Proposed Sale of 13,600 Acres of Public Native Prairie in the Bow Island Provincial Grazing Reserve to SLM Spud Farm for Conversion into Irrigated Cropland for Potatoes
The Honourable Ed Stelmach
Premier of Alberta
Room 307, Legislature Building
10800 – 97th Avenue
Edmonton, AB T5K 2B6
October 12th, 2010
Re: Proposed Sale of 13,600 Acres of Public Native Prairie in the Bow Island Provincial Grazing Reserve to SLM Spud Farm for Conversion into Irrigated Cropland for Potatoes
Dear Mr. Stelmach:
Nature Alberta would like to express its grave concerns about a proposal currently under consideration by Cabinet involving the sale of 13,600 acres of Public native dry mixed grass prairie rangeland (currently under grazing lease) to SLM Spud Farms for conversion into irrigated cropland for potato production. Details on the proposed deal remain sketchy. However, it is our understanding that water for the project will be obtained from the Bow River Irrigation District by constructing a siphon across the Bow River and refurbishing irrigation canals that were built, but never used, seventy years ago. Potatoes are a thirsty crop, so large volumes of water will be required for this project. The deal may also involve a land swap.
Our concerns relate to the lack of transparency and public consultation, threats to biodiversity, lost recreational and ranching opportunities, water management, environmental assessment, and land use planning.
Lack of Transparency and Public Consultation
In a recent radio interview about this project, the Honorable Mel Knight, Minister of Alberta Sustainable Resource Development, correctly indicated that there were no provisions for public consultation in the Public Lands Act. Consequently, deals like this are done behind closed doors with little or no public disclosure and no public consultation despite the importance of these lands to ranching, oil and gas, recreational, cultural and environmental stakeholder groups. Yet all it would take is for you, or Minister Knight, to release a detailed project description and to order public consultation for the large land block involved in this deal. We suggest, too, that the Public Lands Act needs to be amended such that transparency is brought to the potential sale of public lands through active public participation.
Threats to Biodiversity
Sixty-one per cent of native prairie in Alberta’s Grassland Natural Region has been lost, and much that remains is highly fragmented. Native grassland habitats are amongst the most threatened natural habitats in Alberta, Canada and North America. They constitute only about five percent of the provincial land base, but support approximately half of the rare ecological communities, 40% of rare vascular plant species and 70% of federally and provincially designated at risk mammal, bird, reptile and amphibian species.
Readily available, published information reveals that the Bow Island Provincial Grazing Reserve (BIPGR) has high biodiversity values, including:
- Important deer habitat and Critical Ungulate Winter Range occurs along the South Saskatchewan River.
- Extensive Pronghorn surveys have been conducted in the immediate area over the last thirty years, confirming that healthy Pronghorn populations occur. The Grand Forks Pronghorn winter range lies a few miles west of the BIPGR.
- The South Saskatchewan River valley in the BIPGR has been identified as one of the most productive raptor breeding areas in the province. The uplands are important feeding areas. Nesting populations will disappear if feeding areas are lost.
- Upland areas north of the river have a number of artificial Ferruginous Hawk nesting platforms.
- The area has been rated as being locally important to Burrowing Owls and RSF modeling indicates the area contains above average Burrowing Owl habitat
- The South Saskatchewan River valley contains numerous large snake hibernacula and is part of the range of the Short-horned Lizard and Western Small Footed Bat. Like raptors, snakes require a constellation of habitats including hibernaculum, rookeries and upland feeding areas.
- The South Saskatchewan River is important to breeding Canada Geese, loafing American White Pelicans and migrating and overwintering waterfowl
- Alberta Sustainable Resource Development's Habitat Suitability Index Modeling indicates that lands in the BIPGR contain highly suitable or suitable habitat for Ferruginous Hawk, Burrowing Owl, Prairie Falcon, Sharp-tailed Grouse, Sprague's Pipit, Loggerhead Shrike, Great Plains Toad, Plains Spadefoot, Prairie Rattlesnake, Short-horned Lizard, Richardson's Ground Squirrel and Badger.
Based on range maps and habitat descriptions in provincial and federal status reports and recovery plans, 17 federally and provincially designated at risk species potentially occur in the BIPGR (see attached table). Nature Alberta’s Natural History Database indicates that 178 bird species, including the eleven at risk bird species identified in the attached table, occur on lands in or adjacent to the BIPGR. Published information indicates at least two other species, Prairie Rattlesnake and Greater Short-horned Lizard occur on the reserve. Wildlife data in Alberta Sustainable Resource Development’s Fisheries and Wildlife Management Information database would provide additional information on the occurrence of at risk and other wildlife species in the BIPGR. We urge the government to carefully review this information.
The federal and provincial status reports and recovery plans for all of the 17 at risk species known to or potentially occurring on the BIPGR all indicate that habitat loss and fragmentation have led to population declines and remain as major threats to these species. The Alberta Ferruginous Hawk Recovery Plan released in 2009 (pg 22) highlights the need to retain native prairie on provincial public lands: “Develop … an Alberta government policy to ensure retention of remaining intact native grasslands on provincial public lands. This should also prevent selling or trading away of native grasslands as these are essential habitat for ferruginous hawks and many other wildlife.” The current proposal to sell public land on the BIPGR is at odds with this management object. Conversion of the native prairie habitats into irrigated cropland also appears to violate the endangered species provisions of the Alberta Wildlife Act, and possibly the critical habitat provisions of the federal Species At Risk Act. It would also destroy the habitat of migratory birds protected under the federal Migratory Bird Convention Act.
