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| Last Review/Updated: August 20, 2002 |
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NRBS - HomeTable of Contents |
Northern River Basins Study Final Report
4.0 Study Board Recommendations
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Recommendation 1 Recommendation 2 Recommendation 3 Recommendation 4 Recommendation 5 Recommendation 6 Recommendation 7 Recommendation 8 Recommendation 9 |
The scientific findings of several Study components have direct bearing on water resource management in the northern rivers. Thus, studies completed on nutrients and dissolved oxygen have implications for regulations. Contaminant studies also call into question the adequacy of present measures to protect water quality. The quality of drinking water took the Study somewhat far afield from the mainstem river systems but this was necessary to answer the question that the residents wished to have answered: is the water safe to drink?
Early in its work, the Board decided not to expend some of its limited budget on studies of land use within the basins. The primary focus of field and laboratory studies centred on the aquatic ecosystems, and virtually all of the research projects focused on aquatic environments. But land use issues kept cropping up at community gatherings, at meetings of the Science Advisory Committee and in discussions of the component group leaders. Workshops were organized on land use policies and forestry practices and a number of recent reviews were provided to Board and staff members. Many of the Board members had a wealth of experience and expert knowledge which assisted Board discussions.
In consequence of their sustained interest in the inter-relationship between land use and water resource management, the Board developed several recommendations concerned with government policies and proposed legislation. The result is a diverse group of recommendations, but all relate to the activities in the basins and their impact on the residents and the rivers.
Preamble
During the public consultation process, the Board encountered concerns about the nature and extent of effluent from municipal, industrial and other sources. Some representatives from the public-at-large and interest groups called for a reduction of these effluents within the basin, and, in some cases, for the elimination of pollutants introduced through human activity.
While public attention was often focused upon concerns relating to toxic substances emitted by point sources, scientists have expressed parallel concerns over nutrient additions and associated runoff of biocides and heavy metals from large water reservoirs and lands disturbed by agriculture, forestry and industrial activities.
The Board was encouraged by the findings of the science research that over the course of the study, the concentrations of certain organochlorines (notably dioxins and furans) decreased. However, these contaminants are still found in detectable amounts in sediments and fish tissue samples across the basins. Also of note, were PCB levels found in some reaches of the northern rivers. Other research results indicate that fish within the basins have been exposed to toxic contaminants and may be responding in a variety of ways. Lesions and other abnormalities in the fish populations were also noted at some locations at higher levels than occur naturally. In some cases, changes to the aquatic ecosystem through the addition of nutrients were also cause for concern. This concern is based largely on the implications for instream productivity, dissolved oxygen and benthic community structure.
Traditional knowledge reinforced the science findings with observations of lesions and other abnormalities in the fish populations. Fish populations are said to be far less abundant than they once were. It was stated that some fish that are caught do not taste or smell as they should and that the rivers are less clean than they once were.
Opinions of some respondents to the householder and stakeholder survey were reinforced by comments of some people attending community gatherings and workshops. They told the Board of their strong support for the concept that "zero discharge" of substances or waste into the environment should be the objective of environmental management strategies.
Taken literally, "zero discharge" would be difficult to achieve. For example, eliminating discharges directly into the rivers could result in discharge to the land or air. As it stands now, some pollution comes to the northern basins from far afield, from North America, Europe and Asia. Airborne contaminants such as mercury, PCBs, pesticides, dioxins and furans, as well as radioactive isotopes are imported to the basins. Local airborne sources may also contribute to stream pollution directly and indirectly through drainage from the land. The disposal of wastes directly in landfill may similarly mean that contaminants that originally came from point sources become more widely dispersed, seeping into the streams as non-point sources. Other non-point sources, such as agricultural drainage containing pesticides and fertilizers, are equally difficult to assess and control.
However, understood within the broader principle of pollution prevention, zero discharge may be one of the ways to reduce the deposition of unwanted substances or waste into the environment. The pollution prevention principle requires the elimination or virtual elimination of the generation, use and discharge of persistent toxic substances that tend to bioaccumulate in the environment. It also requires significant reduction in or the virtual elimination of deposits of all other forms of waste into the environment.
