On April 24, 2026, Markham Hislop of and Energi.Media joins me, Jenny Yeremiy of The Gravity Well podcast, at the Montgomery Community Association from 6:00 pm - 8:00 pm. Join us for a night of reflection and revision for Alberta based on our research and conversations with experts, advocates, and professionals. Each podcaster will share our current efforts to educate and ignite a better future for our province, enriched by a conversation between us. A Q&A will follow for audience members.

Get Your Tix Here!

Itinerary:

• 6:00 pm-Doors Open

• 6:30 pm-Speaker Introductions & Insights

• 7:00 pm-Dual Podcast Discussion

• 7:30 pm-Audience Q&A

What to Expect

Drawing on both Jenny’s and Markham’s 25+ years working in or reporting on the Western Canadian oil and gas industry. The discussion will explore how intensive and poorly tracked industrial water use, including fracking withdrawals and large-scale injection, is depleting Alberta’s water table and contributing to broader “water bankruptcy” amid shrinking glaciers, reduced snowpack, and drought impacts on vegetation and agriculture.

The event will also examine the tight linkage between energy and water—given that most energy use involves water movement—and argue for a shift toward water restoration as a core policy and industry priority.

On the energy side, Markham will challenge Alberta’s dominant narrative of rapidly expanding LNG exports and doubling oil production, presenting evidence that Asian oil and gas demand is peaking or slowing due to electrification, petrochemical trends, and the region’s strategic move toward electricity-based energy security, especially in response to recent geopolitical shocks and war-related supply disruptions.

The conversation will highlight how massive new global LNG capacity, falling prices, and Canada’s high-cost position undermine the case for new pipelines and LNG plants, calling instead for a risk-based approach that recognizes shifting Asian markets and the likelihood of overbuilt, stranded infrastructure. A further focus will be Alberta’s vast, under-addressed environmental liabilities—estimated at $260 billion—including inactive wells, contamination plumes, and the industry’s reluctance to fund remediation, alongside insider accounts of professional silencing, career repercussions for raising liability concerns, and even alleged strategies to use political separation to evade cleanup obligations.

Structured as short opening presentations followed by a recorded dialogue and audience Q&A, the event aims to equip attendees—industry professionals and the public alike—with a clearer understanding of how misjudged global demand, mounting liabilities, and unsustainable water use intersect, and why collective pushback and new perspectives are urgently needed in Alberta’s energy conversation.

Markham Hislop

A Canadian energy and climate journalist. He hosts the Energi Media podcast, conducts video interviews with experts from around the world, writes the Markham On Energy political analysis column, and writes about the energy future. He is frequently interviewed on Canadian radio about energy transition issues.

Energi Media is your go-to source for understanding the energy transition in Alberta and abroad. His channel is dedicated to providing insightful journalism, strategic advocacy, and community engagement that empowers Albertans to embrace a new energy future. Expect a variety of compelling content, including in-depth interviews, reports, and explainer videos. Covering topics like the energy transition, economic diversification, and the shift from oil and gas to renewables. Whether you're a professional, policy maker, or informed citizen, our channel offers insights and strategies for engaging with Alberta's energy future.

Subscribers gain from our narrative, "The Future is Electric," highlighting technology, economics, and policy in creating a sustainable energy landscape. Together, we'll engage, communicate, and persuade for a brighter energy future. Subscribe now and join the movement!

Jenny Yeremiy

Jenny is an Albertan, partner, mother, and friend with 25 years of development and liability (asset retirement) experience as a Geophysicist in the Alberta, British Columbia, and Saskatchewan Oil and Gas industries.

Jenny grew up in Edmonton and St. Albert, then moved to Calgary in 2000 to join “the patch.” She has drafted energy, environment, and economic policy which put water and land stewardship laws, regulation, and enforcement front and center.

She is a full-time activist focused on preserving nature and healing relationships with all life here in Alberta, the Bow Bioregion, Treaty 7, and Métis Districts 5 and 6.

Jenny hosts The Gravity Well podcast to celebrate and share the stories of the people looking out for our home and to empower the Alberta community with the knowledge and skills required to reestablish stability in our communities and ecosystem.

Get Your Tix Here!

Share the event with your network!

See you there.

LETHBRIDGE, AB - DECEMBER 12, 2025 – Corb Lund announced today that Elections Alberta has notified him that his previously approved citizen petition initiative against coal mining in Alberta’s Rocky Mountains has been cancelled.

“This morning, we were informed that our approved application for our petition to prohibit any new coal mining in the Rockies has been retroactively cancelled. We will now need to reapply under new, more stringent regulations,” says Lund.

Lund says that just two weeks ago, Premier Danielle Smith stated her support of citizen-initiated referendums.

“Our Premier said that it is really important that people have their say and that the rules are out there, and that she will watch with great interest,” says Lund. “So I guess the rules weren’t ‘out there.’”

“This kind of behaviour by government is disappointing and fundamentally unfair, but we will continue and reapply for a new petition and fill out as many forms as we have to, to allow the voices of Albertans to be heard to stop coal mining in the headwaters of Alberta’s Rocky Mountains.”

Lund says momentum for the citizens’ petition against coal has been gaining support across Alberta, and although signatures and canvassers cannot be gathered at this time, he encourages Albertans to express their interest in becoming involved at the newly launched website: https://www.coalpetition.ca.

MORE INFO:

Bill 14, introduced by Alberta Justice Minister Mickey Amery, proposes significant changes to citizen referendum rules and the powers related to citizen initiative petitions. Key changes include:

• Transferring decision-making power over citizen initiative petitions from the independent Chief Electoral Officer to the Justice Minister, raising concerns about separation of powers and potential partisan influence.

• Removing the Chief Electoral Officer’s ability to refer citizen initiative questions to court, consolidating that power with the minister and cabinet.

• Restricting political party names to prevent use of certain words associated with other parties, aiming to reduce voter confusion.

• Quashing any citizen initiative petitions not issued before the amendments take effect, but allowing resubmission within 30 days without an additional fee.

The bill has faced criticism from the Chief Electoral Officer and opposition parties for undermining democratic processes and the independence of Elections Alberta. Amendments were made to address some concerns, but debates continue regarding the balance of power and the impact on democratic trust.

STATEMENT FROM CORB LUND:

“Two weeks ago, Premier Smith said, “I support citizen-initiated referenda - I think it’s really important that people have their say. So the rules are out there and I’ll watch with great interest.” Earlier this week her office echoed that.

This morning we were informed that our approved application for our petition to prohibit any new coal mining in the Rockies has been retroactively cancelled. We will now need to reapply under new more stringent regulations. Apparently, the rules weren’t ‘out there’ after all.

This kind of disingenuous behaviour by the government is disappointing. But as frustrating as this is, we will continue in this fight, reapply for a new petition and fill out as many forms as we have to if it stops coal mining in the headwaters of our rivers.

Meanwhile, Premier Smith said a few days ago on the Ryan Jespersen show that we should take yes for an answer and that the government has addressed the coal issue.

But Mine 14 near Grand Cache has been approved after having had its public hearing unilaterally cancelled by the AER. Grassy Mountain is in the application process. As is the Blackstone mine, which is in the Bighorn region in the headwaters of the North Saskatchewan River, which feeds the city of Edmonton. And the Aries project near the Ram River, is waiting in the wings.

Albertans want no new coal mines of ANY KIND in the Eastern Slopes of our Rockies, full stop. This is why we are (re)launching our petition.

I thank everyone who has reached out in support of this citizen petition against coal and encourage you to visit at the newly launched website

https://www.coalpetition.ca to express your interest

Sincerely,

Corb Lund

A crowd of more than 70 Albertans gathered in Warburg, Alberta and received a warm welcome from Carl and C4RE campaign leader Mark Dorin. We were there to learn about the Government of Alberta’s im-Mature Asset Strategy (MAS). Brian Jean’s Chief of Staff plus Political Third Party Advertiser, Vitor Marciano, and the Premier’s advisor plus Alberta Energy Regulator board member, David Yager, presented the government’s MAS strategy for oil and gas liabilities. In short, no MAS! Thanks for the line, Phil.

As I offered Vitor and the crowd in Warburg, a MATURE asset strategy would include a plan to prevent ecological collapse via site restoration. The audience would see the best producers and worst offenders outlined with a plan to address the MOST urgent site closures across the province for decades to come. A $260 billion economy, in wait because the Alberta Government and Regulator are both captured by industry and focused on the profitability of mostly foreign investors rather than the safety of Albertans.

The Rural Municipalities of Alberta (RMA) was present to ensure that the government did not misrepresent their support of MAS. The Alberta Surface Rights Federation offered the government a simple plan to acquired financial deposits: apply a moratorium exactly like the one imposed on the renewable industry in 2023. Landowners shared their stories about cattle dying due to venting, and unpaid surface lease rentals MONTHS after submitting formal requests through the Land and Property Rights Tribunal (LRPT). Vitor had suggested that unpaid lease payments may serve as a LEADING (oops!) indicator for the AER to intervene. I asked David Yager what deposits or forfeitures the AER has completed since his arrival. He took a couple minutes to say, “Zero”. The former head of the RMA Paul McLaughlin saved his comments until the end, he explained it is clear there is no support in the room for MAS which clearly is Premier Smith’s R-Star program rebranded. He said its time the government starts over to include the people of Alberta. Hear, hear!

Feedback from Calgary on the Forever-Canadian.ca campaign

I organized two Forever Canadian events in the past two weeks, one on the northside of the Edworthy Park bridge and one at the Memorial Drive (or Calgary Curling Club stairs), great locations! The people who sign are amazing, they’re both excited and grateful. And the energy of the campaign is like magic, “Good trouble” as Tami Smith of likes to say. There is, however, a common irritation among a significant portion of the population. I hear, “we shouldn’t have to do this” or “this question is misleading because Alberta is already within Canada.” For the first question, tell me about it. None of the volunteers are getting paid but believe in the concept of social democracy. As for the second—wut? In order to remain a part of something you need to be a part to begin with—yes. I am in Smokey Lake next week for the ACFN’s Inaugural Decolonizing Land & Water Summit and will return to FC action the week after next.

Upcoming Events

September 13th: Calgary Unitarians Fall Faire

VOLUNTEER OPPORTUNITY: The has been invited to the Calgary Unitarians Community Fall Faire this Saturday, September 13th from 11 am to 3 pm, an event that brings artists, community organizers, and the general public together in hopes of raising awareness of issues that impact all Albertans. Can you join Marg at the ABR table? Message me or .

