges and invite many more opponents than SR1. Given the detail and depth of the Springbank Project EIS (+3300 pages) and subsequent information requests, one can only imagine the scrutiny a technically less-effective, on-stream reservoir, on wildlife-rich and publically used crown land, would undergo.

While we look forward to seeing Alberta Transportation’s answers to these above three questions, it remains clear that the Springbank Project is the right choice (and the only choice) if we want to see our city protected within the next decade. This in-flight project is far too important to delay or cancel, with far too much taxpayer money invested already. Based on all the work done to date, it is the best first option available to Calgary and southern Alberta.

The regulatory clock remains stopped at 110 of 365 days. It is anticipated that a response to all questions should be submitted by mid-December, which will then restart the clock. 

You can access full versions of Part 1 (25 pages), Part 2 (40 pages), and Part 3 (87 pages) of the Information Requests Related to the Environmental Impact Statement Round 1 on the CEAA’s website here under ‘latest update’.

A summary of the 23 questions contained in Part 2:

 
• analysis, discussion, and conclusions on whether the Project will have a low, medium, or high level of impact on the exercise of rights for each Indigenous group
• description of cultural experience/experiential values identified by each Indigenous group and potential changes to the environment that interact with these values
• describe how existing land use plans (e.g. South Saskatchewan Regional Plan (SSRP)), guidelines or policies were integrated into the planning of the Project and were used to contribute to the understanding of land use management and planning in relation to traditional use
• describe the economic opportunities associated with the Project that may be of interest to Indigenous groups and any commitments to facilitating these opportunities
• additional assessment of the effects to federal lands, taking into account the entirety of each reserve area identified rather than sample portions
• demonstrate how Indigenous knowledge, including cultural values, cultural transmission, and intergenerational knowledge transfer, was considered in the selection of Valued Components (VC) and in establishing spatial and temporal boundaries
• updated assessment of effects to traditional land and resources including distribution of resources, relative importance, and access to and preference for use
• additional information on the availability of and access to country foods, and the role of country foods from a holistic health perspective (physical, mental, spiritual)
• clarity and rationale for the proposed land classifications (A, B, C, D) and details on subsequent changes in land availability and use for Indigenous peoples
• additional information and revised assessments of effects on physical and cultural heritage on any structure, site, or thing that is of historical, archaeological, paleontological, or architectural significance
• list the species identified by Indigenous groups as species of importance and demonstrate a robust understanding of potential effects to each of these species
• additional detail on the four-class wildlife habitat rating scheme and habitat sustainability models
• rationale for survey timing for western toad and yellow rail
• additional detail on areas of uncertainty regarding wildlife movement
• detailed schedule for restricted access periods and construction timing, as related to seasonal and regulatory parameters for species of concern
• clarify whether or not proposed access roads overlap with the key wildlife and biodiversity zones, specifically ungulate (elk) winter range
• address the limitations in the data used to predict baseline conditions and pathways of effects to grizzly bears
• explanation of plant survey methods and level of engagement of Indigenous groups in survey design
• describe the potential for vegetation and wetland fragmentation to result from filling and draining of the reservoir and sediment clean up
• provide evidence to support claims of natural reestablishment of vegetation, as well as additional information on revegetation plans, integrated forest management plans, and invasive species mitigation measures
• additional assessment of how changes to terrain and soil conditions might impact Indigenous land use
• describe current Indigenous navigation practices on the Elbow River and how project components and project phases may affect those navigation practices

A summary of the 47 questions contained in Part 3:

• clarity is required to understand whether change in climate, climate uncertainty, and the magnitude of effects in the context of climate change were considered
• analyse one additional Probable Maximum Precipitation (PMP) scenario
• rationale for the selection of the design flood level
• list and provide rationale for the criteria used to determine the Local Assessment Area (LAA) and Regional Assessment Area) for hydrology study
• rationale for the capacity of the emergency spillway
• rationale for the freeboard (distance between the maximum water level and top of the dam) in the reservoir considering the potential for waves due to strong winds
• additional details on the sediment transport model
• describe project interactions with and effects on an unnamed tributary including potential effects to VCs
• clarify at what flow volumes and what flood frequency the Project will be in operation
• assess the environmental effects of a reduced frequency of inundation of the Elbow River downstream (relating to river bed movement)
• additional information on sediment deposition and potential effects to fish and fish habitat
• additional information on water retention time for each flood scenario
• additional information is required on potential in-stream maintenance activities and potential effects to VCs
• discuss how bedload sediment accumulation in front of the overflow gates would affect river morphology
• additional information on impact to groundwater quality during construction and dry operations
• additional groundwater monitoring wells are required in specified locations, as well as detailed information on location, depths, and planned use of all groundwater monitoring wells
• extend the RAA’s southern boundary within the hydrogeological model to a location where the groundwater boundary conditions can be more reliably estimated and update relevant sections of the EIS to account for the new southern boundary
• additional details and rationale on time-variant boundary conditions for groundwater monitoring
• identify groundwater dependent traditional uses and culturally sensitive areas and describe potential pathways of effects and mitigation measures
• describe potential changes to ice regime as a result of the Project (potential for Project components to affect ice jamming)
• additional information is required regarding nutrient detection limits and potential eutrophication and toxin production (e.g. cyanobacterial blooms or microcystin toxin) to understand potential changes to water quality
• provide evidence that Total Suspended Sediment (TSS) is an appropriate surrogate for other water quality parameters
• assess effects related to herbicides applied to control vegetation during Project operations
• provide an assessment of the effects of noise and vibration to fish and fish habitat during construction
• provide a detailed breakdown of areas to be affected by the Project (temporary and permanent) that would cause the alteration or destruction of fish habitat
• provide a map of fish habitat that is consistent with the definition of fish habitat provided in the requirements in the EIS Guidelines
• revised assessment of effects to fish and fish habitat from changes in temperature and dissolved oxygen
• assess potential effects to spawning within the low level outlet channel
• assess potential effects to fish trapped in the reservoir, specifically sensitive salmonid species, due to changes in water quality and threats of predation
• evidence of the historic and current presence of westslope cutthroat trout (pure and hybrid) within the PDA
• additional information on the cumulative effects assessment for effects to fish and fish habitat
• provide additional risk estimates for chromium emissions including risk of airborne exposure during construction
• identify the country foods harvested from the Elbow River and for each describe their susceptibility to the uptake and biomagnification of methylmercury
• update assessment of effects of noise from the Project including blasting noise
• additional information is required to understand project changes to air quality, relative to applicable standards, and subsequent effects
• documentation that confirms that there would be enough snow cover in the Project area from November to February to achieve 90% dust control
• information on mitigation, monitoring and follow-up plan for Volatile Organic Compounds (VOC) and dustfall for all phases and components of the Project
• detail how air quality effects from interactions with the developments (Community of Harmony and Bingham Crossing) in the region will be determined, managed, and mitigated
• provide an updated assessment of health risk for each Chemical of Potential Concern (COPC) for each phase of the Project prior to the implementation of mitigation measures that are not design features
• describe all potential light sources throughout the Project area during flood and post flood operations, anticipated light levels, times and duration of use (e.g. 24 hour) and assess potential effects to each relevant VC resulting from the anticipated change in ambient light
• update the cumulative effects assessment for air quality to include predicted COPC contributions from potentially overlapping projects/activities in the area for the reasonably foreseeable future
• update the Surface Water Quality and Aquatic Ecology cumulative effects assessment to include past and present projects or physical activities
• update the Hydrology and Aquatic Ecology cumulative effects assessments to include the Bragg Creek Flood Mitigation Project and the Southwest Calgary Ring Road Project
• describe how potential and reasonably foreseeable flood mitigation measures contemplated for Tsuut’ina Nation reserve lands (local mitigation) were considered in the cumulative effects assessment
• clarify if potential benefits in terms of reduced flood risk are expected for Siksika Nation
• define and identify disturbed areas within the Local Assessment Area (LAA) and explain how existing disturbance will be used in Project design
• for each accident and malfunction scenario, provide the criteria and associated rating used to determine the significance of residual environmental effects for each VC
• details of a communications plan that includes means and procedures for communicating Project construction, maintenance, and operation activities to the public and Indigenous groups

Thank you for your time and attention to this latest news. We will keep you in the loop with any additional information that we receive. 

Regards,

Your CRCAG Board