Conclusion
The Board supports the fundamental principle of pollution prevention. Science and traditional knowledge findings, together with public input, all indicate that action is required to address the presence and effect of contaminants and nutrients generally, and particularly in some reaches of the rivers. In some instances, the Study's findings are preliminary and further study may be required to fully answer the questions raised. However, the weight of evidence justifies a precautionary approach.
The Board recommends that:
| 1. |
Regulatory agencies for the northern rivers declare and
implement, through law, policy and practice, pollution
prevention, including but not limited to zero discharge,
as a primary environmental objective and
as an important component of sustainable development. | ||||||
| 2. |
For contaminants;
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| 3. |
For nutrients;
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| 4. |
For other wastes;
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| 5. |
Regarding international agreements;
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| 6. |
And with respect to performance evaluation;
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Dissenting views
Recommendations 1-1, 1-3, 1-4, and 1-6 carried the substantial support of the Board. With regard to Recommendation 1-2, some members viewed the ten-year time limit as being unreasonably short. With regard to Recommendation 1-5, some members viewed international affairs as being beyond the scope of the NRBS.
Some dissenting members argued as follows:
"Recommendation 1-1. For the NRBS Board to place a recommendation in its report for zero discharge would in, our opinion, be irresponsible as such a recommendation is an impossible illusion and we feel it is irresponsible to make recommendations that are impossible to achieve.
"Recommendation 1-2. The placing of a cap on effluent discharges would have enormous implications for municipal expansions, economic development initiatives and for other areas such as agriculture. Such a recommendation would be devastating for economic development in northern Alberta and would, in our opinion, be extremely presumptuous on the part of the NRBS Board. There are a number of industrial projects in planning stages at this time, some of which are in fact covered by signed agreements with the Government of Alberta. There are processes in place to assess new projects from every perspective, including strong environmental assessments, and these are the processes by which new industrial projects should be judged. For the NRBS Board to forward a recommendation to the Ministers that would eliminate such projects, before any review process, would not be responsible.
"Recommendation 1-3. Our dissenting position with this recommendation pertains to the elimination, or the far-reaching capping, of all nutrients from discharges. This recommendation has enormous potential cost implications for all municipalities in the northern river basin area. It is our understanding that some recommendations on nutrient discharges may be forthcoming from Alberta Environmental Protection in the future, pertaining to tertiary treatment of waste water in larger municipalities. The [Board's] recommendation, as written, does not exclude any municipal waste water treatment facility and, as such, is not acceptable.
"Recommendation 1-4. We oppose this recommendation because it refers to elimination of the discharge of other wastes. We have absolutely no objection to the term 'reduction' of other wastes, but, as noted in our objection to the previous recommendation, we do not believe that zero discharge is a possible objective."
In place of the Board's recommendations, these Board members offer the following alternative, that:
"The regulatory agencies within the northern river basins set, as an objective, the on-going reduction of emission of contaminants, nutrients, and oxygen demanding materials that are determined to have detrimental impacts on river systems and/or human health;
"Methods of discharging effluents be continually improved and upgraded, as technology allows, with reasonable environmental and economic considerations;
"On those reaches of rivers that have been determined to bear excessive effluent loading, a policy of no further loading be established with a future program of staged reduction of effluent discharge."
The above dissenting opinions and recommendations were submitted by the Board members, Mayor Michael Procter and Councillor Diane Slater.
Another Board member expressed the following view:
"It is not reasonable to specify a ten-year period for the elimination of "persistent toxic substances". The timetable must be site specific. The reasons are obvious—technology status, business constraints, and substance differences. This may also inhibit the development of more cost-effective technology. It may be more appropriate to use regulatory means at the licensing level to deal with time-tables."
A further dissenting view was expressed by another Board member with regard to the time line set for eliminating the use, generation and discharge of persistent toxic substances recommended in Recommendation 1-2:
"The technology does not now exist to enable this time limit to be met without placing a huge economic burden on the existing industry and creating related spin-off effects on the citizens of the region. (for example, as a minimum it would require change in TCF technology, even though the zero effects are not proven.) There will be ways to eliminate the substances used or produced by these technologies, but not in the time frame indicated."
