Fracing the Bow River: “The most important resource in the province, and the rarest, is water” Then why let “No duty of care,” legally immune, led by Ex-Encana VP, Charter violating AER permit multinationals to frac it?

Protecting the health of Alberta’s Bow River by Roy MacGregor, October 11, 2015, The Globe and Mail

[Reality avoidance?

In such a comprehensive article about impacts to the Bow River, why leave out frac impacts, when it’s known that companies are sucking massive amounts of water out of the Bow River – without oversight – for drilling and fracing, including through the night when no one is looking?

2012 12 09 Frac'ers's taking water directly from Bow River, Alberta, under bridge hwy 22 at cochrane, under AENVs temporary diversion licence

2012 12 09 Frac'ers taking water from Bow River, under bridge hwy 22 s cochrane, under AENVs temporary diversion licence

2012 12: Above and below: Pump & hoses for two tankers taking water out of the Bow River at once

2012 12 09 Bernum Petroleum pumping water from the Bow under AENVs temporary diversion licence

2012 Pump for taking water out of the Bow River by Bernum Petroleum at boat launch, Cochrane, Alberta

A few examples in 2012 (as of 2013, the “No Duty of Care,” legally immune, Charter violating, 100% industry funded, Ex-Encana VP Gerard Protti Chaired AER now controls all of Alberta’s fresh water to give to the oil and gas and frac industry):

Alberta Government
Approval Documents Search
Protection & Enforcement
Alberta Government Licence to Temporary Divert water
Province of Alberta
Water Act, R.S.A. 2000, c.W-3 as amended

Licence # 00320975: 5,000 cubic meters [ 5 million litres] of water Dec. 06, 2012 – Jan. 31, 2013 Bernum Petroleum hydraulic fracturing

Licence # 00320608: 4,000 cubic meters [4 million litres] of water Nov. 23, 2012 – Dec. 31, 2012 Bernum Petroleum hydraulic fracturing

LIcence # 00320598: 500 cubic meters of water Nov. 22, 2012 – Jan. 15, 2013 Bernum Petroleum drilling

Licence # 00320715: 2,500 cubic meters [2.5 million litres] of water Nov. 27, 2012 – Dec. 23, 2012 Bonavista Energy Corporation hydraulic fracturing

2012 Water hauling trucks lined up at Town Cochrane potable water, sourced from Bow River

2012 Water hauling for drilling fracing, from municipal supply at Cochrane which comes from Bow River, 003

2012 Water hauling for drilling fracing, from municipal supply at Cochrane which comes from Bow River, 002

2012 Water hauling for drilling fracing, from municipal supply at Cochrane which comes from Bow River, 001

2012: Above, trucks at the Town of Cochrane, Alberta municipal potable water supply hauling water for drilling/fracing. Cochrane sources its water from the Bow River.

2012 12 02 Tanker hauling water for drilling, fracing, from Bow River, under Hwy 22 Bridge in Cochrane

2012 12: Hauling water for drilling/fracing directly from the Bow River under Hwy 22 bridge at Cochrane, Alberta

2012 12 Frac'ers' water taking hoses from Bow River, under bridge hwy 22 s cochrane, under AENVs temporary diversion licence 003

2012 12 Frac'ers' water taking hoses from Bow River, under bridge hwy 22 s cochrane, under AENVs temporary diversion licence 002

2012 12 Frac'ers' water taking hoses from Bow River, under bridge hwy 22 s cochrane, under AENVs temporary diversion licence 001

2012 12: Industry hoses under Hwy 22 bridge at Cochrane, Alberta, for taking water for drilling/fracing directly from the Bow River

Thirsty yet?

2012: AEA: Support to the identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe

A proportion (25% to 100%) of the water used in hydraulic fracturing is not recovered, and consequently this water is lost permanently to re-use, which differs from some other water uses in which water can be recovered and processed for re-use.

