Friday, August 31st, 2018, Technical Review of the Environmental Impact Statement for the Springbank Off-Stream Reservoir Project – Information Request Package 3
In the month of September, this year, The Canadian Environmental Assessment Agency (CEAA) submitted a request to Alberta Transportation asking to:
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.
Earlier, this year, the office of the Prime Minister recommended submitting this proposed solution to the Province of Alberta in order to determine whether the “Tri-River Joint Reservoir project” should be prioritized for funding consideration under the Investing in Canada Plan.
Here is the letter from Alberta transportation:
Prairie and Northern Region
Suite 1145, 9700 Jasper Avenue
August 31, 2018
Provincial Transportation Environmental Coordinator
3rd Floor Twin Atria Building
4999 98 Avenue
Edmonton, Alberta T6B 2X3
SUBJECT: Technical Review of the Environmental Impact Statement for the
Springbank Off-Stream Reservoir Project – Information Request Package 3
The EIS identified five potential locations for flood mitigation measures on the Elbow River.
Public comments received during technical review of the EIS indicate interest in specific alternative means of reducing effects of future extreme floods on infrastructure, water courses and people, such as the Tri-River Joint reservoir of Alberta and the Micro-Watershed Impounding Concept,(for example, CEAR 1152 and CEAR #1037).
a) Given any Project updates, provide information on the comparison of MC1 and the Project, including costs/benefits.
b) 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 orarchitectural significance.
c) 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.
Tuesday, July 31st, 2018, Letter to Andrew Wilson, Resilience Strategy Director
Dear Mr. Wilson:
Thank you for your email of June 21, 2018 in reply to our email of May 15th to Minister Phillips and others concerning Dam Safety regarding the proposed Springbank Dry Dam. We would like to let you know that on May 29, 2018, Dr. Gabriel received an email from the Prime Minister’s office recommending he submit the Tri-River Joint Reservoir proposal for flood mitigation and water conservation to the Alberta Government as the Federal Government is investing $180 billion under the long-term Investing in Canada Plan. Under the new Agreement, proposed projects must first be prioritized by the province before they are submitted to Infrastructure Canada for consideration. The email stated “I would encourage you to submit your proposal to the Province of Alberta so that it may determine whether the Tri-River Joint Reservoir project should be prioritized for funding consideration under the Investing in Canada Plan”.... “The Government of Canada’s Disaster Mitigation and Adaptation Fund is a 10-year $2 billion national program designed to help communities better withstand current and future risks of natural hazards. The projects funded under this competitive, merit-based program will increase the resilience of Canadian communities to the negative impacts of weather-related events and safeguard the continuity of their services”.
The currently proposed flood mitigation infrastructure option, the Springbank Dry Dam (SR1), has been unable to pass environmental assessments or receive social acceptance to date, and the present environmental impact assessment has been stalled at 110 days by the Canadian Environmental Assessment Agency because the Agency and other Federal Authorities have identified large gaps in the information required. Environment and Climate Change Canada have raised safety concerns regarding the estimates of the Design Flood Level and Possible Maximum Flood estimates (refer to pages 6-10 of the attached “Environmental & Climate Change Technical Review – June 18, 2018” pdf). Another important drawback is that SR1 will require removal and re-location of major natural gas distribution lines, which will cause great inconvenience to nearby residents, and great cost to taxpayers – yet this fact has not been brought to the attention of the public (see above referenced attachment). Because of all these significant obstacles to SR1 we again request that a PROPER feasibility study be commenced immediately on the Tri-River Joint Reservoir option.
In your June 2018 correspondence you refer to your previous letter to us of June 2017 in which you advised that the Tri-Rivers Joint Reservoir was “evaluated” and found to suffer significant shortcomings which rendered it ineligible for further investigation. However, despite our requests, we have never received any information as to where we can find any actual government or consultant reports or evaluations that would constitute any sort of study conducted on the TRJR option, let alone a feasibility assessment. Further, the information the TRJR proposal was expressed to supposedly lack is the very information that a proper feasibility assessment is expected to provide. The only information we have of any consideration given to TRJR is in the letter you sent to Dr. Gabriel (refer to the attached “Letter from Andrew Wilson – July 10, 2015”) which stated:
“This is a high level document and there are many details that would need to be addressed before this proposal could be considered. These details include: costs and cost benefits: the number and the design of the dams: the numerous engineering difficulties in constructing the connector channels through mountains; and the environmental impacts of proceeding with the project, among others.”
The AEP Springbank Project Engagement Team replied to our question about a third proposal being considered for flood mitigation on October 06, 2017, stating “other possibilities for flood mitigation including the Three Rivers proposal, were examined at a high level, and owing to cost logistics, environmental issues and poor catchment basin, were not pursued further”. We have been repeatedly advised that a “high level” assessment has been done on TRJR, but despite all the efforts of our Comprehensive Flood & Water Management Council team, we have been unable to find any report or record of this, nor have we received any further information from your department or the Government of Alberta. In our opinion, this demonstrates a serious lack of accountability by your department/office.
Our vulnerable river communities are in great danger each spring and live with the fear of another devastating flood. At the same time we are already facing water shortages for our growing community, agricultural and industry needs. We have always trusted our governments to protect us and also plan for future needs (and sufficient water is the most important of these), so we again respectfully request that, as the Prime Minister’s Office has recommended, the Tri-River Joint Reservoir proposal be submitted for the necessary feasibility study. The Environmental Impact Assessment on TRJR should only require 365 days, if no major problems arise such as have been discovered with the SR1 option, and Albertans could obtain a priceless asset for the future that would remove the enormous threat of spring flooding from our Bow Basin river communities, conserve the priceless bounty of clear mountain waters received in the spring, and provide an opportunity to generate the cleanest, renewable power available – hydroelectricity. We again request that our government recommend and authorize a proper feasibility study be commenced immediately on the Tri-River Joint Reservoir option, as it is becoming more obvious by the day that SR1 is not the project that is in the best interest of Albertans and taxpayers. You can refer to the website www.preventingalbertafloods.ca which provides more information on the research that has resulted in the Tri-Rivers Joint Reservoir proposal.
David & Noelle Read,
on behalf of the Comprehensive Flood & Water Management Council
Download the letters referred to here.
Monday, February 12th, 2018, The CFWMC team and Councilor Farkas at city hall.