Preamble
Oxygen is required by aquatic organisms to survive, grow and reproduce. Dissolved oxygen in water can be depleted during winter as a result of oxidation of organic matter (decomposition) during the time of year when ice and snow cover prevent replenishment by photosynthesis and reaeration. The sources of organic matter that contribute to under ice water column and sediment oxygen demand (SOD) include terrestrial leaf-litter, suspended solids in pulp mill and municipal effluent, and elevated levels of algal growth in nutrient enriched reaches of the rivers. Wastewater effluent may also have significant levels of biochemical oxygen demand (BOD). Continuous winter dissolved oxygen monitoring and winter dissolved oxygen surveys on the Athabasca River have shown that levels have stayed above 6.5 mg/L at the two low points upstream of Smith, Alberta and upstream of Grand Rapids since 1989. Pulp mill BOD discharges presently exist at less than half of their licensed limits and are not as dominant a factor in determining winter dissolved oxygen as they probably were during the 1960s. Under present conditions BOD, SOD, headwater and tributary dissolved oxygen inputs, mainstem flows, and reaeration at variable open water leads, all appear to be important influences on winter dissolved oxygen.
Laboratory studies on effects of lowered dissolved oxygen levels (3 mg/L) at low temperatures (2-3°C) showed that mountain whitefish eggs took longer to hatch and bull trout alevins were less well developed than at higher dissolved oxygen concentrations. The commonly occurring mayfly in the northern rivers (Baetis tricaudatus) was also found to have decreased survival and reduced feeding rates at a dissolved oxygen concentration of 5 mg/L. Given that mayflies and the early life stages of fish live at or in the surface layers of the riverbed and that dissolved oxygen concentrations can differ by 3 mg/L between the water column and the water in the sediments of the riverbed, dissolved oxygen concentrations in the Athabasca River could already be at levels that could have chronic effects on these animals at localized sites.
Additions of nutrients such as nitrogen and phosphorus stimulate plant growth which in turn contributes to oxygen deficiencies under winter ice. Effects of this kind are negligible in the mainstems of the Peace and Slave Rivers but in the Athabasca and in the Wapiti / Smoky systems, pulp mill and municipal effluent cause biological enrichment. Many organisms, including fish may grow faster and have higher rates of survival. Nutrient additions are thus a mixed blessing, since moderate additions can increase the growth of aquatic insects and fish but excessive enrichment can substantially degrade water quality and the aesthetics of rivers.
In the long term, nutrient enrichment is cumulative. Nitrogen and phosphorus recycle in ecosystems. In consequence, the initial impact of nutrient additions may extend for only a few kilometres downstream from a point source, but subsequently the effect may be observed much further downstream. While the effect of a point source is quickly dampened as the nutrients become chemically locked in sediments or become incorporated in plants and animals, the release of nutrients from sediments that are disturbed or from decomposing plants and animals can extend nutrient impacts far down stream.
Conclusion
The adherence to strict uniform wastewater treatment design standards for all municipalities, without regard for the fish habitat and existing dissolved oxygen problems in downstream reaches, may be inadequate to protect these reaches and may also unduly penalize some communities situated on larger, well-oxygenated reaches.
The Board concludes that governments must examine the concept and implementation of reach-specific water quality objectives to protect sensitive fish habitat and spawning areas while taking into account nutrient and contaminant loadings to the river.
This implies a need to achieve a better understanding of the dissolved oxygen requirements of various fish species and other aquatic organisms in the northern rivers under ice cover winter conditions.
The Board is not satisfied that present regulation of nutrient additions is adequate for controlling their environmental effects in many locations in the basins. As cities and agricultural activities grow and as new industrial facilities come online, nutrient effluents may constitute a worsening long-term threat to the ecosystem. Effluent standards for municipalities should be based on providing a good general level of treatment supplemented by additional (tertiary) treatments as necessary to protect downstream fish habitat and maintain dissolved oxygen levels. Standard reporting requirements for water quality parameters and flow rates should be in place. Correction of these and other deficiencies would ensure better control of nutrient rich effluent from municipal sewage treatment plants and pulp mills and would facilitate assessment of longterm consequences of nutrient additions.
