Hello Alberta Environment and Parks Regulatory Approvals Centre,
Re: Application number: DAPPL0002488/001-00474043
I am writing a statement of concern regarding the Public Notice, Water Act Notice of Application by Alberta Transportation that was put in the Calgary Herald on August 3, 2021.
PART 1
The following two points are a summary of a few of my concerns relevant to matters regulated by the Water Act. Due to my limited available time to write this, as described in points #1 and #2, I am not able to list nor thoroughly address all the water concerns.
- Unethical Timing of the Public Notice
It is noted that Alberta Transportation timed this notice to be only in the City of Calgary’s Herald and only on August 3, 2021. The mandate of elected officials of government is to represent and act in the best interests of Albertans. It is unethical to allow government departments to choose a date in the middle of summer when it is well known that many Albertans are on holidays, just coming back from, or just leaving for holidays, and therefore it was unlikely that few, if any the affected parties by SR1 would see this one-time only PUBLIC NOTICE.
As a result of this unethical timing the PUBLIC NOTICE was not truly a PUBLIC notice.
I was informed about this Notice through a telephone call August 16, 2021, from a Calgary resident who was wondering whether I was writing a reply to the SR1 concerns. It was a shock to find out that the deadline for responses was the next day, August 17, 2021. Our whole Springbank Concerned Landowners Group (SCLG), who worked so hard on the CEEA and NRCB submission to stop SR1, did not know about this notice. We therefore had hardly a day to review our documents and to send a submission.
Like the others in the SCL Group, I needed more notice time to read through, identify and develop points from the Don’t Dam Springbank/Springbank Concerned Landowners Group submissions over the past few years of hundreds of pages to CEEA/IAAC and to NRCB.
The government departments’ choice of mid summer timing is unethical, unfair, and results in not having an true PUBLIC NOTICE as evidenced by none of the SCLG were aware of the Notice.
- Unethical placement of the Public Notice
It is now obvious that the two SR1 decision making government departments, Alberta Transportation and Alberta Environment and Park are biased towards Calgarians. The result of this bias is that those of us upstream of the planned SR1 continue to be the “Forgotten Ones.” It is notable that these two government departments placed the Public Notice only in the City of Calgary’s newspaper.
It is also notable that the Calgary Herald is not considered a local newspaper for residents who are directly affected by SR1. Residents have two local newspapers, namely the Rocky View Weekly Newspaper and the High Country News monthly newspaper. The High Country News also has an on-line option for additional articles daily. The notice was not put in either newspaper or on-line.
The result of this public notice being placed only in the City of Calgary’s newspaper is that residents who are directly impacted have not read the one time only placement of the notice in the city newspaper. The evidence of not seeing this Public Notice placement is that none of our group members were aware of this “Public” Notice, and no resident in the area has contacted any of our group members to discuss this notice.
It is sad that the Alberta government could not find a way to communicate this notice in a local paper that is read by those actually being impacted.
It is also sad that the Alberta government continues to separate the need for flood control of Calgarians from the needs of flood control for residents who live upstream of Calgary. All Albertans on the Elbow River are entitled to have flood protection/control. A new need, as recognized by the government departments is the need for a water retention capacity to help provide water when there are drought in situations of low water flow in the Elbow River.
Based on the placement of the “Public” Notice in just one newspaper in the City of Calgary, and on the holiday timing when many Albertans were away, I request that consideration be given to another PUBLIC NOTICE being placed in the two newspapers where directly affected “public” reside and who are now not likely to be on holidays. Or another possibility is that Alberta Environment and Parks review each written submission and allow for the lack of detail, and possible omissions in the submissions. This lack of details should not affect the right to file a notice of appeal with the Environmental Appeals Board.
This practise of unethical timing and unethical biased placement of the Public Notice by the Alberta government departments must stop.
It is also noted that the Alberta Government department’s plan to avoid having statements of concerns filed by the SCLG almost succeeded.
