Proposed sale of 25 sections of public lands (Twp 12, 13, Rge 11 W4 M) leased to the Bow Island Grazing Association for production of potatoes under irrigation by SLM Spud Farms

27 September 2010

Premier Ed Stelmach

Office of the Premier
Room 307, Legislature Building
10800 - 97th Avenue
Edmonton AB T5K 2B6

Dear Premier Stelmach:

We are writing to express our concerns about a proposal before the Alberta Cabinet to privatize 25 sections of public land, currently native prairie under grazing lease, for production of irrigated potatoes. Our concerns relate to biodiversity protection, water management, wetland and soil conservation and responsible land use planning. We are drawing on four decades each of experience in prairie conservation and watershed management in providing these concerns.  Since there is not public process to make our views known to decision-makers, we are appealing directly to you as Premier of Alberta and Chair of Cabinet responsible for administering laws, ratifying provincial policy and regulating industry.

Biodiversity - The area proposed for sale and cultivation is home to at least four species listed as ‘Endangered’ or ‘Threatened’ under Canada’s Species at Risk Act and Alberta’s Wildlife Act. The lands are also home to several species assessed as ‘Special Concern’ provincially and nationally. There are likely other species at risk living in the area, however we do not yet have full information from the Alberta Conservation Information Management System and adequate survey has not been conducted to know the full extent of species of conservation concern. Native grassland constitutes only about five percent of the provincial land base, and yet supports approximately half of the rare ecological communities, 40% of rare vascular plant species and 70% of mammal, bird, reptile and amphibian species considered at risk or may be at risk. Government has responsibility in legislation to protect species at risk. It would be prudent policy in meeting international, national and provincial biodiversity commitments to conserve the few remaining large tracts of native prairie that support species at risk (Prairie Conservation Action Plan).

Water Management - Conversion of 25 acres of native prairie to cultivated land under irrigation also has implications for water law and policy. The lands in question are within the South Saskatchewan River Subbasin below the confluence of the Bow and Oldman Rivers and are not within an established irrigation district.  The Bow, Oldman and South Saskatchewan subbasins are closed to further allocation because of water scarcity, stressed aquatic ecosystems and historical over allocation (South Saskatchewan River Basin Water Management Plan). The proponent of the project would therefore need to acquire water. It is our understanding that SLM Spud Farms plans to obtain water from the Bow River Irrigation District (BRID) by constructing a siphon across the Bow River and digging an irrigation distribution system. This suggests that BRID has significant amounts of water allocation that are excess to its needs. Given that the lower Bow River is degraded, it would be prudent policy consistent with Water for Life and the work of the Alberta Water Council to identify opportunities for allocating some of this water, perhaps saved through public investment in irrigation infrastructure upgrades, to meet instream flow needs, instead of increasing the risk of water scarcity and aquatic ecosystem degradation.

Wetland and Soil Conservation – The native prairie in question is underlain mostly by medium to coarse textured river- or wind-deposited soils with low-lying areas subject to salinization that support wetlands and areas of sand ridges susceptible to erosion. Provincial policy requires conservation of wetlands (Alberta’s Wetland Policy). Proposals to expand irrigated acres require assessment of soil suitability for irrigation (Irrigation Districts Act, Policy of Alberta Agriculture and Rural Development). It is our understanding that there is insufficient information for the area to meet these requirements.

Land Use Planning – A regional plan for the South Saskatchewan Region is currently being developed through a Regional Advisory Council advisory to Cabinet (Terms of Reference for Developing The South Saskatchewan Region). A Cabinet decision to approve privatizing 25 sections of environmentally significant native prairie for potato production undercuts the work of the RAC and is not in keeping with Land Use Framework outcomes – a healthy economy supported by our land and natural resources; healthy ecosystems and environment; and people-friendly communities (Land Use Framework). If additional potato production is demanded by the market, there is already ample cultivated land in or near irrigation districts to meet that demand for years to come. The project would lead to further loss of habitat for species at risk and degradation of aquatic ecosystems (rivers and wetlands) and soils. And finally, there is ample evidence that the proposal is creating controversy and divisiveness within and among communities in southern Alberta.

In conclusion, we urge you and your Cabinet colleagues to show responsible leadership regarding a decision about this proposed sale of high value public land by ensuring the aforementioned laws and policies are followed and that industry is appropriately regulated.

Yours sincerely

Cheryl Bradley and Lorne Fitch

cc:       Hon. Mel Knight, Minister, Sustainable Resource Development

Hon. Rob Renner, Minister, Alberta Environment

Hon. Jack Hayden, Minister, Alberta Agriculture and Rural Development

Ms. Bridget Pastoor, MLA, Lethbridge East