The Board recommends that:
Preamble
Uppermost in the concerns of northern residents is whether the water is safe to drink and the fish are safe to eat. The Board's drinking water study went far afield from the mainstems of the rivers and their tributaries, examining the quality of water that people actually drink from a variety of sources. There are 122 drinking water treatment and supply facilities in Alberta that are regulated by the federal and provincial governments. These facilities serve a population of approximately 173,300. Thirty-seven of these facilities serve a population of approximately 151,400. The remaining 21,900 people are located in 85 communities with less than 500 population each.
Studies determined that the risks stem primarily from the consumption of water from unregulated or non-conventional supplies and in some communities with less than 500 population. The risks arise primarily from microbial contamination that poses an immediate health risk, as compared to chemical parameters which are usually only a concern in the context of a lifetime of exposure.
Information on water treatment facilities in the Northwest Territories was not included in the assessment.
Conclusion
The problems in smaller communities are often related to the operation of plants because facility owners do not make use of existing operator training, certification and assistance programs. Facility owners must be educated so that water treatment becomes a priority. The facilities must be given adequate attention and resources. There is a need to continue enforcement of water quality guidelines and promote standardized water delivery and storage practices. Drinking water quality monitoring requires improvement. There is a need to provide public education on safe use of naturally found water.
The Board recommends that:
Preamble
The integration of water quality and water quantity is essential for sophisticated water management. Their separation in Alberta government legislation is unfortunate. The impact of effluent on river ecosystems depends not only on the substances they contain but as well on how rapidly effluents are diluted. The Water Management Advisory Committee, during its public meetings, received many comments on this subject stressing the need for "strong, visible coordination or links" between the new Water Act and the Environmental Protection and Enhancement Act".
Conclusion
Aside from provisions for referral, the proposed new Act is silent on the subject of the coordination of quantity and quality. Water management plans may involve cooperation with "government agencies and other government departments" that could include Alberta Environmental Protection but the key issue of integrating water quality and quantity considerations is not specifically nor adequately addressed.
The Board recommends that:
Preamble
Adequate levels of flow are necessary for the protection of stream and riparian biota, for aesthetic reasons, and the pursuit of stream-based recreation. Ensuring those flow levels is commonly recognized as being consistent with balanced use of water resources. There are many administrative ways to secure these instream flow needs (IFNs), among which is the provision in the proposed new Alberta Water Act for the government to apply for a licence. The Act does not make clear what might motivate the Alberta government to apply for a licence but presumably, strong representations from residents and users could be influential in determining government actions. Proactive steps from within government might lead to a more consistent approach.
Conclusions
The Board is of the view that the Alberta government should play an active role in setting aside stream flows for protection of aquatic habitat. A positive proactive program with consistent criteria would best serve the public interest.
The Board recommends that:
Preamble
Inspection and enforcement of regulations concerning water quality and water quantity are essential for wise use of water resources. Until recent decades, competition for water has not been intense. With progressively greater settlement and industrial activity there has been a commensurate requirement for closer control of water uses. Many licences provide for more water than is needed. Some people believe that some licences provide for much less than is taken. The proposed new Alberta Water Act contains an arsenal of provisions for inspecting and enforcing water quantity that should be used fully.
The same may be said for the provisions of the Alberta Environmental Protection and Enhancement Act with respect to inspection and enforcement of licensing provisions for effluent discharges. Without rigorous inspection and enforcement the purpose of legislation may be frustrated.
Conclusion
In the course of its public meetings throughout the basins, the Board heard strongly expressed views about the ineffectiveness of current inspection and enforcement activities. Public concern about the adequacy of inspection and enforcement were echoed in the Board's survey of basin residents. It is evidently perceived that much could be done to address these concerns.
The perceptions may not necessarily accord with realities, in which case there is need for better communication with the public. On the other hand, concerned members of the public should do everything reasonably possible to determine whether the facts support their perceptions. This might be achieved in part by applying for information under the Freedom of Information Act. In any event, the Board feels there is room for improvement in the areas of inspection and enforcement of water licence legislation.