PART 2
Introduction
Residents of Redwood Meadows have concerns about SR1 as listed in my September 15, 2020 submission to NRCB. This September submission identifies problems with SR1’s impact on many aspects of Elbow River water, aquifers, and lack of flood management. It is important to note that residents upstream of Calgary on the Elbow River are in favor of flood control, the same as Calgarians.
- Calgary will run out of water by 2036. Redwood Meadows/Bragg Creek will also experience Water Shortages in the future.
It is a fact that the south portion of the City of Calgary that relies on the Elbow River for water will run out of sufficient water by 2036. This fact was a main reason why SR1 should not be built. Surprisingly, during the NRCB Hearing, Alberta Transportation revealed a new solution to avoid building a dam upstream of Bragg Creek. The new solution is to build another dam on the portion of the Bow River that flows through the Stoney-Nakoda land. It is my understanding that Alberta Transportation is now negotiating with this First Nation to finalize a deal to build another dam on the Bow River. This planned new dam on the Bow River will leave Redwood Meadows and Bragg Creek without a controllable water source, such as a dam, upstream. Not having a dam upstream of Redwood Meadows and Bragg Creek will result in problems with options for water because the Elbow River flow volume continues to reduce as shown by the measurements of flow amounts that began in the 1930s.
NRCB did not give adequate thought to equal access to water during times of drought for all Albertans on the Elbow River. The bias in favor of Calgary needs to be resolved.
- Dirt Berms do not fully protect towns. Future floods similar or larger than the 2013 flood will put at risk again the possible flooding of the Town of Redwood Meadows and the flooding the Hamlet of Bragg Creek.
NRCB process did not adequately address what is the second level of protection in addition to berms for our towns. What will happen the next time there is a flood larger than the 2013 flood causing the berms to be breached. Consultants recommend there needs to be a second level of flood protection in addition to berms.
It would be effective and efficient use of flood water to have a dam upstream of all residents on the Elbow River. Then in non-flood times, the Elbow River could be managed to provide consistent flow downstream, into the Bow River and into the provinces of Saskatchewan and Manitoba.
- Berms do not protect residents upstream of SR1 from flooding of homes by the Alluvial Aquifers.
The NRCB process did not address the problem of houses flooding due to alluvial aquifers in Redwood Meadows and Bragg Creek that causes thousands of dollars of damage even due to smaller floods.
- Residents who experienced the 2013 flood still have Trauma memories.
The NRCB decision did not address the fact that many residents of Bragg Creek and Redwood Meadows continue to have traumatic memories arising from the big flood of 2013. The entire Town of Redwood Meadows was placed on mandatory evacuation.
Trauma is at the core of many costly mental health problems such as depression and anxiety. More follow up is needed with residents about their trauma memories, not just their mental health in general.
- In the Notice it states there will be simply be an “alteration to …”
NRCB did not sufficiently consider the impact of permanent large boulders where the low level output flows through the unnamed creek and back into the Elbow River.
Residents upstream float on air mattresses and little rubber dinghies down the river in non flood conditions. Instream work within the Elbow River such as putting boulders at the output of the SR1 when the water is released maybe be useful for the few days of the release of flood waters back into the river. What about the other non flood days, perhaps even 10 years x 365 days, where the boulders are a danger to families/children who float down the river during the non flood times. Consultation must take place with non flood time users to ensure they are not endangered by the plan for boulders, and other options need to be considered.
CONCLUSION
As requested in the Notice, below are the additional parts of required information in this submission.
I am one of over 1,000 residents living in Redwood Meadows who are directly affected by SR1 because there remains the possibility of the Intake backing up, the unknown impact of the new, river narrowing berms in Bragg Creek and the sandwiching of Redwood Meadows between the SR1 intake and the Bragg Creek berms.
Redwood Meadows property line is only a few km from the SR1 Intake. It is “next door” to Mary Robinson, whose ranch is directly at the Intake.
As mentioned earlier in this letter, there may be other points to add, but I only had a few hours to review prior information and write about NRCB and water related concerns.
Thank you for considering our comments.
Dr. Karen Massey, Redwood Meadows
