Please help us to protect the last 10%
of Calgary’s remaining wetlands
Please help us to protect the last 10%
of Calgary’s remaining wetlands
Water Act Approval 00388473-00-00 to fill in 24 wetlands within the SWCRR corridor
In the Environmental Appeals Board (the “Board”) decision in the Hanson, Lindberg versus the Director decision dated Feb 20, 2014, the Board made the following rulings:
- After reviewing the evidence, submissions, and the record, it did not appear AESRD considered avoidance of the wetland and only considered compensation. Therefore, the Board is recommending the Approval be reversed.
- The Board, when preparing its recommendations, must consider existing legislation, policies, and guidelines that are in force at the time of the Board’s decision, which may be different than what existed at the time the Director made his decision
- The Board finds the Director did not consider the applicable legislation, policies, and guidelines prior to issuing the Approval
Given this precedent, and the fact that the proponet had once agian used the the 1993 Interim Policy as opposed to the 2013 that was in full force and effect in the white zone as of June 1, 2015, the appelants made the following submissions to the Board that clearly proved that the Director had erred, i.e. as in the Hanson case, the proponet had moved directly to comepnsate without considering “avoidance” or “minimization”.
- See Part I of the appellants submission
- See Part IIa of the appellants submission
- See Part IIb of the appellants submission
- See Part III of the appellants submission
Wetland W06 (the “beaver pond”)
One of the wetlands that we have
saved for future generations
Wetland W06 – One of the wetlands that we have saved for future generations
Why are wetlands so important? According to the Association of State Floodplain Wetland Managers (ASWM), wetlands are important because:
- They provide unique habitat for waterfowl, certain mammals and amphibians, reptiles, aquatic insects, fish and birds.
- Wetlands are often nicknamed the “kidneys” of a watershed because they filter out toxins, which improves water quality for surrounding streams, rivers, lakes and other wetlands.
- they also perform other functions, such as flood attenuation, water storage, providing habitat for wetland-dependent species and recreation opportunities for people, including nature-watching, birding, hunting, hiking, paddling and fishing.
- Wetlands also help natural resource managers better understand climate change impacts, such as sea level rise and natural hazards like hurricanes.
For these reasons and more the ASWM concludes, ” it is essential to protect and conserve wetlands”.
Wetlands are the only ecosystem in the world recognized by an international treaty, the Ramsar Convention. A major obligation under the Convention is implementation of principles, proposed in 1987 by Canada, for the wise use of wetlands. The Convention notes the “wise use” of wetlands is defined as their “sustainable utilization for the benefit of humankind in a way compatible with the maintenance of the natural properties of the ecosystem”. Further, it calls for the establishment of wetland conservation policies in each nation to improve institutional and organizational arrangements, to address legislative needs, to increase knowledge and awareness of wetland values, to monitor the status of wetlands, to identify program priorities and to develop action plans for specific sites.
The U.S. Environmental Protection Agency (EPA) also states, “Wetlands are among the most productive ecosystems in the world, comparable to rain forests and coral reefs”. The EPA also states, “Protecting wetlands can protect our safety and welfare“.
Taking into account this information, the information provided by Ducks Unlimited in the YouTube videos on this page, and the goal of the Alberta Wetland Policy – to conserve, restore, protect and manage Alberta’s wetlands to sustain the benefits they provide to the environment, society and economy – we are a loss to explain why a road that has a 280 m wide right-of-way cannot avoid some of the last remaining wetlands on the west side of Calgary. As the Alberta Wetland Policy states, Wetlands of the highest value are protected for the long-term benefit of Albertan. Moreover, wetlands are the only ecosystem in the world recognized by an international treaty, the Ramsar Convention. Plus as previously mentioned, Canada has an obligation under the Ramsar Treaty to implement principles related to the wise use of wetlands, which is defined as their sustainable utilization for the benefit of humankind in a way compatible with the maintenance of the natural properties of the ecosystem. Given the importance of wetlands, worth more more hectare than most other ecosystem types, why did the Director of the Water Act approvals team give the approval to fill in these 24 wetlands?
Wetland W11 – Should have been SAVED – So Sad!
Wetland W11 – Should have been SAVED – So Sad!
During the course of the EAB Hearing on the 24 wetlands, the appellants proved that Alberta Environment and Parks used the 1993 Wetland Policy as opposed to the Alberta Wetland Policy (2013), which was required for all applications where fieldwork was completed after May 31, 2015.
- Fieldwork for the Wetland Impact Assessment was completed in October 2016).
- The AMEC Environmental Assessment (Update 2104) only included 10 out of the 24 wetlands.