📍 Calgary Unitarians

📅 Saturday, September 13th

🕙 11 am to 3 pm MST

September 20th: Draw-the-Line Rally

Seniors For Climate and Eco Elders of Calgary Climate Hub are pleased to invite The Gravity Well and your supporters to attend a global mass mobilization in support of climate regeneration and social equity on Saturday September 20th, from 1:00 to 3:00 PM, at Calgary City Hall Plaza.

📍 Calgary City Hall

📅 Saturday, September 20th

🕐 1 to 3 pm MST

"Draw The Line - For People. For Peace. For The Planet" highlights the need to minimize global warming, build the world we want for our grandchildren and eliminate social inequity and corporate greed.

Draw the Line has five demands of legislators (Details on the website HERE):

• Uphold Indigenous sovereignty.

• Put people and communities over corporate profit.

• Protect Mother Earth. End the era of fossil fuels.

• Treat immigrants fairly. Stop blaming migrants.

• Stand for justice and peace. End the war machine.

September 23th: AB Resistance Inglewood Town Hall

Marg Tokar is coming to town to hear from you, Inglewood and Calgary. Please join us to hear updates from and offer your thoughts for recalling your or other Alberta Government MLAs.

📍Inglewood Hall

📅 Tuesday, September 23rd

🕖 7 pm MST

Campaigns & Podcasts

The Calgary Environmental Roundtable (CERT) Municipal Election campaign is a non-partisan coalition initiative of environmental and climate organizations in Calgary, led by the Gravity Well Podcast. We aim to prioritize water, nature, and climate issues in the City of Calgary's future planning by engaging residents and candidates through questionnaires, mayoral ward panels, and voter engagement tools. The campaign emphasizes the importance of clean water, biodiversity, and bold climate action to ensure a sustainable future for Calgary.

Send an email to your candidates!

Our campaign launch featured speakers Preet Kang from the Alberta Environmental Network and former councillor Bob Hawkesworth, who answers the survey questions by sharing his strategies for addressing the climate emergency, protecting biodiversity, and ensuring affordable housing and transit in Calgary. Key points included the need for strong policies, increased funding for non-market housing, the adoption of green building standards, and the role of ENMAX in achieving the city's 2035 clean electricity goals. Bob also highlighted the importance of civic engagement and collaboration among environmental organizations to influence municipal decisions and promote a sustainable future for Calgary. A wonderful start to the campaign, thank you, Bob! Watch the full episode here.

Water in Southern Alberta

Bob Morrison has been working hard to identify the outstanding conversations for the Water in Southern Alberta podcast. We will pick up where we left off after the municipal election on October 20th.

Self-Regulation Training

Sessions 1-4 (of 8) with Brad Chapin are available for paid subscribers. If you participated, I would greatly appreciate any feedback!

Take Action | In the News

Oppose the Cancellation of a Public Hearing for Summit Coal Inc.’s Mine 14 Project via the Alberta Wilderness Association

The CEO of the Alberta Energy Regulator (AER) cancelled the public hearing for Mine 14, an underground metallurgical coal mine near Grande Cache, Alberta, proposed by Summit Coal Inc.

Summit has now successfully circumvented the public hearing process and invalidated all the previous decisions made by the AER’s own hearing commissioners and panel by appealing directly to the CEO of the AER. The CEO’s decision undermines the authority and credibility of the AER, the hearing commissioners, the panel appointed to review Mine 14, and the entirety of the public hearing process.

Write the AER: Say NO to Summit Coal

Tell policymakers we need bold action on methane pollution with For Our Kids

We need the federal government to pass bold methane regulations and get to near-zero emissions by 2035, matching BC’s leadership. This means preventing methane from ever entering our atmosphere – avoiding future disasters, creating good jobs, and showing our kids we care about their future.

The good news? Cutting methane is the low-hanging fruit of climate action. Solutions already exist, and companies are ready to scale them up right now.

Call Your MP!

Lookback | Engagement | Measurement

• TGW website Substack now has 477 newsletter subscribers, thank you for the continued support! Please let your friends know they may subscribe here. And please follow TGW on YouTube, LinkedIn, TikTok, and Bluesky.

• Share this newsletter with your friends and network! Support The Gravity Well by becoming a paid subscriber today.

• This week’s shout out goes to Preet Kang, she has worked tirelessly to help me with the launch of the CERT candidate campaign. I look forward to hosting candidates with you!

Events

No More Public $$$ For Pipelines (or Carbon Capture and Storage)

Protestors gathered in front of the Harry Hays Building and the office of the Pathways Alliance in Calgary, on August 20th, to demand an end to public dollars towards fossil fuel development (pipelines or carbon capture and storage). Led by For Our Kids Alberta, the Calgary Climate Hub, and the Canadian Association of Physicians for the Environment, members sent a clear message for oil and gas executives to proceed at their own risk. Watch and listen to Claire Kraatz explain.

A Discovery in Didsbury, courtesy of Minister Brian Jean’s Chief of Staff

The C4RE trial Drill & Dash town hall in Didsbury last Thursday was a success. The group was joined by the Department of Energy (DOE)’s Chief of Staff, Vitor Marciano. Vitor explained to a room full of landowners and polluter pay supporters how the Government of Alberta is working to increase the costs of natural gas in our province, in order to prevent unprofitable corporations from failing. Thank you, Vitor, for helping us understand what the priorities of your office are: corporations not taxpayers or landowners. Liability comes before profitability, Vitor, the problem is clearly with the DOE not upholding polluter pay laws.

Premier Smith calls for a lifting of the BYD Tariffs

In response to the 75% Chinese tariff on Canadian canola, Premier Smith is calling for the Government of Canada to lift the ban on BYD electric vehicles, “It makes no sense to have a punitive tax to protect an industry that doesn’t yet exist in Canada, which is the EV vehicle industry, at the same time as we’re getting punished on canola and pork, which are products the world wants and needs, including China. So I think that that approach has to be reconsidered,” the premier said this week.

I am very pleased to announce I 100% agree with the Premier on this point, though it has been pointed out to me that some might consider her comments as government overreach.

Now Canola farmers, please consider growing less toxic and resource intensive crop. Learn about The Dark History of Canola here. 📺

The Passing of Watershed Legend Dale Christian

I had the privilege of meeting and working with Dale Christian over the last two years. Dale worked for the Red Deer River Watershed Alliance for over 20 years, and fought for water, river, and land rights until her passing this week. I had the privilege of learning from her in Episode 12 and 23 of Season 1. Not only was Dale extremely knowledgeable and articulate but she dedicated her retirement to standing up for what is right, for her and her neighbours. I am sad to hear of her passing but will maintain the fight with Dale’s spirit in mind. Here’s a clip of Dale from Episode 23:

Ongoing & Upcoming Events

Calgary River Pathways Weed Pulling Days

🪧Join the Calgary River Valleys (CRV) community on August 23 and/or August 30 from 9 to noon to pull weeds on the Elbow River. CRV is restoring the natural function of the riparian zone 🛶 on these sites, since 2023. They’ve planted more than 600 native shrubs, as well as native wildflowers to attract pollinators.

Help them accelerate the restoration by pulling invasive species. Easy and satisfying work with wonderful people! Sign up here.

Campaigns

Join the Forever Canadian movement by collecting signatures!

The Forever-Canadian.ca campaign is growing exponentially but help is still required! Sign up to collect signatures. Former Minister Lukaszuk has created a movement, the campaign is growing beyond believe but the team is hyper-focused on results: collecting nearly 300,000 signatures by the end of October. I am looking to connect with other collectors in Calgary-Bow or Signal Hill. Please reach out to me to set up a signing station together!

Here’s Thomas speaking with all about it and the ruling by an Alberta judge to determine the meaning of the Alberta Prosperity Project’s “sovereignty” question. Help Alberta stay Canadian today!

A reason to wear your iron ring again

Are you a member of the Association of Professional Engineers and Geoscientists of Alberta (APEGA) and concerned about upholding public safety and maintaining member protection in a rapidly changing environment? Join and share this online, fall campaign–-to carry out a gap analysis between what APEGA says it does and what we do–-with your fellow APEGA members and friends. Together we can uphold APEGA's rights and delegated responsibilities. Email us at info@thegravitywell.net to join.

Support the AB Resistor

The AB Resistance is hard at work reviewing all the activities affecting Albertans and updating you regularly. A special shout out to Tami Smith for all of your work! Please become a paid subscriber if you appreciate this work!

AB Resistance

How to help us change the Political Landscape in Alberta

August 19, 2025…

Read more

9 months ago · 14 likes · 20 comments · AB Resistance

The Gravity Well Podcast

Highlights from Season 2, Episode 15: What are the Impacts of Climate Change on Insurance?

Please watch, like, and share these short reels from Markham, Derek, and myself describing looming insurance crisis and growing risk aversion related to increasing climate catastrophes. Full episode available here.

Leadership Training

Session 1 and 2 of Self-Regulation Skillset Training Program with Brad Chapin are available on TGW website for paid subscribers and participants. Please check it out! And consider ordering a copy of the Self-Regulation Skillset for Educators journal here. Session 3 through 8 will be released over the next six weeks!

Lookback | Engagement | Measurement

• TGW website is on Substack with 436 newsletter subscribers, thank you for the continued support! Please let your friends know they may subscribe here. And please follow TGW on YouTube, LinkedIn, TikTok, and Bluesky.

• Share this newsletter with your friends and network! Support The Gravity Well by becoming a paid subscriber today.

• This week’s shout out goes to Karen Fahrlander, a leader in the watershed world and grassroots organizing machine. I will see you at the SPOG neighbour day tomorrow! Join us if you are in the area.

  

Do you have your Protect Our Water sign out again? Make coal a municipal election issue by getting an albertabeyondcoal.ca sign. Let’s remind candidates that water is life, share this site and campaign with your friends!

“Drill and Dash” August 14th Didsbury Town Hall

Join the Coalition for Responsible Energy (C4RE) this Thursday, August 14th from 6:30 to 9 pm at the Didsbury Elk’s Hall. Learn about the Mature Asset Strategy, an Alberta Government sponsored effort to dump liabilities onto Alberta taxpayers and landowners, rather than upholding the responsibilities of polluters.

Forever Canadian

Want to ensure Alberta stays within Canada? Sign up to be a petitioner for the forever-canadian.ca campaign. Join thousands of Albertans who wish to vote for the following referendum questions, “Do you agree Alberta should remain in Canada?”. Follow the campaign on social media for locations to sign!

No Public $$ For Pipelines (or Carbon Capture and Storage)

Led by members of the Calgary Climate Hub, For Our Kids, and the Concerned Calgarians on Climate Change (4C), a rally against public dollars being put towards fossil fuel development (pipelines or carbon capture and storage) will be held on Wednesday, August 20th from 12 to 2 pm MST at the Harry Hays Building, downtown Calgary. Let the Federal Government know that you are following the plot. A rapid fossil fuel phase down is required, no more expansion with public dollars!

Campaigns

Are you a member of the Association for Professional Engineers and Geoscientists of Alberta and want a good reason to wear your ring? Join a group of APEGA members interested in upholding our professional mandate and remaining protected by the association. Learn more here!

Season 2, Episode 15: What are the Impacts of Climate Change on Insurance

joined me as co-host with Commercial Insurance Broker to discuss The Impacts of Climate Change (Water) on Insurance. Have a listen to the full conversation here.

Do you wish to recommend a future episode and/or co-host an episode or more with me? Apply here. I am pleased to be working with Bob Morrison on the Water in Southern Alberta series of episodes.

Leadership Training

Session 1 of Self-Regulation Skillset Training Program with Brad Chapin is available on TGW website for paid subscribers and participants. Please check it out! And consider ordering a copy of the Self-Regulation Skillset for Educators journal here. Session 2 through 8 will be out shortly!

Lookback | Engagement | Measurement

• TGW website has moved over to Substack and has 417, and growing, newsletter subscribers, thank you for your continued support! Please let your friends know they may subscribe here. And please follow TGW on YouTube here.

• Share this newsletter with your friends and network! Support The Gravity Well by becoming a paid subscriber today.

• A shout out to marketing volunteer, Ashley, for providing us a framework to break through the propaganda machine. Please message me to learn how to support ABR’s marketing strategy.

Feedback

• Share your ideas and concerns to info@thegravitywell.net or Box 201, Unit 406, 917-85th Street SW, Calgary, AB, T3H 5Z9.

The (ABR) board has been busy building a virtual marketing strategy. Thank you, Ashley! If you have expressed interest in supporting this effort, you will have received an invite to our first virtual meeting, on Thursday, August 7th at 7 pm. We will share our strategy to pre-bunk the mis and disinformation machine and want your input! For starters, what do you think of the following slogan, “Recall, Reclaim, Rebuild…Albertans rise”?

Please message me if you haven’t received the invite and would like to attend, or if you’re interested in joining the ABR board, we are looking.

The Secret Long Tree Society on Absolutely Canadian

The Secret Long Tree Society’s “Absolutely Canadian” one-hour series showcasing documentaries and performance programs that tell unique stories from communities across Canada airs on Gem today and on CBC channel 4 locally after the Nature of things on Saturday. All programs are produced locally. A special shout out to for this and all the work she does to defend fresh water and biodiversity in Alberta.

Drill & Dash on YOUR Land?

Please join us for a Landowner and Community Town Hall in Didsbury. Hosted by Phillip Meintzer with the Coalition for Responsible Energy, on Thursday, August 14 from 6:30 to 9:00 pm at Elk’s Hall in Didbury, Alberta. Learn what is happening now…how their shell game works, what industry insiders and the government are planning with this fall’s Mature Asset Strategy, and what we will do to stop them.

RSVP to the Piikani Nation Prayer for Old Man River’s Headwaters

As the Piikani Nation recovers from the loss of two of her elders to the spirit world, I am patiently waiting for the rescheduling of the traditional Prayer Ceremony in Napi’s Garden. I have been reflecting on my conversation with Harley Bastien last year. Before we recorded, I told Harley I was there to understand what I am missing in my thinking. “What are my blinders?” “What do I not understand?” This clip shows just a taste of Harley’s wisdom and compassion. Please RSVP to join him and others Piikani Elders in prayer for Old Man River’s headwaters soon.

Campaigns

Want a reason to wear your iron ring again? Join a collaboration of the Association of Professional Engineers and Geoscientists of Alberta (APEGA) members concerned about the direction the province is headed, and interested in reviewing our organizations mandate and our protection. Sign up and share with your fellow concerned APEGA members.

Join the Coalition for Responsible Energy and take action towards polluter pay in every way today!

Join the Recall For Change | AB Resistance community to use United Conservative Party of Alberta’s recall legislation to recall at least three UCP MLA’s. Do you wish to support the Calgary Bow and NorthWest recall campaigns or lead a recall in your constituency? Let us know at recallforchange@gmail.com.

The Podcast

The next episode of the Water in Southern Alberta series will air Live-Live on Thursday, April 7, at 12 noon. is co-hosting with me to learn from Derek Connick about The Impacts of Climate Change (Water) on Insurance. Do you wish to recommend a future episode and/or co-host an episode or more with me? Apply here.

Here’s a clip from the latest episode on Dryland, Irrigated, and Ranchland Farming with co-host Bob Morrison, Dwight Popowich, John Smith, and Julian Vandenberg. In it, Julian explains what it is like to be an irrigation farmer in of Enchant, Alberta today and the changes he is seeing.

Courses

TGW Self-Regulation Leadership training podcast mini-series will be released in the coming week. Note: the materials will be available to paid subscribers and contributors. Check out the Leadership Training page for its release and the release of Organizing For Power training, Creative Problem-Solving, Land Restoration, and Treaty 7 education.

Should you wish to participate in the upcoming Land Restoration, Treaty 7 training, or another round of Organizing For Power happening in November, please message me!

Lookback | Engagement | Measurement

• TGW website has moved over to Substack and has over 400 newsletter subscribers, thank you for your support! Please let your friends know they may subscribe here. And please follow TGW on YouTube, Bluesky, TikTok, and LinkedIn.

• Engagement on posts is most welcome, please leave comments with any questions, concerns, and ideas, I want to hear from you!

• Please share this newsletter with your friends and network! Support The Gravity Well by becoming a paid subscriber today.

Feedback

Share your ideas and concerns to info@thegravitywell.net or Box 201, Unit 406, 917-85th Street SW, Calgary, AB, T3H 5Z9.

I am pleased to announce the second action taken by the Coalition For Responsible Energy (C4RE) and our partners. On June 22, 2025, “Ecojustice lawyers filed an investigation request with the Ethics Commissioner on behalf of Dwight Popowich, a landowner in Two Hills, Alberta. The submission requests an investigation of David Yager, Special Advisor to the Premier and Alberta Energy Regulator (AER) Board Member, for breaches of the Conflicts of Interest Act, and the Alberta Government’s Procurement of Sole-Sourcing Policy regarding his role as Chair in the creation of the province’s controversial Mature Asset Strategy.”

Listen to Dwight Popowich, a landowner in Two Hills, Alberta and chair of the Polluter Pay Federation explain and take action here:

Recall For Change | AB Resistance has been hard at work behind the scenes building materials, communication strategies, and plans for constituencies leads in order to initiate recall campaigns this fall. Currently aiming to host a virtual meeting with volunteers who have indicated a wish to support our social media efforts to build public awareness. If you do not receive an invite by mid next week but wish to participate, please send me a message to get involved!

Bob Morrison and I’s “Water in Southern Alberta” podcast miniseries has six episodes to-date. We are looking for your input and feedback before returning to the studio in mid-September to talk about The Future. Please watch the episodes and offer your comments, concerns, recommendations, and participation in the comments. Thank you to all those who have participated so far!

Upcoming events

Led by Piikani Nation elders Harley Bastien and Morris Little Wolf, participate in a traditional prayer ceremony for the Old Man River’s headwaters. Sign up for this event and check out others here.

Recall For Change | AB Resistance marketing and recall campaign strategy virtual meeting planned for the week of Aug 5th, please message me if you have not received an invite by next week and wish to join.

Campaigns

Join the Coalition for Responsible Energy and take action towards polluter pay in every way today!

Join the Recall For Change | AB Resistance community to use United Conservative Party of Alberta’s recall legislation to recall at least three UCP MLA’s. Do you wish to support the Calgary Bow and NorthWest recall campaigns or lead a recall in your constituency? Send me or a message today!

Do you wish to recommend a future episode and/or co-host an episode or more with me? Apply here. I am pleased to be working with Bob Morrison on the Water in Southern Alberta series of episodes.

Have a misinformation complaint? The Federal greenwashing portal is now open, let’s use it. Share your misinforation complaints with me to share your action with TGW network here.

Courses

TGW Self-Regulation Leadership Training podcast mini-series will be released in the coming week. Note: the materials will be available to paid subscribers and contributors. Check out the Leadership Training page for its release and the release of Organizing For Power training, Creative Problem-Solving, Land Restoration, and Treaty 7 education.

Should you wish to participate in the upcoming Land Restoration and Treaty 7 training, please message me!

Lookback | Engagement | Measurement

• TGW website has moved over to Substack and now has over 400 newsletter subscribers, thank you for your support! Please let your friends know they may subscribe here. And please follow TGW on YouTube here.

• Share this newsletter with your friends and network! Support The Gravity Well by becoming a paid subscriber today.

• A special shout out to for all of his support and guidance over the last year. Should you wish to improve your communication using a systematic outcome-based strategy, Andy will help you!

Feedback

Share your ideas and concerns to info@thegravitywell.net or Box 201, Unit 406, 917-85th Street SW, Calgary, AB, T3H 5Z9.

Continued, this is the last part!

Section 3

Question 3.1: Indicate your level of support for identifying circumstances that would be defined in regulation as lower risk inter-basin transfers. These could include transfers for:

• Municipal water supply applications, for example regional water lines/systems.

  • Drinking water is high quality and poses little risk to people or the environment, particularly when piped between municipalities.

• Groundwater applications.

  • Aquifers typically yield much less water than surface water sources

  • The act could also consider hydrogeology, including aquifer properties as well as base of groundwater protection.

• Where a project or operation is located on both sides of a major river basin boundary, and the overall impacts would be lower if water is sourced from an adjacent major river basin compared to where water is used

  • If the project were located anywhere else, the licence would be relatively straightforward.

• Treated wastewater applications.

  • Reusing treated wastewater can avoid taking new water from a natural water body, reducing net environmental impact and could provide a net benefit even in an inter-basin transfer context.

• Applications that fall below a specified volume threshold, where the potential for adverse impacts is considered unlikely or is no greater than typical smaller Water Act licensing applications.

  • Amounts could be tailored to reflect the differences in major basin sizes and supply.

Answer: I do NOT support this proposed change.

1. The Existing Requirement for a Special Act Serves as a Vital Safeguard

• The current requirement for inter-basin transfers to be approved through a special act of the legislature ensures:

  • Democratic accountability,

  • Rigorous scrutiny,

  • And meaningful public debate.

• This safeguard reflects the unique and irreversible ecological implications of moving water between basins, especially under changing climate and hydrological conditions.

2. Risk Is Context-Specific — Not Easily Categorized as ‘Low’

• Even small-volume or “treated” water transfers can have disproportionate impacts when:

  • Cumulative effects are not understood,

  • Source basins are over-allocated or under-monitored,

  • Downstream First Nations or communities depend on flow volumes and timing for cultural, ecological, or legal reasons.

