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Springbank Off-Stream Reservoir Project
Canadian Environmental Assessment Agency
Canada Place
9700 Jasper Avenue, Suite 1145
Edmonton, Alberta T5J 4C3


Thank you for the opportunity to comment on the Preparation of an Environmental Impact Assessment pursuant to the Canadian Environmental Assessment Act, 2012 in regard to the proposed Springbank “dry dam”.

Firstly, I ask that Elbow River flood mitigation be viewed more broadly than it is now. Alternatives to the Springbank reservoir project must be equally considered, including the McLean Creek alternative, the Tunnel from the Glenmore Reservoir to the Bow River, and dredging the Glenmore Reservoir to reclaim its capacity.  

The benefit of the Springbank project needs to be thoroughly examined. In the project description, section 1.1, the GOA implies that the project would benefit the entire City of Calgary, when in reality it benefits a small portion of the City, and does not benefit the communities of Bragg Creek and Redwood Meadows.  It also does not benefit, and could do significant damage to, the Tsuut'ina First Nation.

With regard to the specific environmental and social factors that need to be studied, please consider the following:

1. A thorough comparative analysis of all potential Elbow River mitigation options. Projects in the upstream portion of the Elbow River were dismissed early with little study.  The McLean Creek project is viewed by many to be a preferable project to Springbank, but has been dismissed by the GOA with minimal scientific study.

2. Public consultation has been inadequate under the current approach.   An example is the estimated current cost of the Springbank project which the GOA refuses to disclose, yet asserts it is the most cost effective project.  Feedback from attendees at GOA open houses held in 2015 overwhelmingly favoured McLean Creek over Springbank, but this has been ignored.

3. A thorough review of the environmental impacts of the project, including: 

·      Fish and wildlife impact.

·      Water quality in the Elbow River.  

·      Impact on groundwater.

·      Residual and cumulative impacts.  

4. Health hazards. The large, high-pressure natural gas pipelines underneath the land in question have been ignored and need to be addressed by the National Energy Board. 

5. Health hazards. The GOA submission refers to the potential for contaminants, including raw sewage, after the reservoir is drained.  I request that CEAA conduct a detailed examination of all potential health issues that could arise from the construction and operation of the off-stream reservoir project as there is significant population, including the Tsuut'ina First Nation, surrounding the proposed project.

6. Impact on Community.  CEAA is required to consider the lives and livelihoods of the residents whose land will be taken for this project. Also consider the long-term negative economic impact on Rocky View County.

7. Economic benefits of the project.  I suggest that the economic benefits cannot be considered in a vacuum – any such benefits must be considered in relation to the economic cost of the project.  The proponent should be required to provide CEAA with a comprehensive and up to date benefit/cost analysis of the off-stream reservoir project, which should be compared to alternatives for Elbow River Flood mitigation.

The proposed Springbank project will forever have a negative impact, both environmentally and socially, on the area and residents west of Calgary.   Thank you for your consideration. I look forward to a full and thorough review by an impartial federal authority.