End Reality avoidance]

Here, beside the Bow River, it is possible to see for a century. In a special room at the Whyte Museum of the Canadian Rockies, an exhibition called “Legacy in Time” features the landscape photographs of the Vaux family – 100 years apart. In the years leading up to the First World War, Philadelphia siblings Mary Vaux, George Vaux IX and William S. Vaux spent their holidays photographing glaciers throughout the Canadian mountain range. A century later, George’s grandson, Henry Vaux, Jr., began shooting the same scenes for comparison.

In total, there are 13 dams, four weirs and eight reservoirs in what is, by far, the most-regulated river system in the province, likely the country. It’s understandable why Alberta’s favourite wilderness writer, the late Andy Russell, would call the Bow a “multiple-abuse” river.

And Calgarians clearly love their river. “We fish on the Bow, paddleboard and canoe and kayak on the Bow,” says Calgary aquatic biologist Francine Forrest. “When I see the river, it just brings me happiness. It’s a ‘vacation’ from the busyness of the city.”

In early September, the Bow River Basin Council gathered in Calgary to discuss the multiple concerns of this remarkable watershed. They met in a large room at TransAlta Corp., the modern name for Calgary Power. The council’s mandate is sustainability, a word of enormous and complicated meaning when applied to something with as many competing strings attached as the Bow River.

“Slow the hell down!” lawyer Judy Stewart, a former mayor of nearby Cochrane, warned developers.

As Calgary has boomed, it has spread westward as wealthy homeowners build ever-larger homes with, they hope, a view of the mountains. Development now nears the reservoirs that supply the area drinking water, and each year more and more ecologically valuable wetlands vanish under fill and pavement. “The city of Calgary has destroyed 90 per cent of pre-settlement wetlands,” Stewart says.

“The most important resource in the province, and the rarest, is water,” says Kevin Van Tighem, former superintendent of Banff National Park.

Mr. Van Tighem, author of a new book on the Bow River called Heart Waters, worries that infrastructure changes such as dams or more efficient irrigation usage is equivalent to “closing the barn door after the horses have left,” and he is hardly alone.

“Water comes to the river,” he argues. “It doesn’t come from the river.”

Clear-cut forestry causes quick runoff, as does the pounding and rutting of the landscape by off-road vehicles. Scientists such as John Pomeroy, who spoke to the council gathering, say that climate change is causing snow melts to come earlier and earlier, meaning water is racing through the system before it is needed for planting and reduced, at times sharply, when it is most needed. Glacier melt, says Dr. Pomeroy, is no longer a significant factor later in the growing season.

Despite the havoc of the 2013 floods that struck Canmore, Calgary and High River with such vengeance, causing more than $5-billion in damages, Dr. Pomeroy and other scientists fear that the West of Canada, like California, has entered a period of higher temperatures, little rain and drought conditions.


Recent work completed by World Wildlife Fund Canada found that the Bow scored “poor” in terms of overall health of the watershed, “fair” for water quality and “good” for fish health. As far as threats to the watershed, the conclusion was “very high” given the overuse of its waters, the continuing pollution from agriculture practices and the potential for pipeline incidents. [But frac’ing is left out of the impact discussion?]

“The Bow River is beautiful, and important culturally, historically and economically,” said David Miller, the former mayor of Toronto who is now head of WWF-Canada. “While it is the most regulated river in Alberta [but not for frac impacts], the risks facing it were not well known. After our assessment we found that over all, the Bow River is at a high risk. We need to start raising awareness about these issues.”

“I don’t think it’s an example of an efficiently well-managed river by any means,” says Robert Sandford, Canadian chair of a United Nations initiative that advocates long-term protection for water quality. “If drought conditions continue,” warns Mr. Sandford, “agriculture could be in decline.” 

Dr. Pomeroy also believes the Bow has to be managed more efficiently. The 2013 devastation was called the Flood of the Century, but he says this is a “deception” – as at least twice in the previous century there were greater floods.