• The assumption of low risk often fails in real-world implementation, particularly in Alberta’s closed or stressed sub-basins.

3. This Change Could Open the Door to Regulatory Loopholes

• Creating a regulatory carveout for “lower-risk” inter-basin transfers risks incremental erosion of public protections.

• There is concern that such a provision could be exploited for resource extraction, municipal expansion, or industrial growth, bypassing the higher bar of legislative approval.

4. Undermines Watershed-Based Management and Local Authority

• Inter-basin transfers — even of groundwater or reclaimed water — can:

  • Undermine cumulative watershed planning,

  • Disrupt regional efforts to maintain water conservation objectives (WCOs), and

  • Create precedents for cross-basin water markets that prioritize economic demand over ecological and community needs.

Alternative Recommendations:

If specific low-risk transfers must be addressed:

1. Strengthen the emergency use provisions already available under Section 107 for critical public needs.

2. Instead of a blanket exemption, require any proposed inter-basin transfer — regardless of scale — to:

   • Undergo a public environmental review,

   • Demonstrate no harm to source watershed,

   • Provide Indigenous consultation evidence, and

   • Include monitoring and enforcement mechanisms.

Conclusion

I oppose the creation of a regulatory category for “lower-risk” inter-basin transfers, as it opens the door to cumulative degradation, diminished oversight, and potential water equity issues. Alberta must maintain a strong, precautionary approach to protect its watersheds for future generations.

Share any feedback on situations or issues where special Act of the legislature would remain warranted.

1. When Transfers Cross Major River Basin Boundaries

• Transferring water between major basins (e.g., from the Peace-Athabasca to the South Saskatchewan) disrupts the natural hydrological integrity of both the donor and receiving watersheds.

• These decisions are irreversible, precedent-setting, and carry long-term ecological, social, and economic risks.

• A Special Act ensures transparent, deliberative, and public decision-making, appropriate to the scale of consequence.

2. When the Transfer May Affect Water Conservation Objectives (WCOs) or Instream Flow Needs

• Many Alberta basins already face seasonal low flows, over-allocation, and ecological stress.

• Inter-basin transfers risk depleting source basin flows, especially during drought or climate-induced shifts.

• Legislative oversight is needed to balance economic demand with ecological responsibility and treaty obligations.

3. When Transfers May Set Precedents for Water Markets or Commodification

• Even seemingly small or “low-risk” transfers can establish legal and administrative precedents for future, larger-scale diversions or trade-based water reallocations.

• A legislative process is essential to debate and control the scope and intent of such actions — especially in relation to equity, Indigenous rights, and public interest.

4. When Indigenous and Treaty Rights May Be Affected

• Water is a treaty-protected resource for many First Nations. Transfers that impact baseflows, fish habitat, or culturally significant watersheds require meaningful consultation and recognition of free, prior, and informed consent (FPIC).

• A Special Act process ensures these rights are acknowledged and debated in the open.

5. When Cumulative Effects and Long-Term Impacts Remain Unclear

• Watershed-scale hydrology is complex and climate-sensitive. Even well-intended transfers may produce unintended ecological, geological, or hydro-political consequences over time.

• Requiring legislative approval helps ensure that rigorous review and adaptive governance mechanisms are in place.

Conclusion

The requirement for a Special Act of the Legislature is not bureaucratic redundancy — it is a vital democratic safeguard that reinforces Alberta’s responsibility to manage water as a shared, public trust. Especially in an era of growing scarcity, inter-basin transfers must be exceptional, not routine. They demand the highest level of scrutiny, public transparency, and ecological foresight.

Question 3.2: Indicate your level of support for mending section 47 of the Water Act to introduce two categories of inter-basin transfers:

1. Higher risk transfers or large-scale transfers, which would continue to require a special Act, and

2. Lower risk transfers, which could proceed through the standard licensing process without requiring a special Act.

Enabling of any review processes for inter-basin transfers described in regulations would also require added authority for the Minister to make regulations under section 169.
Authority to approve a lower-risk inter-basin transfer could be shifted from a special act to either:

• Cabinet, by a Lieutenant Governor Order in Council, similar to how these transfers can be authorized under section 107 during a water-related emergency; or

• Minister, if the inter-basin transfer meets the lower risk criteria set out in regulation.

Answer: I do NOT support this proposed change.

1. Inter-Basin Transfers Are Inherently High-Stakes and Require Full Legislative Oversight

• The requirement for a Special Act of the Legislature exists precisely because inter-basin transfers — regardless of size — carry far-reaching ecological, legal, and social implications.

• They alter natural flow regimes, impact cumulative watershed function, and undermine the principle of basin self-sufficiency that is central to sustainable water management in Alberta.

2. The Terms “Low-Risk” or “Small-Scale” Are Highly Subjective

• These categories are difficult to define objectively, and once enshrined in regulation, they can be incrementally expanded under political or industrial pressure.

• Cabinet or Ministerial discretion lacks the transparency, accountability, and democratic safeguards of a legislative process.

3. Creates Precedents That Erode Watershed Integrity

• Introducing a two-tiered approval system weakens the legal and symbolic weight of section 47.

• Even one exception to full legislative scrutiny could be used as precedent for future deregulation, leading to normalized inter-basin transfers and market-based water speculation.

4. Current Water Governance Gaps Do Not Support Decentralized Approval

• Alberta lacks:

  • A provincial water security strategy,

  • Public basin-level water budgets,

  • A functioning cumulative effects framework, and

  • A system for assessing interactions between groundwater and surface water across basin divides.

• Until these tools exist, no inter-basin transfer should occur without full legislative review.

Conclusion

Water flows define ecological, cultural, and regional identity. Any diversion across basin boundaries, no matter how “small,” risks undermining both environmental function and public trust. Alberta must continue to hold inter-basin transfers to the highest standard of scrutiny — through a Special Act of the Legislature.

We urge the government to maintain the current legislative requirement and instead focus efforts on:

• Water efficiency within basins,

• Strengthening local and regional collaboration, and

Restoring watershed resilience through nature-based solutions.

Question 3.3: Indicate your level of support for consolidating the list of major river basins, including combining the Peace/Slave and Athabasca River basins (that converge within Alberta) to form the Peace-Athabasca-Slave River Basin.

Answer: I do NOT support the proposed changes.

1. Undermines Legal Clarity and Watershed Protection

• The current distinction between Peace/Slave and Athabasca River basins reflects important hydrological, ecological, and jurisdictional differences.

• Consolidating these basins would reduce legal safeguards by redefining inter-basin transfers between them as intra-basin — thus removing the requirement for legislative approval under Section 47 of the Water Act.

2. Risk of Deregulating Inter-Basin Transfers Through Technical Redefinition

• This proposal appears to be an administrative workaround to facilitate inter-basin water transfers that would otherwise require a Special Act of the Legislature.

• Merging basins that are functionally distinct — especially without full public consultation — sets a precedent for regulatory weakening through definitional manipulation.

3. Peace and Athabasca Basins Have Distinct Ecological and Cultural Significance

• These basins support different Indigenous territories, ecosystems, and resource pressures.

• The Athabasca Basin, in particular, includes oil sands development with serious implications for downstream water quality and quantity.

• Combining them could mask cumulative impacts and weaken basin-specific protections.

4. Fails to Reflect International and Interjurisdictional Responsibilities

• Alberta’s existing basin designations correspond with Canada’s national and transboundary water governance frameworks, including the Mackenzie River Basin Agreement.

• Merging major basins may create discrepancies with national reporting, Indigenous water agreements, and interprovincial commitments.

Conclusion

Consolidating the Peace/Slave and Athabasca River basins may seem technically convenient, but it carries serious risks:

• Weakens basin-specific governance,

• Erodes legislative oversight for inter-basin transfers,

• Undermines Indigenous sovereignty and cumulative effects tracking.

We urge the government to retain the existing basin definitions and instead invest in improving:

• Cumulative effects monitoring,

• Basin-level water budgeting, and

Transparent governance mechanisms that reflect both hydrological function and socio-cultural realities.

Section 4

Question 4.1: Indicate your level of support for creating a mechanism to authorize reuse of wastewater by an entity other than the producer. This may include defining responsibilities of wastewater producers, users, and regulator(s) related to alternative water sources in the act, regulation or policy.

Answer: (Conditional) Support for Authorizing Reuse of Wastewater by Entities Other Than the Producer

I support this proposed change — with strong environmental and public interest safeguards. Reasons for Conditional Support:

1. Enabling Wastewater Reuse Can Advance Water Conservation

• Reusing appropriately treated wastewater instead of diverting freshwater can reduce pressure on rivers, aquifers, and ecosystems, particularly in closed or stressed basins.

• It supports water-use efficiency, aligns with New Water Paradigm principles, and contributes to a circular water economy.

2. Supports Innovation and Reduces Reliance on Freshwater

• In sectors like oil and gas, agriculture, or industrial cooling, the ability to use treated effluent from another operator can reduce net water withdrawals.

• Municipalities and industry could collaborate on fit-for-purpose reuse systems that make better use of existing resources.

Risks and Required Safeguards:

1. Ecological and Health Risks if Poorly Managed

• Not all wastewater is equal. The composition, contaminants, and treatment levels vary widely depending on source (e.g., fracking flowback vs. municipal greywater).

• Risks include:

  • Introduction of emerging contaminants or residual chemicals,

  • Harm to aquatic ecosystems if return flows are reduced or quality is degraded,

  • Inadequate oversight of how wastewater is stored, transported, and applied.

2. Wastewater Should Not Become a Loophole to Avoid Licensing

• Some actors may seek to reclassify freshwater withdrawals as “wastewater” to bypass licensing requirements or shift regulatory burdens.

• The reuse of wastewater should not be a backdoor into inter-basin transfers or freshwater substitution without accountability.

Recommendations for Mitigation and Policy Design:

1. Wastewater reuse should remain subject to licensing under the Water Act and/or EPEA, except in very low-risk scenarios with defined thresholds.

2. Require a fit-for-purpose treatment and risk assessment framework tailored to the intended use and environmental context.

3. Establish clear accountability:

   • Producer retains responsibility for quality until handoff,

   • Reuser must monitor application and ensure compliance,

   • Regulator oversees tracking, data reporting, and enforcement.

4. Develop a public registry of reuse agreements and discharge points to ensure transparency and enable local engagement.

5. Prioritize reuse within the same watershed unless an environmental review confirms that export will not degrade flow or ecosystem function.

Conclusion

While wastewater reuse can offer environmental and economic benefits, it must be implemented through strictly regulated, transparent, and ecologically informed frameworks. We support the creation of legal mechanisms for wastewater reuse, but only if they uphold the precautionary principle, protect watershed integrity, and ensure public accountability.

Question 4.2: Indicate your level of support for amending the definition of water to clarify that it includes rainwater captured before it hits the ground.

Answer: I support this proposed change.

I support this proposed change — with clarification and appropriate thresholds for licensing exemptions.

Reasons for Support:

1. Provides Legal Clarity for Rainwater Harvesting

• The current absence of rainwater in the Water Act leads to regulatory uncertainty for individuals, municipalities, and businesses considering rainwater collection systems.

• Clearly defining rainwater within the Act — as distinct from stormwater — will:

  • Support responsible water innovation,

  • Provide a foundation for future policy and program development, and

  • Reduce confusion among regulators and the public.

2. Promotes Water Conservation and Urban Resilience

• Rainwater harvesting can reduce demand on potable freshwater supplies, especially for:

  • Irrigation,

  • Toilet flushing,

  • Industrial or commercial greywater uses.

• This supports goals of water efficiency, drought preparedness, and urban water resilience, particularly in over-allocated basins.

3. Prevents Unregulated Large-Scale Harvesting

• Including rainwater in the Act allows Alberta to set clear volume thresholds for what constitutes exempt small-scale use (e.g., household barrels) versus what requires licensing (e.g., large commercial collection and reuse systems).

• This ensures that cumulative effects — especially in dense urban developments or industrial zones — are accounted for and mitigated.

Recommended Policy Design and Mitigation Measures:

1. Amend the Water Act definition of water to clearly include rainwater captured before it reaches the ground.

2. Introduce a licensing exemption for:

   • Individual residential rain barrels,

   • Rooftop cisterns for non-potable indoor or outdoor use under a defined volume threshold.

3. Require licensing or regulatory oversight for:

   • Large-scale or commercial systems with potential cumulative impacts,

   • Uses that involve distribution or sale of collected rainwater.

4. Clarify that rainwater use must remain within the same parcel or watershed, and cannot be used to bypass licensing for inter-basin transfers or consumptive commercial withdrawals.

Conclusion

This amendment is a practical and future-forward step toward enabling conservation innovation while protecting water security. With appropriate thresholds and oversight mechanisms, Alberta can both support household and business rainwater reuse and protect against unregulated large-scale interception of precipitation.

I support this change.

4.3 Stormwater Use: Indicate your level of support for enabling stormwater diversion without requiring a water licence, at volumes up to the net difference in runoff between pre- and post-development.

Answer: I do NOT support this proposed change.

1. Stormwater Is a Critical Component of the Natural Water Cycle

• Stormwater plays essential ecological roles:

  • Replenishing groundwater,

  • Supporting wetlands, riparian zones, and baseflows, and

  • Carrying nutrients and sediments important for aquatic life.

• Diverting stormwater — even modest volumes — without oversight can disrupt hydrology and water quality at a sub-watershed level.

2. The “Net Difference” Test Is Difficult to Monitor and Enforce

• The proposed threshold — up to the net difference between pre- and post-development runoff — introduces high regulatory ambiguity.

• Measuring and verifying these volumes requires site-specific hydrological modelling, and without licences or permits, regulators lack tools to enforce limits or track cumulative effects.

3. Cumulative Impacts Could Undermine Ecosystem Health

• Even small diversions, if left unregulated and repeated across many developments (e.g., industrial parks, subdivisions, agricultural operations), can cause:

  • Lower return flows to streams and wetlands,

  • Reduced resilience during drought,

  • Increased flood risks from poor management of modified flow paths.

• These risks are particularly acute in closed or over-allocated basins like the Bow, Oldman, and Red Deer.

4. Existing Licensing System Already Allows for Reasonable Use

• The current 6,250 m³ exemption under the Water (Ministerial) Regulation provides sufficient flexibility for low-risk use of stormwater in most cases.

• Larger or cumulative uses should continue to be subject to licensing or transfers — especially in basins where all available allocations are already spoken for.

Conclusion

Stormwater is not a waste product — it is a vital flow within our natural and built environments. Enabling its diversion without a licence, based on vague pre/post-development comparisons, would:

• Create regulatory blind spots,

• Undermine ecological water budgeting,

• Weaken the ability of watershed managers to track and govern total withdrawals in already-stressed systems.

I strongly recommend retaining stormwater licensing requirements and improving data, modeling, and coordination instead.

Share Feedback:

Feedback: Stormwater Supply and Use by Third Parties Must Be Controlled and Regulated

We strongly recommend that the supply and use of stormwater by third parties remain subject to regulation and oversight. Reasons for Regulation of Third-Party Stormwater Use:

1. Stormwater Is Part of the Public Water Cycle

• Stormwater is not a private asset. Once it enters collection systems (e.g., municipal drains, ponds, wetlands), it is part of the managed hydrological system and contributes to:

  • Recharge of rivers, wetlands, and aquifers,

  • Water quality control, and

  • Downstream ecological flow needs.

• Its use — especially by third parties — must be managed with the same care and accountability as other water sources.

2. Unregulated Third-Party Use Risks Commodification and Hoarding

• Without oversight, third parties could begin treating stormwater as a private commodity, leading to:

  • Unmonitored diversions or withdrawals,

  • Monetization of a public resource, and

  • Equity concerns for downstream communities and ecosystems.

3. Cumulative Impacts Need to Be Managed

• While individual stormwater uses may seem minor, aggregate use by third parties (e.g., construction firms, agricultural operations, or landscaping contractors) can:

  • Lower return flows into the environment,

  • Alter local hydrology,

  • Impair Water Conservation Objectives (WCOs), and

  • Undermine resilience during drought.

• These effects are especially concerning in closed basins and urbanized watersheds.

4. Regulation Ensures Quality and Safety

• Stormwater can contain pollutants, sediments, hydrocarbons, or heavy metals. Without regulation, third-party users may apply stormwater:

  • Inappropriately (e.g., crop irrigation or dust control near sensitive areas),

  • Without treatment, or

  • In ways that create public health and environmental risks.

Policy Recommendations:

1. Require licences or permits for all third-party uses of stormwater above a clearly defined low-volume threshold.

2. Establish fit-for-purpose quality standards for stormwater use based on its intended application.

3. Ensure that all third-party use:

   • Occurs within the same watershed as collection,

   • Does not conflict with existing return flow expectations, and

   • Is reported, tracked, and assessed for cumulative impact.

Municipalities and regulators should retain primary control over stormwater systems, with clear authority to approve or deny third-party arrangements.

Conclusion

Stormwater must be treated as a public, regulated water source — not an unclaimed or privately exploitable flow. Any use by third parties must be managed under a clear licensing and oversight framework to protect ecological flows, water quality, and public interest. Unregulated access is inconsistent with responsible watershed management and climate-resilient infrastructure.

Question 4.4: Return Flow

Answer: I support this proposed change.

I support this proposed change — with provisions to protect ecological flows, prevent speculative use, and ensure watershed integrity. Reasons for Support:

1. Return Flows Are Essential to Watershed Health

• Return flows — particularly from municipalities and industry — help sustain instream flows, meet Water Conservation Objectives (WCOs), and support downstream users, including ecosystems and transboundary partners (e.g., Saskatchewan under the Apportionment Agreement).

• Clarifying the legal definition of return flow will help ensure these volumes are accounted for, protected, and not diverted for other uses without oversight.

2. Prevents Speculative or Unlicensed Reuse

• Without clear legal definition, there is a risk that entities could attempt to recapture or resell return flows, especially where high-value water markets or water stress exist.

• This creates legal ambiguity and opens the door to double-counting or secondary appropriation of water that was presumed to be re-entering the ecosystem.

3. Strengthens Accountability and Monitoring

• By bringing return flows under clearer regulatory authority, the province can:

  • Better track actual water consumption vs return,

  • Improve flow forecasting and management, and

  • Hold licence holders accountable for maintaining return flow conditions specified in their licences.

4. Supports Adaptive Management and Climate Resilience

• In a changing climate, return flows become even more critical to maintaining baseflows during low-flow periods.

• Defining and regulating return flows enables the province to model and manage cumulative impacts at the sub-basin level.

Recommended Implementation Provisions:

1. Define return flow in the Act as:

“The portion of a licensed water diversion that is returned to a surface water body, after use, treatment, or other modification, and is not consumed or lost.”

2. Clarify that return flows:

   • Are part of gross diversion volumes, but must be accounted for and not repurposed without licensing.

   • Are subject to quality standards and discharge conditions under both the Water Act and EPEA.

3. Require approval for any reuse of return flows by the original user or third parties.

4. Prohibit transfers of return flows that would alter flow regimes, WCO compliance, or downstream commitments without full environmental assessment.

Conclusion

Return flows are a critical component of Alberta’s water balance. Clear legal definition and licensing of return flows will:

• Prevent unauthorized reuse,

• Strengthen water budgeting and ecological protections, and

• Ensure Alberta’s water governance system remains transparent, equitable, and sustainable.

I support this proposed amendment.

Clarification on Gross vs. Net Diversion and Use of Return Flow Credits

Key Points and Recommendations:

1. Gross Diversion Should Remain the Primary Legal and Regulatory Framework

• The current system, where licences are issued based on gross diversion volumes (i.e., total water withdrawn), provides clarity, enforceability, and consistency.

• It ensures that all users are equally responsible for reporting, managing, and accounting for their full impact on the water system — including:

  • Consumption,

  • Losses (e.g., evaporation), and

  • Return flows.

• Recommendation: Confirm that gross diversion remains the default legal basis for all water allocations and licence issuance in Alberta.

2. Return Flow Credits / Net Diversion Should Only Be Considered in Highly Controlled, Limited Circumstances

• In theory, recognizing return flow credits could incentivize:

  • Efficient water use, and

  • The reuse of non-consumptive volumes,

  • Especially in industrial or municipal systems with consistent, monitored return flows.

• However, in practice, the following risks and limitations must be addressed:

A. Risk of Double-Use or Water Hoarding

• Without robust oversight, return flow credits could be used to reclaim, reallocate, or trade volumes already assumed to benefit the ecosystem.

• This undermines assumptions behind WCOs, instream flow needs, and downstream access.

B. Monitoring and Enforcement Complexity

• Measuring actual return flows — especially their volume, timing, and quality — is complex, and often dependent on:

  • Infrastructure capacity,

  • Flow conditions, and

  • Changes in operational practices.

• Any return flow credit system must require real-time metering, transparent verification, and public reporting.

C. Water Quality Concerns

• Not all return flows are environmentally benign. Even treated wastewater or industrial discharges can contain thermal, chemical, or nutrient pollution that alters aquatic ecosystems.