The Board recommends that:
Preamble
The Peace-Athabasca Delta has been slowly drying up since the Bennett Dam was completed over 20 years ago. Regulation of the Peace River flow at the Bennett Dam has been held partially responsible because spring and summer flows are lower and winter flows higher. The effect of the Bennett Dam has been exacerbated by relatively dry climate conditions over the past two decades. Rock filled weirs, constructed in the 1970s, have restored summer water levels and reduced their seasonal amplitude, but have not reflooded many of the perched basins—the areas that have experienced the most drying. For these basins, a large-scale flooding of the Peace River is required.
Several measures could be taken to reflood all or part of the delta periodically. Variable height control structures that allow water in but not out of lower basins have been used on an experimental basis in the past with some success, but problems with ownership and responsibility must be addressed. The method deserves further attention and though it would affect only limited areas it would provide valuable information on the response of vegetation to flooding. Hydraulic pumps have been suggested for flooding perched basins above the main flow network but for larger scale flooding, the construction of an ice dam near Quatre Fourches Dog Camp is probably needed. An attempt in 1994/95 was hampered by winter decreases in flow related to operation of the Bennett Dam. Future attempts should be preceded by understandings with B.C. Hydro.
Complete restoration of periodic flooding of the higher perched basins is only feasible with an ice dam on the Peace River, perhaps with ice thickness enhanced using spray ice techniques. This method will probably only work in years when high tributary flow is augmented by increased releases from the Bennett Dam. Monitoring the snow pack of tributary basins is essential for precise forecasting of the likelihood of favourable conditions for flooding. Present monitoring of the Wabasca River basin is inadequate and further refinement of Smoky River basin monitoring would be desirable. The creation of ice jams using "thermo-siphons" as initiators was suggested in the early 1970s and is worth consideration. Reopening a connection from the Peace River to the creeks that drain into Lake Claire would facilitate flooding and a connection via the Claire River has recently been opened.
Reclamation of the delta is of great importance to residents of the area. Production of waterfowl, muskrats, fish and bison depends on returning the delta to its former state. The way of life for delta residents depends in turn on restoration of its flooding from time to time (see the Traditional Knowledge synthesis report).
Conclusions
The Board was pleased that projects of the Study and those of the Peace-Athabasca Delta Committee could be undertaken closely together and that the Science Advisory Committee's services were available for both.
The Board concludes that enough is now known of the mechanisms responsible for flooding of the delta to make attempts to partially or fully return the delta to its natural condition of periodic flooding. The Board's studies, both scientific and traditional knowledge, have demonstrated conclusively that the flow regulation and operation of the Bennett Dam on the Peace River has altered the aquatic ecosystem to a large extent throughout the basin. Mitigation of these impacts in the absence of a natural flow regime has proven to be extremely difficult in the one area of the basin where attempts have been made (Peace-Athabasca delta). Many other areas, habitat types and specific reaches remain with unchallenged and dramatic impacts from the alterations to the natural flow pattern. The causes are complex, including possible factors such as climate change, and no results can be guaranteed. However, some modification of regulation of discharge from the Bennett Dam in late winter and spring, combined with high tributary flows, could be an element of major remedial plans.
Downstream effects and conditions as a result of development are important and must be considered in any development. Where effects result, the cost of mitigation and remediation strategies should be factored into the development.
For all reclamation schemes, public consultation with residents of the region is essential. They not only have a lot at stake, but are very knowledgeable about the complexities of the delta and its history of flooding. Moreover, they may feel that the future of the delta may not necessarily be designed to mimic the past; other land use options are available.
The Board recommends that:
The plan may also include full-scale delta flooding requiring modification of the flow from the Bennett Dam, which may mean possible impacts along the Peace River, notably at the town of Peace River. It may also result in denial of any additional hydroelectric development in either British Columbia, Alberta or the Northwest Territories if it has impacts on reclamation of the delta.