“Downtown Calgary,” he says, “should never have been put where it is.” But since downtown Calgary will remain where the Bow and Elbow rivers converge, better planning, monitoring and preparation will be required in the years to come. “We must be better at managing water better,” he says, “and avoiding another event like the 2013 flood.”

It is not only infrastructure that is required, in Dr. Pomeroy’s opinion, but thinking. Climate change is bringing vast changes, potentially in every direction from drought to flood, and yet so many people and politicians seem in denial.

“We built Canada on water,” Dr. Pomeroy says. “The fur trade, industry, agriculture – and yet we take it all for granted. We’re going to struggle if we don’t pay attention to it. In part, we need to stop describing our water as ‘bountiful.’

“I’m not so sure it is anymore.” [Emphasis added]

[Refer also to:

2006 09 6-11: ROSENBERG INTERNATIONAL FORUM ON WATER POLICY, FORUM V, BANFF, CANADA SEPTEMBER 6 -11, 2006, PROGRAM SYNOPSIS & LESSONS FOR CANADA & ALBERTA 99 Pages by Henry Vaux Jr., Chair, Rosenberg International Forum on Water and Policy Analysis, and Robert Sandford, Chair, United Nations Water for Life Decade Canadian Partnership Initiative

2012 09 6-11 Rosenberg International Forum, Lessons learned for Canada & Alberta, Banff, Vaux, Henry Jr., Bob Sandford


The Rosenberg International Forum on Water Policy was created in 1996. It is named for Richard Rosenberg, former Chairman of the Bank of America. Upon Mr. Rosenberg’s retirement in 1994, the Bank of America endowed the University of California in his name with resources to help support an invitational biennial water forum for the world’s leading water scholars and senior water management practitioners. The main thrust of these Forums is the resolution of conflict emerging from trans-boundary water issues. The first of these Forums were held in San Francisco, U.S.A.; Barcelona, Spain; Canberra, Australia; and Ankara, Turkey.

The 5th Biennial Rosenberg International Forum on Water Policy was held in Banff, Canada between September 6th and 11th, 2006. The principal sponsors of the Rosenberg International Forum on Water Policy are the University of California and the Bank of America. Local co-sponsors for the 5th Forum included Alberta Environment, Alberta Ingenuity Centre for Water Research, Alberta Irrigation Projects Association, The Banff Centre, The Max Bell Foundation, The Calgary Foundation, the Columbia Basin Trust, Zaragoza EXPO2008 and the United Nations Water for Life Decade initiative in Canada.
Participants in the Forum included 52 scholars and water managers from 24 countries.

There are seven over-arching lessons for Albertans and Canadians from the Rosenberg International Forum on Water Policy that was held in Banff in the fall of 2006.

1. Canada is not as advanced as it might like to believe in terms of public policy relating to water supply and quality assurance. There are issues of equity; inefficiencies associated with jurisdictional fragmentation of responsibility and accountability; an absence of reliable and commonly useful data and widespread examples of inadequate foresight and management of water in the context of other forms of resource development. There are many gaps in federal and provincial water management policy that need to be filled. The country needs to move past its own myths of limitless water abundance to create a new national water ethic based on conservation and different formulae for valuing water as a resource in its own right.

2. Compared to other places in the world, there is not yet a water crisis in Alberta or in the Canadian West. But Alberta, in particular, has all the makings of one. These elements include:

• Heavy agricultural reliance on water
• Rapidly growing populations
• Increased water demand from cities and industry
• Reduced flows in important watercourses
• Unpredictable climate variability

3. There are others from whom Canadians and Albertans can learn. Canadians should vigorously pursue access to global knowledge and experience, so that we do not make the same mistakes others have made. The old saying is true. Every time history repeats itself, the price goes up.

4. Though highly significant in a Canadian context, the Alberta Water for Life Strategy is not unique. Approaches similar to this have been explored in many other countries with varying degrees of success. It could become unique, however, simply for having been fully implemented. Such implementation, however, will require political support and appropriate funding.