• Any return flow that contributes to crediting must meet stringent water quality thresholds that protect downstream users and aquatic health.

When (and only when) Net Diversion or Return Flow Credits May Be Considered:

We recommend the following criteria for limited-use pilot programs or regulated applications:

1. Return flow is metered, monitored, and traceable to the licensed activity.

2. Return is made to the same surface water body and sub-watershed within a short distance and time delay.

3. Return flow meets or exceeds predefined environmental quality standards, especially regarding temperature, nutrient load, and toxic substances.

4. Net diversion accounting does not exceed the original licensed allocation volume or rate under any conditions.

5. Return flow credit cannot be used to justify inter-basin transfers or significantly altered timing of withdrawals without full environmental review.

6. The system is part of a publicly transparent reporting platform, with third-party or community-based monitoring where applicable.

Conclusion

Gross diversion should remain the foundation of Alberta’s water licensing system. Net diversion and return flow credits may offer some efficiency benefits — but only where scientific, legal, and ecological safeguards are strong, and transparency and accountability are guaranteed. Misapplication of return flow accounting could lead to over-allocation, ecosystem degradation, and erosion of public trust.

Any exploration of return flow crediting should proceed cautiously, preferably as limited, well-monitored pilot projects within closed basins where flow restoration and water security are priorities.

Provide additional info, comment, and submit.

The Government of Alberta is proposing major changes to the Water Act and have created an engagement survey for the public. Yes, I know, another survey that will be tossed in the waste bin by our government, and yet these changes are too big not to offer comment. with the support of watershed council members has created responses.

Here is the link to the survey and my responses based on their input:

Section 1

Question 1.1: Indicate your level of support for changing section 54 of the Water Act to allow licence amendments of licences to be able to add points of use, areas or boundaries outside the original point of use specified in the licence.*

Answer: I do not support this proposed change.

Potential Consequences:

1. Weakened Watershed-Based Water Management

   The point of use is fundamental to local water budgeting and cumulative effects analysis.

   Allowing expanded use outside licensed lands breaks the spatial integrity of current watershed planning and complicates enforcement of limits set by Water Conservation Objectives (WCOs) and Water Management Plans.

2. Risk of Cumulative Impacts and Ecological Degradation

   Even if volume and timing remain constant, changes in return flow distance, soil infiltration, or evaporative loss may reduce actual water returning to the source — especially in arid or fully allocated sub-basins.

   These impacts may be individually small but cumulatively significant, particularly in stressed watersheds like the Bow and Oldman.

3. Legal and Administrative Uncertainty

   The current framework ensures a clear linkage between a water licence and specific land. Expanding point of use beyond licensed parcels would:

   1. Undermine certainty for landowners, regulators, and downstream users.

   2. Create precedents for incremental deregulation of basin-based water controls.

4. Increased Risk of Functional Interbasin Transfers

   While not explicitly an interbasin transfer, expanded points of use may enable functionally similar outcomes, especially if return flow patterns change. Without strong guardrails, this opens a regulatory back door to water movement across watershed divides.

5. Undermining of Water Conservation Incentives

   If water can be freely reallocated across lands under one entity’s control, there is reduced incentive to invest in efficiency or stewardship at the original point of use.

Recommended Mitigations (if pursued despite opposition):

If the government proceeds with this change, the following strong safeguards must be implemented to mitigate risks:

1. Limit scope strictly to contiguous parcels within the same sub-watershed.

2. Require a hydrologic and ecological impact assessment, including modeling of return flow scenarios.

3. Mandate public notice and appeal rights for affected licence holders and communities.

4. Prohibit expanded use where WCOs are not currently being met, or where basins are closed to new allocations.

5. Require that any changes to point of use preserve or improve environmental outcomes, not just convenience.

Conclusion

The “point of use” is not merely administrative. It is foundational to watershed-based planning, environmental protection, and fair access. Weakening this spatial linkage increases risks of misuse, ecological harm, and diminished public trust. For these reasons, we strongly oppose the proposed change to section 54.

Question 1.2: Indicate your level of support for changing section 54 of the Water Act to allow licence amendments to add or change a point of diversion outside the original land specified in the licence or plan attached to the licence, provided there is no adverse effect on the water rights of others nor on the ability to conserve or manage a water body.*

Answer: I do not support this proposed change.

1. Undermines Watershed-Based Allocation Integrity

• The point of diversion is a critical control mechanism in Alberta’s water licensing framework. It ties a licence to a specific location, sub-basin, and source conditions.

• Changing the point of diversion outside the original land breaks the geographic specificity that underpins cumulative impact assessments, basin planning, and infrastructure expectations.

2. Elevates Risk of Disruption to Other Water Users

• Moving a point of diversion — even slightly — can:

  • Alter flow regimes for downstream users,

  • Affect riparian rights,

  • Reduce baseflow support in tributaries,

  • Disrupt priority calls under the FITFIR system.

• The test of “no adverse effect” is difficult to verify, especially under variable climate and flow conditions.

3. Impacts Environmental Flows and Instream Values

• Changing where water is taken can have unexpected consequences on fish habitat, sediment transport, wetland function, and aquatic species.

• If the new diversion point is closer to the headwaters, it could reduce flow contributions to mid- and lower-reach ecosystems, especially in dry years.

4. Creeping Deregulation & Precedent Setting

• Allowing more flexible diversion points opens the door to case-by-case approvals that bypass basin-wide planning objectives and Water Conservation Objectives (WCOs).

• It sets a concerning precedent for future water marketing and transfers that may prioritize flexibility over ecological stewardship.

5. Monitoring and Enforcement Challenges

• Tracking actual points of diversion in the field already strains capacity. Allowing off-licence diversions increases the risk of unauthorized draws, reporting inaccuracies, and reduced compliance visibility.

Mitigation (if amendment is pursued):

If the government moves forward despite concerns, the following strict conditions should apply:

1. Must remain within the same sub-basin or hydrologic unit.

2. Must undergo full hydrologic and ecological assessment, including modelling of flow impacts and return flows.

3. Public notice and appeal rights must be triggered automatically.

4. Changes must support or enhance WCO compliance and must not be permitted in closed basins.

5. All proposed changes must be subject to transparent justification and documentation in a publicly accessible registry.

Conclusion

Changing the point of diversion outside the licensed area introduces significant risk to watershed integrity, equity among users, and environmental flows. The current system prioritizes place-based governance for good reason — and we urge the province to maintain that discipline. We do not support this amendment.

Question 1.3: Indicate your level of support for the Director being able to initiate corrections or amendments to licences where the amendment results in an ability to access water in lower flow conditions.*

Answer: I do not support this proposed change.

Low Flow Conditions Require Ecosystem Protection — Not Expanded Access

• Alberta’s rivers are already experiencing stress from over-allocation, prolonged drought, and climate change.

• Instream Flow Needs (IFNs) and Water Conservation Objectives (WCOs) must remain a top priority during low flow periods — not be weakened to allow licensees greater access.

• This proposed change risks shifting the burden of scarcity onto aquatic ecosystems and downstream communities.

2. Director-Initiated Amendments Without Public or Independent Review Undermines Transparency

• Allowing Directors to unilaterally amend licences to benefit users creates a major governance concern:

  • It lacks clear public notice, appeal rights, or environmental assessment.

  • It incentivizes administrative convenience over ecological integrity.

3. Weakens Trust in Water Management During a Time of Scarcity

• Any perception that the government is changing licence conditions to benefit powerful water users (e.g., irrigation districts or municipalities) — without public scrutiny — undermines public trust in Alberta’s already fragile water allocation system.

• It may also erode confidence in WCOs and other flow protection mechanisms.

4. Undermines Precautionary Principles in a Changing Climate

• The dams cited (e.g., Oldman, Dickson) were introduced to help manage variability — not to justify retroactive amendments that favor withdrawals during sensitive flow periods.

• Future conditions will become increasingly uncertain, and our policies must err on the side of conservation and risk mitigation, not expanded use.

Alternative Approaches, if efficiency is the concern:

1. Encourage a group application process for licensees with shared circumstances to apply for amendments collectively — with full transparency and regulatory review.

2. Allow the Director to identify potential amendment candidates but require public notification and independent ecological review before any approval.

Conclusion

Director-initiated amendments to increase access during low-flow conditions pose serious risks to environmental flows, transparency, and equity. While some historical assumptions may be outdated, corrections must be pursued through open processes that preserve ecosystem health and public confidence — especially in closed or stressed basins.

We urge Alberta Environment and Protected Areas to focus on enhancing data transparency, ecological monitoring, and inclusive decision-making, not short-circuiting the regulatory process for administrative efficiency.

Question 1.4: Indicate your level of support for amending notice provisions (e.g., section 37(1)) within the Water Act to require notice to be issued, not only to the applicant, but also to the holder of the authorization.

Answer: I support this proposed change.

Protects the Legal Rights and Responsibilities of Authorization Holders

• In many cases, consultants, legal agents, or third parties submit applications or amendments on behalf of the licensee or authorization holder.

• Failing to notify the actual holder of the licence or approval increases the risk of unintended or unauthorized actions, and erodes confidence in the permitting process.

2. Improves Transparency and Administrative Integrity

• Providing notice to both the applicant and the authorization holder ensures better accountability and governance, especially when changes may affect:

  • Licence terms,

  • Compliance obligations,

  • Operational responsibilities, or

  • Potential legal liabilities.

3. Supports Public Trust and Procedural Fairness

• This amendment aligns with broader principles of natural justice and good regulatory practice.

• It prevents situations where holders are left unaware of regulatory changes affecting their allocations, rights, or responsibilities — an especially relevant issue in joint-ownership or delegated operations.

4. Reduces the Risk of Administrative Errors or Disputes

• Confusion over who receives notice has, in past cases, led to appeals, project delays, and unnecessary conflict.

• Clear statutory notice requirements will help streamline application processing and reduce procedural disputes.

Recommended Implementation Measures:

1. Require that both applicant and authorization holder receive written notice at all major decision points.

2. Provide guidelines for consultants or third-party agents to ensure that authorization holders are identified and confirmed at the time of application.

Conclusion

This is a simple but meaningful improvement to the Water Act that enhances transparency, accountability, and procedural fairness. It ensures that authorization holders are kept fully informed of changes or applications affecting their rights — a necessary safeguard in an increasingly complex water management environment.

I fully support this proposed amendment.

Question 1.5: Indicate your level of support for amending notice provisions (e.g., section 37(1)) within the Water Act to require notice to be issued, not only to the applicant, but also to the holder of the authorization.

Answer: I do NOT support this proposed change.

