Jon Fennell submission to RVC

February 17, 2021

Dear Council Members;

 

My name is Dr. Jon Fennell and I am a professional hydrogeologist and geochemist in good standing the Association of Professional Engineers and Geoscientists of Alberta (APEGA). I am also a resident of Rocky View County and user of Big Hill Springs Provincial Parks.  I have been supporting a group, Friends of Big Hill Creek Provincial Park, with their opposition of the Mountain Ash Limited Partnership (MALP) application to establish a gravel pit (the Summit Pit) in close proximity to the Park.  I share a number of concerns that the “Friends” do regarding this development.  I will not belabour them, as I am sure they are very similar to concerns expressed by others, but they basically boil down to the following:

 

Background facts:

  • Big Hill Springs Provincial Park is a unique ecological setting of significant value for people and wildlife.
  • The springs that form the headwaters of this park provide cool, clear water of relatively stable temperature that flows from an extensive sand and gravel aquifer system trending off towards the northwest.
  • The water that flows from the springs forms Bill Hill Springs Creek, which eventually flows into the Bighill Creek system supporting up to 50% of the flow in that water course.
  • The temperature regulation provided by Big Hill Springs Creek is responsible for the development of unique aquatic habitat in Bighill Creek
  • Bighill Creek is identified on Fisheries and Oceans Species At Risk website as being protected for Bull Trout populations.
  • There is habitat restoration potential in Bighill Creek for other cold water fish, like the West Slope Cutthroat Trout.

 

Issues related to MALP and other gravel mining developments:

  • The MALP property is located in the sensitive headwater area of the Big Hill Springs complex, and is located at the downstream end of the large sand and gravel complex.
  • MALP proposes to mine the sand and gravel from this headwater area to a depth of 1 m above the water table.
  • The removal of up 20-30 m of this gravel will significantly reduce the ability of the aquifer to filter out natural and/or introduced contaminants that will occur as part of this development.
  • The exposure of the sand and gravel will increase its ability to weather and release harmful trace elements into the groundwater, such as arsenic, cadmium, chromium, selenium, and others.
  • Baseline investigation of the local groundwater by MALP indicates that these trace elements are already in the water, which increases the risk of further contamination during and following pit development.
  • Contaminants released into the groundwater (natural or development-related, like fuels or chemicals) will flow through a significantly reduced gravel layer and into the fractured bedrock where they will move the springs and discharge with minimal attenuation.
  • Once in Big Hill Springs Creek they will move down into the Bighill Creek and impact sensitive and protected the aquatic habitat, possibly triggering a Fisheries Act violation.
  • Remediation of any contamination will be extremely difficult and may inadvertently impact the springs further by intercepting groundwater that would otherwise report to them.
  • MALP has not assess any of this risk, and instead is insisting that their development will not cause harm.  This insistence is unsubstantiated with any proof or modelling results and it is left up to faith. This is not a balanced of comprehensive communication to the Council members by MALP.
  • This is not the only gravel development that may happen in this sensitive headwater area, as there are other gravel leases even closer to the park boundary and the springs that threaten their viability and support of Bighill Creek (i.e. cumulative effects risk)

 

The proposal:

  • To ensure prudent and sustainable gravel mining in the area, establish a development setback around the Park and springs complex to preserve the ecological integrity and recreational value of the area.
  • The proposed setback is 1.6 km around Big Hill Springs Provincial Park, where no gravel development would be allowed.  This would be followed by an additional 1.6 km of gravel mining restriction to limit the excavation to within 4 m of the water table (as opposed to the usual 1 m) to ensure proper contaminant filtration capability and attenuation.
  • The proposed setback distances are based on works of other that have documented impacts from sand and gravel extraction occurring around such developments.

 

I have attached a rather lengthy technical document to support my position, and that of the “Friends”.  Much of it is personal credentials, but the front material is there to provide you with the basis to make an informed decision on the MALP application (and any others that threatened the Park and the springs).  Unfortunately, what has been presented by MALP  does not even begin to explore the issues of their proposed development and the related risks to the environment. If you are not inclined to read my full report, I ask that you at least read the Executive Summary where I have outlined the main issues and recommendations (it is only 2 pages).

 

The recent decision made by the RVC Council to deny the Scott Pit in Bearspaw was a good and prudent decision protecting the rights of the people over profit.  The use of that land for gravel extraction is clearly incompatible with the country residential setting.  Denying the MALP application, and any others that want to establish in the headwater area of Big Hill Springs Provincial Park, would be an equally good and prudent decision in favour of the environment, while still allowing gravel development occur in less sensitive and important areas.  To truly be sustainable, one needs to balance the economic considerations against the needs of the people and the environment, and by establishing a suitable development setback around the Park this will be achieved.

 

Respectfully,

 

Jon Fennell, M.Sc., Ph.D., P.Geol.

Water Resource Specialist

Hydrogeology | Geochemistry | Climate risk

Email:  j.fennell61@gmail.com

Phone:  +1 587-891-5831

February 17, 2021

Dear Council Members;

 

My name is Dr. Jon Fennell and I am a professional hydrogeologist and geochemist in good standing the Association of Professional Engineers and Geoscientists of Alberta (APEGA). I am also a resident of Rocky View County and user of Big Hill Springs Provincial Parks.  I have been supporting a group, Friends of Big Hill Creek Provincial Park, with their opposition of the Mountain Ash Limited Partnership (MALP) application to establish a gravel pit (the Summit Pit) in close proximity to the Park.  I share a number of concerns that the “Friends” do regarding this development.  I will not belabour them, as I am sure they are very similar to concerns expressed by others, but they basically boil down to the following:

 

Background facts:

  • Big Hill Springs Provincial Park is a unique ecological setting of significant value for people and wildlife.
  • The springs that form the headwaters of this park provide cool, clear water of relatively stable temperature that flows from an extensive sand and gravel aquifer system trending off towards the northwest.
  • The water that flows from the springs forms Bill Hill Springs Creek, which eventually flows into the Bighill Creek system supporting up to 50% of the flow in that water course.
  • The temperature regulation provided by Big Hill Springs Creek is responsible for the development of unique aquatic habitat in Bighill Creek
  • Bighill Creek is identified on Fisheries and Oceans Species At Risk website as being protected for Bull Trout populations.
  • There is habitat restoration potential in Bighill Creek for other cold water fish, like the West Slope Cutthroat Trout.

 

Issues related to MALP and other gravel mining developments:

  • The MALP property is located in the sensitive headwater area of the Big Hill Springs complex, and is located at the downstream end of the large sand and gravel complex.
  • MALP proposes to mine the sand and gravel from this headwater area to a depth of 1 m above the water table.
  • The removal of up 20-30 m of this gravel will significantly reduce the ability of the aquifer to filter out natural and/or introduced contaminants that will occur as part of this development.
  • The exposure of the sand and gravel will increase its ability to weather and release harmful trace elements into the groundwater, such as arsenic, cadmium, chromium, selenium, and others.
  • Baseline investigation of the local groundwater by MALP indicates that these trace elements are already in the water, which increases the risk of further contamination during and following pit development.
  • Contaminants released into the groundwater (natural or development-related, like fuels or chemicals) will flow through a significantly reduced gravel layer and into the fractured bedrock where they will move the springs and discharge with minimal attenuation.
  • Once in Big Hill Springs Creek they will move down into the Bighill Creek and impact sensitive and protected the aquatic habitat, possibly triggering a Fisheries Act violation.
  • Remediation of any contamination will be extremely difficult and may inadvertently impact the springs further by intercepting groundwater that would otherwise report to them.
  • MALP has not assess any of this risk, and instead is insisting that their development will not cause harm.  This insistence is unsubstantiated with any proof or modelling results and it is left up to faith. This is not a balanced of comprehensive communication to the Council members by MALP.
  • This is not the only gravel development that may happen in this sensitive headwater area, as there are other gravel leases even closer to the park boundary and the springs that threaten their viability and support of Bighill Creek (i.e. cumulative effects risk)

 

The proposal:

  • To ensure prudent and sustainable gravel mining in the area, establish a development setback around the Park and springs complex to preserve the ecological integrity and recreational value of the area.
  • The proposed setback is 1.6 km around Big Hill Springs Provincial Park, where no gravel development would be allowed.  This would be followed by an additional 1.6 km of gravel mining restriction to limit the excavation to within 4 m of the water table (as opposed to the usual 1 m) to ensure proper contaminant filtration capability and attenuation.
  • The proposed setback distances are based on works of other that have documented impacts from sand and gravel extraction occurring around such developments.

 

I have attached a rather lengthy technical document to support my position, and that of the “Friends”.  Much of it is personal credentials, but the front material is there to provide you with the basis to make an informed decision on the MALP application (and any others that threatened the Park and the springs).  Unfortunately, what has been presented by MALP  does not even begin to explore the issues of their proposed development and the related risks to the environment. If you are not inclined to read my full report, I ask that you at least read the Executive Summary where I have outlined the main issues and recommendations (it is only 2 pages).

 

The recent decision made by the RVC Council to deny the Scott Pit in Bearspaw was a good and prudent decision protecting the rights of the people over profit.  The use of that land for gravel extraction is clearly incompatible with the country residential setting.  Denying the MALP application, and any others that want to establish in the headwater area of Big Hill Springs Provincial Park, would be an equally good and prudent decision in favour of the environment, while still allowing gravel development occur in less sensitive and important areas.  To truly be sustainable, one needs to balance the economic considerations against the needs of the people and the environment, and by establishing a suitable development setback around the Park this will be achieved.

 

Respectfully,

 

Jon Fennell, M.Sc., Ph.D., P.Geol.

Water Resource Specialist

Hydrogeology | Geochemistry | Climate risk

Email:  j.fennell61@gmail.com

Phone:  +1 587-891-5831