Alberta Grassland Vegetation Inventory mapping reveals that the BIPGR is part of a large contiguous and mostly intact block of native prairie extending from the South Saskatchewan River north across the Red Deer River and well into the Special Areas. The Alberta Prairie Conservation Forum and other national and international bodies have emphasized the importance of maintaining these remaining large tracts of native prairie to protecting prairie biodiversity values.
Lost Recreational and Ranching Opportunities
Alberta’s 32 Provincial Grazing Reserves have been established with the main purpose of providing summer pasture for the province’s farmers and ranchers on public land, allowing them to use their own land for crop and hay production. The reserves also offer a host of recreational activities and are used by oil and gas operators, pipeline and seismic companies, and gravel haulers. They also provide excellent habitat for wildlife. The BIPGR is no exception. It supports extensive natural gas development, particularly north of the river, and since 1965, has provided opportunities for deer, antelope and big game hunting, canoeing, hiking and fishing.
Opportunities to pursue these multi-use recreational activities would be lost over a third of the area of the BIPGR if the proposed land sale goes through, as would the historical grazing opportunities the reserve was initially established for. The use of public lands for natural history enjoyment is of great importance to Nature Alberta, its members and its member clubs. We are deeply concerned when such opportunities are lost.
Water Management
The BIPGR lies within the South Saskatchewan River Basin. There has been a moratorium on the issuance of new water licenses over most of the basin for a number of years because of water scarcity, stressed aquatic ecosystems and historical over allocation. We are therefore surprised to learn that the Bow River Irrigation District (BRID) would have excess water to supply to this project. The project would increase the area of the BRID by more than 5%, and would require substantial amounts of water. The effects on water quality and quantity issues in the lower Bow River system must be evaluated before this project can be considered viable.
Potatoes are currently only grown on about 15% of the irrigated land base in the BRID. Ample land, an irrigation distribution network, and existing allocated water supply is available within the BRID. What is the imperative to increase irrigated acreage for potato production outside the district?
Environmental Assessment
Because of the lack of transparency, it is unclear to what extent an environmental assessment or review of this project has been undertaken and how that assessment, if it exists, will be considered in Cabinet’s decision as to whether the land sale should proceed. As stated, the BIPGR has significant prairie biodiversity values and supports a high number and densities of federally and provincially designated at risk species. The project will also have significant ramification on water quality and quantity issues in the South Saskatchewan River Basin, particularly the lower Bow River, soil erosion and salinization, and wetland loss, as well as socio-economic consequences. If a land swap is to occur, environmental values must also be fully considered on the swap lands. Has a comprehensive environmental assessment been conducted for this proposal? If it exists, is it available for the public to see?
Land Use Planning
The Regional Advisory Council to Cabinet is only months away from releasing the South Saskatchewan Region Land Use Framework (LUF). The approval of this project would undermine the Land Use Framework process promised by the Alberta government and is at odds with the planning framework promised outcomes of “a healthy economy supported by our land and natural resources; healthy ecosystems and environment; and people-friendly communities with ample recreational and cultural opportunities”. No decision on this project should be made until it can be considered in the context of the LUF.
At least five past planning exercises have noted the ecological importance of lands in the BIPGR:
- In 1991, uplands north of the South Saskatchewan River were identified as a Regionally Significant Environmentally Significant Area and the South Saskatchewan River valley was identified as a Provincially Significant Environmentally Significant Area
- In 1997, the Nature Conservancy identified the South Saskatchewan River valley as one of 176 landscapes of biological significance in the Great Plains region of North America
- In 2005, the Commission for Environmental Cooperation and the Nature Conservancy identified the area as part of the Bow Island Priority Conservation Area
- In 2009, the South Saskatchewan River valley and portions of the uplands north of the river were identified as Nationally Significant ESA
- In August 2009, in its submission to the Regional Advisory Committee, South Saskatchewan River Plan, the Prairie Conservation Forum identified the Grand Forks area as a High Value Biodiversity Landscape in Southern Alberta.
These planning exercises further support maintaining native prairie habitats in the BIPGR.
In conclusion, Nature Alberta, on behalf of its over 40 member clubs and their 5000 strong membership, wants to add its voice to the growing number of Albertans against the sale of public native prairie rangeland in the BIPGR and who want greater transparency and public involvement in issues involving public lands, particularly public land sales. We urge you and cabinet to reject this proposal.
Sincerely,
Chuck Priestley
President
Nature Alberta
Nature Alberta’s Vision is that Alberta’s natural heritage is widely enjoyed, deeply appreciated and thoroughly protected
cc: Hon. Mel Knight, MLA, Minister, Alberta Sustainable Resource Development
cc: Hon. Rob Renner, MLA, Minister, Alberta Environment
cc: Hon. Jack Hayden, MLA, Minister, Alberta Agriculture and Rural Development
cc: Dr. David Swann, MLA, Leader Alberta Liberal Party
cc: Mr. Brian Mason, MLA, Leader New Democrat Party
cc: Mr. Paul Hinman, MLA, Wild Rose Alliance
Follow these links to documents with more information on the issue above:
Additional Background on the Bow Island Provincial Grazing Reserve Land Swap Issue
Storm Brewing on the Prairies – Public Lands up for Grabs
-By Joyce Hildebrand, AWA Conservation Specialist Storm
A pdf version of the complete letter pasted above can be found here:
