Update to Prairie Creek Frac Diversion
Folks,
It's been an interesting journey watching the Alberta Energy Regulator [AER] attempt to defend the issuance of a Diversion Permit for the upper reaches of Prairie Creek. We will not know for a couple of years if the Diversion destroyed the primary spawning activity for this year which is located downstream about 2 km. from the Diversion site.
To this point, although letters describing the concern have been sent to Minister of the Environment - Nixon, Minister of Energy- Savage and Minister of Fisheries and Oceans - Murray, the only response was from someone in AER.
Copied below is my response to the AER contained in the letter to the Minister. of Environment
Nixon, Jason, Honourable
Minister of Environment and Parks, House Leader,
323 Legislature Building
10800 - 97 Avenue
Edmonton, AB, T5K 2B6
Subject: Follow up to my letter of January 28, 2022 regarding Prairie Creek Frac Water Diversion
Dear Sir,
There are three questions:
1] Should AER be responsible for water resources in Alberta?
2] Have they demonstrated in the Prairie Creek Diversion protection of the aquatic resources?
3] Why is the Diversion permit issued for 1 year rather than a single instance? A yearly permit could result in multiple diversions at the same time dewatering the stream entirely.
Response to AER and Minister,
Good Day,
Thank you for responding to my letter regarding the Water Diversion from Prairie Creek License No. 00480667 issued December 29, 2021
I’ve read and attempted to understand your response and as well have shared it among others interested in the Diversion issue. Without exception, none of use really understand what you are talking about. Therefore, I am ignoring the calculations based on yearly flows or other water courses that were used to validate the Diversion Permit. And I find it incredibly strange that you suggest I reach out to the company acquiring the permit I have to wonder why? I had no idea that they controlled water issues in Alberta. I have believed for some years that water was a Public Resource and was managed by Alberta. Why do you believe that they could supply the logic for when and how the permit was issued?
With that, below are further questions:
1] You say 41 Temporary Diversion Licenses [TDL] have been issued. While this is true, there is an enormous difference between filling a cattle watering trough and the tankage/water volumes needed for Frac use. As the Frac Permit is a one off so far, why would you include it in the Water Diversion [WD] list?
2] What the use of water flow rates in the Clearwater River illustrates, is that the Desktop Monitoring System is nothing more than a guess of the actual flow at the Water Diversion site. Utilizing a metering Station for the Clearwater River, whose source water extends well into the mountains, is more than strange as the Diversion is located on a stream whose source water is all from the Foothills. Why was the Clearwater River flow applicable at all.
However, not all is lost, Water Survey of Canada measurements are quite consistent although both are higher at Everdell Station on Prairie Creek [ 05BD002] than the flows recorded the end of October 2021 by 25% on December 16, 2021 measurement and 13% on February 23, 2022.
Although the flow at 05BD002 doesn’t determine the flow at the Diversion site, subtracting the tributaries entering above 05BD002 to the Diversion would yield a much more accurate flow rate. What I find most curious is that the measurement of flow captured by Water Survey Canada @ 05BD002 is higher than the station recorded in both the spring and fall of 2021 when the meter station was obviously ice free. I have witnessed the Water Survey of Canada do winter rates. What the Water Survey Canada efforts demonstrates is the ability to measure real time flow rate in the winter. Why was this not done at the Diversion site?
I understand your spirited defence of calculating water flows in the absence of real data. However, as indicated by the ability of the Water Survey of Canada to measure winter flows at 05BD002, a real time flow rate could have been acquired resolving the flow rate issue. This would have ensured reducing the risk to fisheries based on a real calculation rather than a guess provided by the Desktop Monitoring Concept.
3] Your response indicates a Stream Order of 6 and yet in the Surface Water Allocation Directive [ SWAD ] on page # 7 a paragraph entitled Stream Order does not reference flow rates. However, it does mention adding Headwater streams increases the stream order. The North Fork of Prairie Creek may be considered a 1 and where the south and centre fork combine yield a 3 due to the addition of Lick Creek. The only point on Prairie Creek that may approach as Stream Order is 6 is at 02BD002.
4] Although the companies seeking the permits may make the argument that the water diversion permit must be issued immediately, in the Prairie Creek Diversion case, filling the tanks then allowing them to freeze for 2 months (which resulted in one tank failure dumping the contents when thawing, one can only assume a rapid permit issue was not required or were the volumes needed as one tank sufficed for the frac.
In conclusion, if real data is possible, it must be used to establish permitted volumes to protect aquatic life, or a permit should not be issued until stream data is available.
Regards,
Don Andersen
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