January 28, 2022

5616 54a  Ave.

Rocky Mountain House,

Alberta, T4T 1H6

Nixon, Jason, Honourable
Minister of Environment and Parks, House Leader,

323 Legislature Building
10800 - 97 Avenue
Edmonton, AB
T5K 2B6

Subject: Follow up to my letter of January 13, 2021 regarding Prairie Creek Frac Water Diversion

Dear sir:

In my continuing investigation of the Water Diversion from Prairie Creek SW of Rocky Mountain House Alberta I learned:

1] A Permit [ # 00480667 ] to Temporarily Divert Water was issued December 29, 2021.

2] Between then and early January water was pumped to two large holding tanks which to date have not been used.

3] Two Kilometers west was another active Frac which was pumping water from the Ram River approximately 40 kilometers away.

4] The Permit issued used the flows in the Clearwater River to establish maximum flow rates even though the Clearwater River

headwaters lie in Banff National Park whereas Prairie Creek headwaters do not extend past the first range. These are two distinct

different drainages with obvious different atmospheric conditions.

5] While there exists a Metering Station [ 05DB002] on Prairie Creek, the accuracy of the station is suspect by the end of October

due to either anchor ices, stream ice cover or level indicator freezing. However, the information available at the station during the

third week of October seems reasonable and accurate. The flow rate recorded of 1.2 m/s prior to ice cover likely drops to near 1 m/s.

6] The Surface Water Allocation Directive [SWAD] requires a diversion to retain 95% of the stream flow. If one uses a 1 m/s [ meters/second]

maximum flow rate at 95% which yields a maximum rate of 0.05m/s as specified in the Diversion Permit. However, the flow rate at the

Meter Station does not reflect the flow rate at the Diversion Point. From the Meter Station to the Diversion point, there are several

tributaries such as the South Fork of Prairie Creek, Swan Creek, several small seeps plus a very large spring that enters Prairie Creek

at 52 12 13N 115 03 14W which contributes approximately 50% of the winter flows of Prairie Creek.

7] If one uses a prudent flow at the Meter Station of 1 m/s and utilizes the Desktop Method as specified in SWAD then subtracting

the flows from the Meter Station to the Diversion Point approximately 20 kilometers upstream, one should subtract the following:

Swan Creek – 0 .1 m/s

South Fork of Prairie Creek – 0.1 m/s

The Spring – 0.4 m/s

Various seeps – 0.006 m/s

For a total of 0.606 m/s

Therefore at the point of Diversion the flow rate would be 1 m/s  - 0.606 m/s  = 0.34 m/s

A retention of 95% as required by SWAD means the permit should have been issued for 0.017 m/s not for 0.05 m/s. It will never

be known if the prime spawning areas approximately 2 kilometers downstream of the Diversion were destroyed by the diversion.

While the incorrect amount is one issue, there exist(s) several interesting issues arising from this permit issuance.

1] I worked in the Oil/Gas industry for near 40 years in a number of positions and rarely does the industry look for things to do

over the Christmas season unless absolutely necessary. A Permit issued December 29 seems quite out of character for the industry. 

2] The retention tanks were filled and are now frozen suggesting this was either a cancellation of the frac or the water is not required

for some time. Relying on nature to thaw the tanks means the water may not be useable till mid-May some 4.5 months later. A diversion

in May, with the history of water flows in Prairie Creek revealing much higher flows would have resulted in much lower risks to the aquatic life.

3] This is the first time where a frac water diversion permit was issued for a stream as small as Prairie Creek in the Rocky Mountain House

area. Prairie Creek, by issuance and diversion is no longer a virgin. Does this mean that AER and Sustainable Resources are going to allow

more medium sized foothills streams to be deflowered? Typically, Frac Diversions are allowed only from larger rivers like the Clearwater,

North Saskatchewan, or the lower Ram River. As Shale Gas deposits tend to be in the same areas of streams the size of Prairie Creek, is

this an attempt to shift Frac Water Diversions to small and medium streams.

4] It is extremely curious that about 2 kilometers west of the Prairie Creek Diversion was another active frac who were pumping water

40 kilometers from the Ram River. Why?

5] Prairie Creek was identified as a 5/6 Classified Stream. I could not find anyone in either the Sustainable Resources or AER who could

detail the criteria for classification. The email from Rieanne Graham of the AER says at the point of Diversion on Prairie Creek is a 5/6

however, SWAD says each tributary adds 1 meaning WHAT?

In conclusion, as demonstrated by the issuance of the Diversion Permit, SWAD is incapable of protecting the fisheries resources

utilizing the Desktop Monitoring Process.  Further, the change from larger rivers to smaller streams is very concerning as they are unde

r increasing pressure of low water and high temperatures. As a result, the only conclusion that can be drawn, discontinue the issuing of

any Frac Water Diversion for small and mid sized streams in Alberta until SWAD can be reviewed and modified to protect streams from fish kills.

A personal aside: : After moving to Rocky Mountain House in 1970, this river reach
2 kilometres downstream of the diversion was the first habitat project I ever
organized in 1972. We planted willow bundles along the stream edge to preserve
the banks. It was then, and has continued to be, a popular and cherished brown trout fishery, attracting anglers from across the province. 

Fishing was banned from the same section to protect the spawning trout.

Then along comes Frac Water Diversion!

Regards,

Don Andersen

donandersen@bamboorods.ca  403-844-3924

CC: Savage, Sonya, Honourable
Minister of Energy, Deputy House Leader
Office of the Minister

minister.energy@gov.ab.ca