[Repeat Reality Check:

What did Dr. John Cherry say in 2002?

2002 Dr John Cherry in CCME report Huge gaps No strong incentives to avoid groundwater contamination

2002 CCME report chapter 4 by dr john cherry hilted

2014 04 30 CCAs Dr John Cherry Ignored His own 2002 CCME report Chapter 4 laws regs weak, lack of enforcement

End Repeat Reality Check]

5. Politics aside, the measure of Canadian water management success will be determined – not by what is said – but by what is actually done, in support of Water for Life and other water management initiatives.

6. Alberta presently has the resources to go right to the front of the world queue and get the management of water right.

7. The final lesson is that the longer policy makers in water scarce areas like Alberta wait to change their water management frameworks, the more investment there will be in current systems and the more difficult it will become to make needed changes. Alberta should move now while there is still slack it can take up in its systems and before it is facing crisis.

The world is watching. As Leith Boully, an Australian water policy expert said at the conclusion of the Rosenberg International Forum on Water Policy held in Banff in September of 2006, “Because of our current good fortune, Canada has a greater obligation than other countries to act soon, and appropriately.” 


2007 REPORT OF THE ROSENBERG INTERNATIONAL FORUM ON WATER POLICY TO THE MINISTRY OF ENVIRONMENT, PROVINCE OF ALBERTA 26 Pages February 2007 [Of interest, notably since the Alberta government and regulators knew in 2004 that companies were illegally frac’ing drinking water supplies in Alberta, hydraulic fracturing is not mentioned once in this vital report] 


CHAIR: Professor Henry Vaux, Jr. University of California, Berkeley (economics of water resources)

Professor Helen Ingram, University of California, Irvine (water institutions & governance)

Professor William Jury, University of California, Riverside (soil & water science)

Professor Ramon Llamos, The Polytechnic University of Madrid (groundwater hydrology)

Professor Paul Perkins, Australian National University (water management and the use of technical information)

Dr. Alphonso Rivera, Environment Canada (hydrology and water management)

Professor Ben Rolston, University of Alberta (hydrology and water resources)

Mr. Robert Sandford, Chair, United Nations Water for Life Decade, Canada (water resources of Canada and their history)

Professor Uri Shamir, Israel Institute of Technology, The Technion (hydrology and water management)

Mr. Peter Watson, Deputy Minister, Alberta Environment [After covering-up and enabling Encana breaking the law and fracing Rosebud’s drinking water aquifers and contaminating water wells with natural gas, now Chair of the National Energy Board. Reward?]
Ms. Bev Yee, Assistant Deputy Minister, Alberta Environment [After years of helping Peter Watson cover-up and enable Encana’s law violations and abuses, now synergizing the Canada Water Network into pushing fracing on all Canadians with Dr. John Cherry and the University of Calgary (oil and gas industry controlled) et al via shoddy science and lies, setting up nature to take the blame for fracing releasing natural gas into drinking water supplies across the country, and repeating the same empty promises to study and monitor the harm to water from unconventional oil and gas]
Ms. Nga de la Cruz, Senior Hydrologist, Alberta Environment [now retired, after also enabling Encana’s law violations and abuses]
Mr. Colin Fraser, Hydrologist, Alberta Environment
Mr. Rob George, Groundwater Quality Specialist, Alberta Environment [also enabled Encana’s abuses and law violations, notably the company illegally perf’ing and frac’ing in multiple fresh water aquifers]
Dr. Kevin Parks, Provincial Geologist, Alberta Geological Survey [Listed as an expert witness to testify to Parliamentary Committee in May 2007 with Ernst and Schwartz, but cancelled the night before]
Ms. Kate Rich, Manager, Water Strategy Office, Alberta Environment [1995 Master’s of Science on gas migration problems from the oil and gas industry’s leaking wells, who to the best of Ernst’s knowledge, never publicly spoke out about Encana’s abuses frac’ing Rosebud’s drinking water aquifers and never gave any harmed residents any help: Download – ERA – University of Alberta]
Ms. Heather von Hauff, Groundwater Quality Specialist, Alberta Environment [In June 2007, supervised Alberta Environment’s gas sampling of Ernst’s dangerously contaminated water and what was previously Lars Lauridsen’s and Debbie Signer’s water. During sampling of Ernst’s water, Heather couldn’t hide her shock at how much gas was present and recommended that Ernst hook up the gas to heat her home (which is illegal)]