In addition to the above, the appellants also proved that the Water Act Approval has the following deficiencies:
- There was no attempt to avoid or minimize the damage to any wetlands in the SWCRR right of way; the proponent went straight to compensate
- This contravenes the Environmental Appeals Board of Hanson & Lindberg vs. the Director (2014)
- Even the Provincial Wetland Restoration/Compensation policy has the hierarchy of avoid, minimize and compensate
- There was no options analysis and no cost benefit analysis
- No Regional impact analysis
- No Hydrological assessment
- The application did not include the impacts to the watershed and source water
- The application did not include the area water management plan and the stormwater management plan for the ring road and adjacent communities
- There was no Cumulative impacts assessment
- No Hazardous goods risk assessment, including risk to drinking water
- No Wetland relative value assessment
- No social impact assessment
- The application did not consider the adverse impacts to biodiversity and species at risk
- The application did not include the assessment of harm to adjacent lands and especially the Special Protection Natural Environment Park (the “Weaselhead”)
- Work has occuured during “restricted activity periods” for fish and birds
Further, the City of Calgary’s interactive “Vulnerability Map” shows that Oakridge and our drinking water is “very high risk” if there is a contaminant spill at the Clay Marsh (11.65 ha wetland W11).
Please click here to view the images that go with this assessment AND click here to see the adverse impacts to wetland W06 (the “Beaver Pond”). To view a timeline of aerial images taken by members of the Weaselhead Glenmore Park Preservation Society (WGPPS) please click on the link below.
The City of Calgary Council approved the Wetland Conservation Plan in 2004, making Calgary one of the first municipalities in Canada to adopt a wetland protection policy that provides procedures for the protection of our priority urban wetlands. The introduction of this Wetland Conservation Plan states:
“The City of Calgary is home to some of the most significant wetland areas in North America.1 In 1981, it was estimated that 78 per cent of the pre-settlement wetlands in Calgary had been lost. Today, the estimate is closer to 90 per cent. Urban development is now extending into areas of significant wetland complexes, some of which are considered provincially and nationally significant to breeding waterfowl.2 These wetlands also play an important role in improving water quality and quantity, reducing flooding and soil erosion, providing bio-diversity, moderating climate conditions, contributing to an aesthetic urban design, and providing educational and recreational opportunities. To ensure that these benefits remain viable and sustainable for our future generations, The City of Calgary has developed the Wetland Conservation Plan, which sets priorities and explores alternatives for wetland conservation in order to guide future urban development.”
Some key principles within this plan include:
“Efforts shall be made to avoid the impact from development on Calgary Wetlands that are environmentally significant and/or contribute to water quality and quantity, and that can be integrated into urban development while maintaining their ecosystem survivability and sustainability”
“Where possible, Calgary Wetlands shall be integrated into The City’s Natural Environment Park system to ensure their long-term sustainability”
“The City of Calgary shall ensure that there is No Net Loss of Calgary Wetlands after efforts have been made to avoid impact from development”
“Using best practices and, as approved by The City of Calgary, proponents of development shall mitigate one or all of the following features and functions of a Calgary Wetland that have been disturbed or lost due to development: a. wetland and upland plant communities; to ensure their normal succession pattern; b. wildlife (including fish) habitat; c. hydrologic regimes (contribution to water quality and quantity); d. flood attenuation and erosion control functions; e. cultural, recreational and educational functions; and f. urban design functions”
“Ecological boundaries of watersheds and/or aquifers do not respect political boundaries. Therefore, a regional planning perspective should be considered when unavoidable losses to existing wetlands are compensated through wetland enhancement and/or creation”
“Calgary Wetlands shall be managed to ensure their long-term sustainability”
With respect to the 24 Wetlands application, the Director’s Record clearly shows that the City relaxed these rules and principles. The question is why because these relaxations violate the objective of managing wetlands to ensure their long-term sustainability.
Wetland W06 (east side of the Beaver Pond)
These images of the east side of the Beaver Pond were taken between June 21 and September 24, 2017. As can be seen, the pond dried up during the summer. However, the west side of the pond remained in the same state as what the east side looked like on July 29, 2017, i.e. remained full of water. The question is what happened to the east side of the pond? YYC Cares has investigated this issue and determined that the drying up is very much related to the filling in of the feeder stream, water course WC01, upstream at the 90th Avenue interchange. The Water Act requires an Approval if an activity will alter the flow or has the potential to alter the flow of water. In this case there was no Approval from AEP for filling in 900 m of the feeder stream for this Beaver Pond in a Special Protection Natural Environment Park. We believe that this has caused irreparable harm.
West side of W06 (The Beaver Pond)
These images on wetland W06 (the Beaver Pond) were taken on October 22, 2017. At this point the transportation utility corridor is 285 m wide but fans out to +600 m wide as it crosses the valley. Consequently there is plenty of room to avoid this wetland that lies within a Special Protection Natural Environment Park. The images at the north and south end demonstrate the extent to which the once pristine valley has been destroyed. In our opinion, this was very avoidable with a clear span bridge.
Some of the one’s that we saved
These are some of the species that inhabit wetland W06 (the “beaver pond”). Thanks to our efforts, they will live another day. However, they should never have been put at risk because our Legislation is designed to protect them.
Click on the link below to view our list of wetland reports