1. Environmental and Public Interest Outcomes Must Guide Timelines — Not Arbitrary Deadlines

• The variability of applications — from low-risk agricultural uses to large-scale industrial withdrawals — demands flexibility in review timelines.

• Introducing rigid timeframes risks rushing complex assessments, reducing stakeholder consultation, and overlooking cumulative or downstream impacts.

2. Water Is a Public Trust — Not a Commodity for Speedy Processing

• Alberta’s water belongs to the people, and decisions on its allocation must prioritize ecosystem health, Indigenous rights, and long-term sustainability.

• Timelines driven by regulatory efficiency rather than ecological due diligence undermine the public’s trust in the system.

3. Complex Applications May Require Iterative Review and Consultation

• Applications involving:

  • Multiple water sources,

  • Sensitive ecological zones,

  • Potential legal conflicts, or

  • Incomplete or poor-quality submissions

often need multiple rounds of clarification, consultation, and independent review.

• Enforcing deadlines could pressure Directors to make decisions before they are fully informed or before critical conditions are addressed.

4. Risk of “Deemed Approval by Delay” Loopholes

Many jurisdictions that impose time limits later introduce default approvals or administrative shortcuts when those limits are not met — a dangerous precedent for water allocation in closed or stressed basins.

Alternative Recommendations for Improving Efficiency Without Sacrificing Integrity:

1. Maintain discretion for Directors and reviewers to set case-appropriate timelines.

2. Introduce target timeframes, not statutory deadlines, for low-risk applications with built-in safeguards.

3. Increase transparency and accountability by:

   • Publicly reporting average review times,

   • Identifying causes of delay,

   • Publishing queue metrics and decision timelines online.

4. Expand pre-application support and digital tools to reduce back-and-forth during the review stage.

Conclusion

Alberta’s Water Act is a vital tool for stewarding a finite, life-sustaining resource. Speed must never come at the expense of due diligence, ecological health, or public accountability. We oppose the introduction of rigid time limits and instead urge the government to focus on improving transparency, resourcing, and communication within the existing flexible review framework.

Question 1.6: Indicate your level of support for limiting the number or scope of requests for information to complete the application by amending sections 37 and 50. For example, one supplemental information request, with any follow-up limited to clarifying the content of the supplemental information provided.*

Answer: I do NOT support this proposed change.

Complex Water Decisions Require Flexibility and Rigor

• Many Water Act applications — especially those involving large withdrawals, sensitive environments, or cumulative impacts — are inherently complex.

• Artificially limiting the number or scope of information requests risks incomplete or poorly informed decisions, undermining environmental protections and public interest.

2. Would Weaken Due Diligence and Appeal Defensibility

• The Director must have full authority to request as much information as is reasonably necessary to:

  • Ensure compliance with the Act,

  • Assess cumulative effects,

  • Evaluate instream flow impacts,

  • Make legally defensible decisions in the event of appeal.

• Restricting supplemental requests weakens the government’s ability to defend its decisions and could increase legal challenges.

3. Reduces Accountability of Applicants

• In practice, many applicants initially provide minimal or incomplete information to test the system.

• Limiting the Director to one supplemental request could enable applicants to strategically delay or evade full disclosure, especially on issues like return flows, water quality, or environmental risk.

4. One-Size-Fits-All Approach Doesn’t Work

• Application complexity varies dramatically depending on:

  • Sector (e.g., irrigation vs. industrial),

  • Location (closed vs. open basins),

  • Potential for conflict or environmental harm.

• Water management decisions should be case-specific, not constrained by a blanket rule.

Alternative Recommendations (If Efficiency Is the Goal):

1. Create a tiered process:

   • Simple applications (e.g., low-volume renewals) follow a streamlined path,

   • Complex applications allow for full discretion on supplemental requests.

2. Provide clear guidance and pre-application checklists to help applicants submit complete information up front.

3. Track and publish timelines and outcomes to identify bottlenecks without reducing review quality.

Conclusion

While administrative efficiency is important, it must never come at the expense of ecological integrity, legal defensibility, or public trust. Limiting the number or scope of supplemental information requests under the Water Act would handcuff regulators, reduce transparency, and risk uninformed decision-making. We urge the government to retain full discretion for Directors in requesting the information needed to make sound, science-based decisions.

Question 1.7: Indicate your level of support for limiting the number or scope of requests for information to complete the application by amending sections 37 and 50. For example, one supplemental information request, with any follow-up limited to clarifying the content of the supplemental information provided.*

Answer: I do NOT support this proposed change.

1. Erodes Accountability and Undermines Water Budgeting

   Exempting more uses from licensing requirements creates blind spots in Alberta’s water accounting system.

   Even small withdrawals — such as those for dust control or borrow pits — can have cumulative impacts, especially in closed or water-stressed basins.

2. Cumulative Effects Are Poorly Understood and Unmonitored

   The province does not currently have the systems in place to track, monitor, or model the collective impact of many small, exempt uses.

   Without that data, exemptions risk undermining Water Conservation Objectives (WCOs) and water availability for licensed users, environmental flows, and downstream communities.

3. Inappropriate Uses Should Not Be Exempted

   Some proposed uses are clearly consumptive and commercial, such as:

   1. Dust control for industry,

   2. Borrow pits in the Green Area,

   3. Bridge and sign washing by contractors.

4. These should remain licensed activities, with clear monitoring, volumes, and return flow requirements. Exempting them may encourage unregulated water extraction as a cost-cutting measure.

4. Undermines Watershed-Level Planning and Equity

• Expanded exemptions make it harder to manage water on a basin-wide, coordinated basis, and weaken the principle that all users should contribute to transparent, sustainable management.

They may also create a perception of unequal rules — where some users are strictly regulated, while others are not.

Support for Limited, Justified Exemptions:

1. The only category we support for exemption — with conditions — is riparian vegetation restoration by municipalities and community-based watershed stewardship groups.

2. This exemption should be narrowly defined, limited to small-scale, restoration-specific uses, and subject to reporting or notification requirements.

Recommended Mitigations (If Exemptions Are Expanded):

If the province proceeds, it must:

1. Require reporting or registration of all exempt uses through a central digital registry.

2. Establish a cap on exempted water volumes per basin or sub-basin.

3. Require environmental assessments for any new exemption category in sensitive or closed basins.

4. Develop a cumulative effects tracking model and update it annually with field data.

Conclusion

Exemptions should be the exception, not the norm. Expanding them without basin-level tracking and oversight threatens ecosystem resilience, fairness among water users, and public confidence in Alberta’s water governance system. We urge the province to reject most of these proposed changes and prioritize transparency, cumulative impact monitoring, and ecological integrity.

Section 2

Question 2.1.1: Indicate your level of support for amending section 54 of the Water Act to give the Director the authority to add, remove and amend the measuring, reporting, and inspection conditions on all licences, regardless of whether such conditions currently exist. This change would enable consistent water use reporting across all licence types, supporting better data, planning and management.

Answer: I support this proposed change.

1. Consistent Reporting Is Fundamental to Modern Water Management

• Alberta’s current reporting regime is fragmented and incomplete, especially for older licences issued without monitoring conditions.

• This amendment would allow the Director to fill critical data gaps, improving the quality and consistency of:

  • Water allocation planning,

  • Compliance monitoring, and

  • Environmental protection.

2. Supports Transparency and Public Trust

• Standardized reporting ensures all licence holders — regardless of licence age or type — are held to the same expectations.

• Better data allows for more transparent public engagement, better oversight of high-volume users, and community-informed decision-making during droughts or shortages.

3. Improves Equity Among Water Users

• Modern licence holders are already required to report use. Extending reporting to legacy licences helps ensure that historic users are not exempt from accountability, particularly in closed basins or high-stress regions.

• This promotes fairness across agricultural, municipal, industrial, and environmental users.

4. Enables Better Protection of Instream Flows and Ecosystem Health

• Accurate, basin-wide water use data is essential to understanding when Water Conservation Objectives (WCOs) are being met, and when water-sharing or restrictions may be needed.

• Without complete data, instream flow protection is compromised.

Recommended Implementation Considerations:

1. Apply a phased approach to legacy licence holders, with technical support for metering and reporting.

2. Ensure clear public guidance on what must be reported and how.

3. Integrate reporting into a digital, publicly accessible water data platform.

4. Include flexibility to tailor requirements based on licence type, size, and watershed sensitivity.

Conclusion

This amendment will modernize Alberta’s water governance framework, ensure greater accountability, and provide the data needed to plan for water security and ecological sustainability. We strongly support this proposed change as part of a larger effort to build a resilient and transparent water management system.

Question 2.1.2: Indicate your level of support for amending section 18 of the Water Act to introduce authority for the Director to establish new, or amend existing, measuring and reporting conditions for deemed licences without affecting other existing terms and conditions. All other terms and conditions related to a deemed licence would continue to prevail, ensuring legal standing and priority rights remain unchanged.

Answer: I support this proposed change.

1. Improves Transparency and Accountability for the Largest and Oldest Users

• Deemed licences — issued prior to 1999 — often represent some of Alberta’s largest water allocations, yet many lack meaningful measurement or reporting requirements.

• Without consistent data from these licences, the province cannot accurately assess:

  • Total water use in a basin,

  • Water availability during drought, or

  • Compliance with Water Conservation Objectives (WCOs).

2. Supports Fairness Across All Users

• Requiring modern licence holders to report while exempting legacy users creates an unequal system, undermining both ecological stewardship and public confidence.

• Applying reporting to all licence holders promotes equity, responsibility, and shared accountability for Alberta’s water resources.

3. Does Not Alter Priority Rights or Water Allocations

• The proposal respects the legal standing and FITFIR priority dates of deemed licences.

• It simply enables the Director to require basic reporting on how much water is used and when — an essential component of responsible water governance.

4. Supports Basin-Level Water Budgeting and Drought Planning

• Consistent data from all licence holders, including deemed licences, is critical for:

  • Accurate forecasting and real-time drought response,

  • Enforcement of voluntary water-sharing agreements,

  • Basin planning and apportionment transparency.

Suggested Safeguards and Implementation Notes:

1. Phased implementation to allow legacy users time to adapt.

2. Provide technical support and low-cost tools for older infrastructure to meet reporting requirements.

3. Ensure that new reporting conditions are reasonable, proportional, and tailored to the type and size of the licence.

4. Integrate data into public-facing dashboards to build trust and inform communities.

Conclusion

This amendment brings long-overdue consistency to Alberta’s water reporting regime. It ensures that all licence holders — including those with legacy rights — are contributing to the shared understanding and sustainable management of Alberta’s water resources. We fully support this proposed change.