….failure to manage water effectively may limit social and economic development in the future and make water scarcity problems in Alberta worse than they need to be. 

9. Data Acquisition and Monitoring
The existing network of groundwater monitoring is insufficient to provide reliable information on water quality and water levels and their variability. Without a more comprehensive monitoring network, it will be very difficult to achieve the goal of ensuring safe drinking water, healthy ecosystems, and reliable water supplies. Monitoring networks need to be installed – and sustained over time – at a density sufficient to ensure proper tracking of level changes and a high probability of detecting contamination before it has spread over a large area. A proactive approach to monitoring should include on-going measurement of contamination indices in the vicinity of agricultural, industrial, and municipal operations that have the potential to pollute ground or surface waters. Such an approach will almost always be cost effective because it will greatly decrease cleanup expenses. In addition, ecological indicators need to be identified and monitored to ensure that adverse ecological changes are detected early in their evolution.

Recommendation: The monitoring networks for assessing the quantity and quality of both surface and groundwater need to be expanded and strengthened. Monitoring networks and indices for assessing ecosystem health also need to be developed and implemented. Monitoring networks need to be maintained over time and be sufficiently dense to allow trends to be measured and analyzed and to permit early detection of contamination episodes.

10. Water-Related Activities and Policies

In the management of Alberta’s economy, water should be viewed as being every bit as important as oil. Evolving water policy should be proactive in anticipating the needs and demands of a growing economy rather than simply providing reactive response to resource development and population growth and pressures. Only by being proactive and anticipatory can water managers and policy makers ensure that the availability of water and water quality do not limit economic and social development in the future. The exploitation of Alberta’s energy resources is proceeding at a pace much faster than had been anticipated. There has been no parallel acceleration in the research upon which protection of the associated water resources could be based.

Recommendation: In the face of accelerated energy production and population growth all efforts should be made to advance the research and regulatory activities needed to protect water resources that could be threatened.

Managing and Governing Groundwater
In Alberta: A Review

Groundwater, which does not respond directly to variations and extremes of precipitation and run-off, will become increasingly prized as a particularly reliable component of the total water supply.

As groundwater becomes increasingly important in the water budget of Alberta, new attention will have to be focused on its management. Existing management and governance arrangements are not adequate to respond to contemporary pressures. Groundwater is not adequately monitored; its availability and the quantities of water extracted are not carefully measured or recorded; and, the regulation and control of groundwater exploitation could be improved. In short, existing governance and management institutions must be strengthened to prevent the “Tragedy of the Commons” which may result when the use of common pool resources is governed by the law of capture and characterized by competitive exploitation. In addition, it will be important to recognize that maintenance and protection of groundwater quality will be a critical element in any effective management strategy.

The development and projected exploitation of oil sands and coal bed methane are likely to pose special threats to both groundwater quantity and quality. These threats will be exacerbated unless both public and private stakeholders remain fully accountable for any adverse environmental consequences that result from their activities. It will be essential to integrate water protection policies into broad resource development strategies and decisions. There is a compelling need for plans to manage unforeseen as well as foreseeable environmental impacts stemming from the development and expansion of the energy industry. The livestock industry and irrigated agriculture will also continue to pose threats to groundwater quality.

If Albertans are to protect and enhance their groundwater resources so that they will be available in the future as a reliable source of fresh water, they will have to develop and implement a strong groundwater management and protection program. Pumping quotas, taxes and extraction fees are examples of the kinds of economic incentives that can be used to regulate and protect groundwater resources. All policies and implementation actions should be fully consistent with the “polluter pay principle” which is implied in most efforts to regulate pollution worldwide. Such policies should be realistically scaled and realistically implemented.

The three major objectives in the Water for Life strategy are likely to drive concerns about groundwater:

• securing high quality drinking water supplies for populations mainly located in southern Alberta, which only has 17% of the province’s surface water,
• maintaining healthy aquatic ecosystems,
• securing reliable water supplies of appropriate quality for resource development.

As groundwater supplies are developed and used, care should be taken to address environmental problems that will inevitably result.

Although oil sands, coal and coal bed methane developments are very important to the future of Alberta and Canada, their very size and complexity pose potential threats to the groundwater resource. Some environmental impact analyses of these activities have been completed but they do not always address the entire range of impacts and especially cumulative effects.

Moreover better information about the threats to groundwater quality and quantity is needed as there is significant risk and uncertainty which is incompletely understood by the public.

[Reality check that the water “experts” keep repeating:

2002 Canadian Council of Ministers of the Environment need baseline hydrogeological investigations to track contaminants

End reality check]

These risks and uncertainties cannot be comprehensively addressed in a groundwater management plan alone because they transcend traditional parameters of groundwater management. Surface water/groundwater interactions must be accounted for as to the important interrelationships between groundwater, land use and other natural resources.

Alberta’s groundwater resources may play a critical role in defining future economic development. Decisions on problems must be made irrespective of whether the underlying science and data are available. The Ministry must be vigilant so as to be prepared to respond to emerging problems even while making efforts to improve the available science and data on groundwater.

Governance of groundwater in Alberta is hampered by a number of factors. The absence of long-term monitoring and the data that it yields hampers scientific decision-making. Management cannot be effective without knowledge of such key characteristics as recharge rates, draw-downs, and actual and potential sources of contamination. … Moreover, governing agencies lack both the financial resources and sufficient qualified staff to compile and analyze the limited data that is presently reported, thereby hampering the development of effective management options. … The assessment of cumulative impacts on groundwater will be especially important. Just as importantly, such assessments need to be open and transparent. [In Alberta? Where has that ever happened?] In addition – and of equal importance – there should be efforts to acquire the appropriate hydrological, geological, biological and other appropriate information needed by managers in districts of concern. The effectiveness of governance will depend crucially on the availability of this information.

It should be recognized that the husbanding and management of groundwater resources is an emerging responsibility that will require additional resources and personnel whose skills are appropriate to the task. It would be a mistake to try to address the many facets of the groundwater management challenge with existing resources which are clearly inadequate. It will also be important to acknowledge that groundwater, like surface water, is linked across many sectors of the Province and therefore across different Ministries. Housing, transportation, agriculture, forestry and energy development are only a subset of the various activities that will, in the future, have important impacts on groundwater. 

IV. Monitoring, Data Management and Tools for Interpretation
Alberta is developing rapidly, and groundwater use is expected to increase markedly in the future. It is vitally important that the spatial distribution, volume, present quality, and hydrologic connectivity of the groundwater resource be characterized and subsequently monitored to determine changes in storage and quality while changes are occurring. Only when the entire groundwater resource has been analyzed will it be possible to manage Alberta’s water resources effectively and optimally in the presence of substantial development and increased use.

To reach this goal, the groundwater management plan of Alberta’s Water for Life strategy needs to include practical, yet modern and scientifically-based tools to survey, monitor, access, integrate and use ground and surface water data as well as land use, climate variability and water quality.

Although capital expenditures to create a comprehensive network to monitor groundwater levels and quality may seem high, they are invariably a bargain compared to costs for remediation of contamination if not detected early. Similarly, because response times are often quite slow in groundwater systems, it is important and highly cost-effective to develop the capability to detect changes in water levels on a continuous basis, so that rates of water use may be adjusted, if necessary, to ensure that the supply is not depleted considerably before action is taken. 