Dissenting views
A dissenting view was expressed by a Board member:
"It would be impossible to restore pre-regulation flow patterns to the Peace River without the removal of the W. A. C. Bennett Dam and the second dam that is downstream of the Bennett Dam. Further, it is very important that the level of the Peace River, at the town of Peace River, freezes over at a reasonably high level to ensure that the ice cover is not broken up during later, higher power generation periods. It is not reasonable to expect that B.C. Hydro would agree to eliminating power generation during their peak demand months of December, January, February, March and April. An additional issue is; how would the storage capacity of Williston Lake respond to the substantial reduction of discharge of water during the winter months?
Preamble
Rivers are integrators of natural factors and of human activities in the basins they drain. The fate of river ecosystems is critically dependent on what happens on land. The Study Board was frequently encouraged at its hearings to engage in studies of land management but was reluctant to go far afield from its mandate. Nevertheless, the Board repeatedly acknowledged the need for better understanding of the effect of land use patterns on the northern river systems.
In addition, the Board devoted some time in its various discussions to a few issues of land use management of particular relevance to the northern rivers, such as land clearing for agriculture and clear cutting in forestry. The Board noted in its discussions that legislation to ensure integration and coordination of land use management planning and water management planning is not in place for the northern river basins under current territorial or provincial legislation. The proposed new Alberta Water Act does not make explicit provision for the integration or coordination of land use and water management planning. Moreover, the June 1995 repeal of the Alberta Planning Act and subsequent changes to the Municipal Government Act have eliminated the role of regional land use planning in Alberta. Such integration and coordination as does occur at present is in the hands of an interdepartmental committee. Surprisingly, the solitudes of land use management and water use management persist despite widespread awareness of their interdependence. For example, the recently released Alberta Forest Conservation Strategy makes virtually no mention of the impact of forest management practices on the quality or quantity of water in streams and rivers or their effects on river ecosystems.
Northern Alberta has undergone significant development in the past few decades and there are prospects for further economic growth in the coming years. Extraction of oil from oil sands could significantly increase, forest harvesting and forest products manufacturing will probably increase, and agricultural land clearing will continue. Together with other developments, these activities will entrain increases in population and recreational uses of the region all with potential impacts on the northern rivers. These changes will take place during a period of world wide climate change in which the effects on the northern river basins area could be potentially greater than elsewhere in North America.
Conclusions
The Board wants to ensure that land use planning and water use planning are sufficiently integrated so as to ensure wise long term management of the natural resources of the northern river basins. This view is strongly supported by those who live in the basins.
The Northern River Basins Study was aimed at the waterways of the north. The Board recognized that the longterm effects of forestry, agriculture, oil and gas development and other land clearing in the Athabasca, Peace and Slave Basins are inadequately known and that these activities may have profound consequences for the aquatic ecosystem.
But the Board also realized that to undertake a detailed and comprehensive review of land use practices was beyond its time frame and resources. The necessary understanding can only be gained by the sustained and coordinated attention of the responsible government agencies.
The Board noted that several studies have been initiated over the past five years on various aspects of the impact of forest management practices on hydrology and other environmental concerns. It is important that the findings of these studies should be quickly incorporated into basin management planning.
The Board recommends that:
| a) | the effects on surface waters and the mainstem rivers of agriculture, forestry, oil and gas activities and other land clearing be reviewed on a continuing and comprehensive basis; |
| b) | all aspects of land use activities be scrutinized including land clearing, road building, channelization, revegetation, use of fertilizers and biocides and waste disposal; |
| c) | attention be given to groundwater levels, flow patterns in tributary streams and the integrity of fish spawning areas; and |
| d) | compounding effects of potential climate change and of atmospheric sources of contaminants be considered as important elements of context. |
Preamble
Water shortages are frequently foreseen as likely causes of national and international discord in the 21st century. Schemes for longer scale transfers of water from one region to another will be proposed, some of which may well be resurrections of schemes that have been proposed in the present century. There is a public fear, expressed through the householder survey and the Board's public consultations, that the waters of the northern river basins may be attractive for major diversions. With the likelihood of climate change their flow may be reduced at the same time as schemes for their diversion proliferate. The potential ecological impact of major diversions from the northern rivers could also have serious ecological and societal consequences.
Conclusions
The Board is strongly of the view that major diversions from the northern rivers should not be permitted.
The Board recommends that:
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