concerned about the change in water alocation policy

As an academic that has studied Rockies hydrology and water resources on and off since 1995, often in partnership with and funded by the Govt of Alberta, and as one who has taught introductory and advanced hydrology at university level since 2000, I am concerned about changes to water allocation policy on the Oldman. A change in policy to allow increased industrial use reverses the headwater water resource protections put in place in 1976. There is much discussion and information circulating about water and air quality issues (e.g. increased selenium contamination and airborne particulates) and these concern me, too. However, my comment here concerns water volume only. 

First, while some can and have argued that water used in industrial processes is recycled, this is only partially true, as much of the water used for extraction and washing processes (and  also for dust mitigation due to our high incidence of severe Chinook winds) will either be lost to evaporation or held for long periods in settlement ponds. I have not personally done a full water balance analysis, as I do not have all the necessary data. However, from the accessible data on the industrial abstraction licenses contained within Benga's AER application, it appears they will have access to up to just over 600,000 cubic metres (or 600,000,000 litres) / yr for coal operations. Amortising this amount over a whole year amounts to between 15 and 20 litres continuously every second, 24 hrs a day, every day of the year. This may not sound like a high number but Grassy Mountain is one mine out of many proposed. So if this represents a reasonable estimate of the coal mining water need in this area, then this must be multiplied across all the areas in the Upper Oldman that could be impacted.

Second, we should question whether the allocation Benga requested represents their actual future water need. The data here are sketchy but based on a quick web search on multiple estimates of water consumption for coal extraction operations around the world, we find estimates ranging from approx 250 litres to 650 litres and upwards per tonne of coal. Benga estimate they will extract 4.5 Million tonnes of coal each year. At the low end, then, this amounts to over a billion litres / yr. This exceeds the 600 million litres / yr in the AER water allocation application, so if this is a reliable estimate of need and allocation, then either there is a shortfall in available water allocation to support the Grassy Mountain operations or Benga are going to be extremely efficient with consumptive water usages. I acknowledge I cannot guarantee nor do I stand by these numbers as they are based on what I can easily access and I do not have data on the specifics of this project. As such, these estimates could be wrong and I urge others to do their own digging and make their own calculations.

Third, historical allocations on southern Alberta drainage basins have been assessed based on around a century of runoff and climatological data. What we know now has improved dramatically since 1976 when it was then deemed inappropriate to continue mining operations in the Eastern Slopes, in part to safe guard future water resources. With more data and better analytical and modeling techniques, we now expect runoff will continue to decline, evaporative losses will increase, eastern slopes snowpack (the source of most of our water) will decline. All of these trends mean future water resources draining the Alberta eastern slopes will be under greater pressure than was historically the case. Add to this, we expect within the next two decades that there will be at least one major drought, perhaps prolonged and perhaps very severe. When this happens this will threaten food security given the increased demand on water supply from irrigation needs. So, if there is a prolonged drought, do we expect that mining operations will temporarily curtail? This would be the most logical remedy, as during hot dry summers, the mines will need more water; especially given chinook winds at this time will require much water to mitigate against health-damaging dust circulation.

I don't have answers, only questions. I have posed some of these questions to Alberta Environment and Parks, Science and Water Policy Branches to hopefully get some answers and to offer assistance with the necessary water resources impact assessment. My main concern, however, is that this change in policy has been expedited purely to address the needs of industry and to facilitate mining operations without undertaking the necessary science-based analysis to conscientiously evaluate whether such a shift in allocation is feasible over the next quarter century. It is my expert opinion that on water quantity allocation grounds alone, the move to increased industrial use in the eastern Slopes is a bad move that will have damaging impacts on downstream ecosystems and all those who depend on water; i.e. all community stakeholders and living organisms that depend on the Oldman River.

Dr. Chris Hopkinson

Research Chair & Professor of Geography and Environment

University of Lethbridge