Beyond its role in assessing the reliability of groundwater supply, the monitoring network is the last line of defense against contamination by industries that are essential to the economic future of the Province. Alberta is embarking on an ambitious plan of oil and gas extraction that will require substantial water withdrawals and quality deterioration that has the potential to seriously contaminate ground and surface waters if protective measures should fail. For this reason it is important to have a comprehensive early warning system for detection of contamination from each operation before it has had a chance to migrate and disperse over a substantial volume of groundwater.

Data Management
The third component of groundwater monitoring and assessment is data management. The groundwater management plan includes provisions to build a groundwater information centre as a water data warehouse. However, this should be more than a storage facility. The ‘centre’ should be designed as a full inter-operable facility where data is not only stored but can be shared with multiple users. This can only be accomplished if the database is designed to be compatible with international standards for data recognition and transfer. …

Development of a comprehensive monitoring and data management plan for Alberta’s groundwater is best achieved in stages. [Like Alberta Environment removing the historic baseline water well data on file in 2010 and replacing it with altered data that removed whether or not gas was historically present and refusing to release the after-aquifer fracing “baseline” data collected by oil companies, not even in response to FOIP requests?]

The Alberta Water for Life Strategy:
Strengths and Weaknesses


Strategic Considerations
• Though holistic in design, the Water for Life strategy’s approach is incomplete. For example, the plan does not account sufficiently for groundwater or the relationships between water-air-land.
The importance of equity or fairness is not explicitly acknowledged or specifically addressed in the strategy. Equity will be increasingly important in gaining public compliance should the province be faced with the introduction of rationing programs and other water economizing measures.
The lack of timely public funding and other public resources to support the evolution and implementation of the strategy is a major weakness. (Collaboration takes organizational attention and the time of people who are in government, not just volunteers. Without proper and timely funding for the initiative both inside and outside government, all gains made to date could be negated.)

The linkages to water law and regulation in the strategic plan are weak or non-existent.

• Similarly, the strategy should acknowledge the role and uncertainty of variables that drive demand for water such as population growth, changes in technology, and changing patterns of industry.

• Water quality issues are not adequately addressed in the strategy. Thus, for example, the strategy should adopt the “polluter pays” principle, and in addition look for opportunities to apply the precautionary principle in partnerships in which there is apparent risk to water quality.
• It is essential that the Water for Life strategy consider watersheds and aquifer systems together as the focus of management. Integration of these is essential if conjunctive use opportunities are to be addressed effectively.
Reference to water sensitive urban planning is missing in the strategy. This is necessary to minimize the negative effects of urbanization on watersheds and their related water resources.

Cooperation and Collaboration and Governance
• The cycle time for the strategy is too long to maintain community interest. (Because it is not funded and is reliant on volunteer effort, public engagement will erode and thus collaborative opportunities will be lost.)
The words “accountability” and “consistency” are missing from the discussion of governance.
• The structure and role of the Alberta Water Council is still evolving. The structure, membership and operations are unclear and need to be refined over time.
• There should be more representation on the Council for the public.
• The evolution of the strategy and its implementation through the action plan needs to be publicly open and transparent.

Monitoring, Data and Measurement
The strategy should acknowledge that the lack of comprehensive monitoring systems is a critical weakness. Existing monitoring systems, especially those for groundwater, are inadequate and without effective monitoring the goals of the Strategy (safe drinking water, healthy ecosystems and reliable supplies) cannot be achieved.

• Timely interpretation of monitoring data is essential but unmentioned in the strategy.

• It will be critically important to develop an inventory of water users, water uses and water rights.

Science and Research
• The linkages between science and policy in the Strategy are weak.



2014 08 28 CAPP's Alex Ferguson admits coalbed methane contaminated well water, in some more infamous cases, landowners could set their water on fire

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