Question 2.1.3: Indicate your level of support for amending section 169 of the Water Act to include regulation-making authority for standardized measuring and reporting requirements. This would enable clear definitions of parameters, frequency, and reporting methods; allow flexibility to tailor requirements by region or licence type (e.g., not requiring specific metering equipment); adapt to new technologies or drought and environmental pressures; and reduce administrative burdens through streamlined, automated systems.

Answer: I support this proposed change.

1. Establishes Clear, Consistent Expectations Across the Province

• Without regulation-making authority, Alberta relies on individual licence conditions to define measurement and reporting — leading to inconsistencies, enforcement gaps, and confusion.

• Amending section 169 would empower the province to set clear, uniform standards for:

  • What must be measured (e.g., volume, rate, timing),

  • How often data must be reported,

  • What technologies or methods are acceptable.

2. Supports Watershed-Responsive, Scalable Management

• The regulation could allow flexibility by region, basin condition, or licence type, ensuring that:

  • Large or high-risk users are subject to higher scrutiny,

  • Small or low-impact users are not overburdened, and

  • Standards can evolve in response to drought, climate shifts, or ecosystem stress.

3. Enables Integration with Digital Regulatory Systems

• A regulatory framework would support automated, streamlined reporting tools, reducing administrative burden and improving compliance through:

  • Digital submissions,

  • Standardized formats,

  • Real-time data sharing with water managers and the public.

4. Improves Enforcement and Public Transparency

• With clear rules established in regulation, government staff will be better equipped to enforce compliance, issue penalties, and verify data.

• Standardized reporting can also feed public-facing water dashboards, strengthening trust, accountability, and civic engagement in water stewardship.

Recommended Safeguards and Features:

1. Co-development with water users and Indigenous Nations, ensuring practicality and cultural alignment.

2. Regional tailoring based on watershed stress, ecological flow needs, and basin closures.

3. Regular review and adaptation of parameters in response to scientific and technological advancements.

Conclusion

This is a necessary and overdue modernization. Giving the government authority to set standardized reporting requirements through regulation will strengthen Alberta’s water governance, improve ecological resilience, and empower all users with better data and clearer expectations. We strongly support this amendment.

Question 2.1.4: Indicate your level of support for repealing section 56(2) of the Water Act to retain the original priorities of individual water allocations within an amalgamated water licence. This would simplify and support accurate reporting as licensees could report the total water used within EPA’s Digital Regulatory Assurance System without risking a false exceedance of their allocated volumes by reporting water use against the wrong licence.

Answer: I support this proposed change.

I support this proposed change — with conditions.

Reasons for Conditional Support:

1. Improves Administrative Efficiency and Reporting Accuracy

• In its current form, section 56(2) discourages amalgamation because it would result in the loss of senior priority dates, creating risk for licence holders under the FITFIR (First In Time, First In Right) system.

• By allowing original priority dates to be retained, this amendment would:

  • Reduce redundancy in records,

  • Improve reporting within the Digital Regulatory Assurance System, and

  • Enable more accurate compliance tracking.

2. Supports Modernization Without Undermining FITFIR

• This change would simplify licence administration without affecting the priority order of access during low-flow periods.

• Provided that priority rights are not consolidated or manipulated, this change preserves the legal integrity of the FITFIR system while making it more workable.

3. Facilitates Cumulative Accounting and Water Budgeting

• When multiple licences are tied to a single diversion point, amalgamating them (while retaining priority distinctions) can help with:

  • Basin-level water budgeting,

  • Understanding total infrastructure impacts, and

  • Aligning infrastructure with allocation tracking.

Recommended Conditions / Safeguards:

To prevent unintended consequences (e.g., hoarding or speculative use), this change should come with the following safeguards:

1. No Change to Allocation Volumes or Purposes:

   1. Amalgamation must not alter the total volume, purpose of use, or points of diversion for each original licence.

2. Public Transparency of Amalgamated Licences:

   1. Each licence within the amalgamated record must retain publicly visible priority dates and conditions.

3. No Transfer Without Review:

   1. Transfers of any portion of the amalgamated licence should be subject to the same review and public notice as before.

4. Apply to Related Licences Only:

   1. Amalgamation should only be permitted for licences held by the same entity for use at the same point of diversion or shared infrastructure.

Conclusion

This proposed change improves regulatory efficiency, simplifies reporting, and modernizes Alberta’s water licensing system — provided that it includes safeguards to preserve legal clarity, priority integrity, and public transparency. With these conditions, we support the repeal of section 56(2).

Question 2.2: Indicate your level of support for defining criteria for good standing in the Water Act or policy could serve to both support compliance with measuring and reporting requirements, and ensure that licence holders have confidence in freeing up water for potential transfers. This would create a practical compliance tool that helps promote accountability by linking timely reporting to eligibility for renewals, transfers, or other administrative actions.

Answer: I support this proposed change.

1. Creates Clear, Enforceable Expectations for Licence Compliance

• Currently, “good standing” is a vague concept, inconsistently applied and not enforceable.

• Clearly defining the criteria in legislation or policy creates a transparent and consistent standard for:

  • Measuring and reporting compliance,

  • Eligibility for licence renewal, and

  • Participation in transfers or amendments.

2. Improves Accountability Across All Licence Holders

• Defining “good standing” allows regulators to take appropriate administrative action when licence holders fail to comply with reporting or use conditions.

• This creates a level playing field and ensures compliance is not optional, particularly for senior licence holders under FITFIR.

3. Enables Transparent, Trustworthy Transfer Markets

• A clearly defined standard provides confidence that any water entering the transfer system comes from a responsible and compliant licence holder.

• It discourages speculation or abuse by ensuring only verified, monitored, and law-abiding licences are eligible for market activity.

4. Encourages Better Data and Stewardship

• Linking good standing to reporting and monitoring ensures the system has better water use data, which is essential for planning, environmental flows, and drought response.

Recommended Enhancements:

To strengthen this proposal, we recommend:

1. Adopt or improve upon the 2014 Administrative Guideline as the foundation, but embed it in regulation or legislation to ensure clarity and enforceability.

2. Include in the “good standing” definition:

   • Up-to-date water use reporting,

   • Compliance with licence conditions (e.g., return flow requirements),

   • No outstanding enforcement actions or violations,

   • Timely response to Director-issued requests.

3. Publish and update a public registry indicating the standing of each licence (similar to inspection status in other regulated sectors).

Conclusion

Defining “licences in good standing” is a low-cost, high-value reform that strengthens compliance, improves public transparency, and helps modernize Alberta’s water allocation and transfer system without altering core licence rights. We fully support this change, with safeguards to ensure ecological and administrative integrity.

Question 2.3.1: Indicate your level of support for introducing new requirements for parties involved in a transfer to disclose additional information on details of transfer (including prices paid).

Answer: I support this proposed change.

1. Transparency Is Essential for Public Trust in a Market-Based System

• Water is a public resource, even if the right to use it is licensed. Any transfer of that right — especially for profit — must occur under conditions of public transparency.

• Without disclosure of prices and terms, Albertans cannot evaluate whether the water transfer system is operating fairly, efficiently, or in the public interest.

2. Supports Equitable and Informed Participation

• Communities, municipalities, conservation groups, Indigenous Nations, and smaller licence holders deserve access to the same market information that large operators and consultants may already possess through informal channels.

• Disclosure of price and volume helps level the playing field and prevents the system from becoming dominated by privileged insiders.

3. Provides Data for Policy Reform and Long-Term Planning

• Over time, publicly reported transfer data can help:

  • Inform pricing benchmarks,

  • Assess regional disparities in water access,

  • Evaluate the economic value of conservation, and

  • Support evidence-based decisions on possible future volumetric pricing or water trust frameworks.

4. Aligns with Best Practices in Other Sectors

• Public disclosure of transaction values is common in real estate, energy markets, and land use decisions involving Crown assets. Water should be no different, particularly given its critical role in ecological and community resilience.

Additional Recommendations:

If implemented, the following safeguards will enhance the proposal:

1. Mandatory reporting of:

   1. Price paid per cubic metre or total transfer amount;

   2. Volume of allocation transferred;

   3. Source and receiving location;

   4. Purpose of use (e.g., irrigation, industrial, municipal).

2. Make data publicly searchable and geolocated through Alberta’s water licence viewer or a new water transactions dashboard.

3. Include summary metrics in annual public water governance reports to track trends, volume moved, and pricing averages.

Conclusion

Disclosure of price and transfer details is a basic expectation in a well-functioning, transparent water management system. It supports better governance, planning, and equitable access — and helps reinforce the idea that water belongs to all Albertans, not just those who can buy or sell it behind closed doors.

I fully support this change.

Question 2.3.2: Indicate your level of support for creating a public platform to publish information on water licences, use, and transfers. This would support transparency, reduce reliance on intermediaries, and improve access to information for those seeking to understand and engage in water transfer opportunities.

Answer: I support this proposed change.

1. Transparency is Foundational to Fair and Accountable Water Governance

• Water is a public good, and decisions about its allocation, use, and transfer must be open to public scrutiny and informed participation.

• A central, publicly accessible platform would democratize access to information that is currently restricted to a small circle of brokers, consultants, and large operators.

2. Supports Equity and Participation in Water Transfers

• Lack of access to licence and transfer information creates barriers for:

  • Small water users, municipalities, and Indigenous communities,

  • Conservation organizations seeking to secure water for environmental flows,

  • Farmers or cooperatives who wish to participate in water sharing or transfers.

• This reform levels the playing field by enabling transparent, informed, and decentralized participation.

3. Reduces Reliance on Private Brokers

• A government-run platform would help eliminate transactional opacity and unnecessary cost burdens associated with intermediaries, while also improving regulatory oversight and data accuracy.

4. Improves Water Security and Regional Planning

• Public access to licence data, use patterns, and transfer history enables:

  • Better water budgeting and availability forecasting,

  • Enhanced drought response coordination,

  • Identification of underutilized or stranded licences,

  • Informed decisions by potential new entrants, including food processors, conservation buyers, and community groups.

Features We Recommend for the Platform:

1. Real-time access to licence and transfer activity, searchable by:

   • Watershed or sub-basin,

   • Licence number, holder, and purpose of use,

   • Priority date and allocation volume,

   • Status (active, expired, pending transfer).

2. Historical use data and compliance summaries (including reporting frequency and any enforcement actions).

3. Integration with Alberta’s existing geospatial water viewer and broader digital regulatory systems.

4. User-friendly design with plain-language summaries and data export features for planners, communities, and researchers.

Conclusion

A public platform for licence and transfer data is a low-cost, high-impact reform that strengthens trust, improves decision-making, and supports collaborative, basin-level water management. In an era of increasing water scarcity, information must be shared — not siloed.

I strongly support this change.