ALIDP response to AEPA water availability engagement January 2025

Posted on Jan 22, 2025 in Volume Targets, Stream Stability, Policy, Reuse, One Water

The ALIDP has released WATER ON THE DEVELOPED LANDSCAPE - Urban Stormwater Policy Recommendations. In response the Alberta Environment and Protected Areas survey 2024/25, the ALIDP has prepared a briefing that provides background and rationale to a number of policy positions. 

In summary, these are the positions

1. It is a misunderstanding of the urban water balance to govern stormwater management facilities as natural water bodies
2. Differentiating between withdrawals to achieve stormwater management runoff reduction and mining of natural runoff is essential
3. Absolute exemptions for withdrawals from stormwater ponds are inappropriate
4. Delta Water must be managed stringently to protect small streams. The potential for shifting requirements from AEPA is making industry reticent to implement practices to protect small streams.
5. All watersheds in Alberta undergoing land development should have an assessment of safe runoff volumes to their receiving water bodies at the tributary level for long-term environmental protection, continued development viability, and protection of people and infrastructure.
6. AEPA should take an approach of ruling out prohibited types of withdrawals from stormwater ponds rather than exhaustively ruling in individual activities
7. Bringing rainwater into the Water Act makes no difference from a stormwater management perspective because it is already part of a Delta Water calculation. As a term it is still useful for describing water quality. Like stormwater, there is no appropriate absolute exemption quantity. Commercial and industrial supplemental rainwater collection devices could be prohibited, if AEPA is worried about this type of loophole in the regulatory framework.
8. Net licensing should be pursued with urgency.
9. Stormwater aquifer storage and recovery and other fit-for-purpose scenarios should be pursued long before any thought of inter-basin transfers.
10. And finally, green stormwater infrastructure should be vigorously pursued to restore the water balance and thereby enhance water storage and water availability. Distributed, natural buffering of soil moisture and restored recharge pathways should be prioritized as part of a shift to supporting natural infrastructure and nature-based solutions that deliver a multitude of co-benefits and enhanced water quality across the landscape.

Readers will find a table in the green stormwater infrastructure topic that identifies water storage features and their applicability in Alberta, categorized by landscape context, water storage type, and land use context. There are also some examples of drought-resilient green stormwater infrastructure at the end.

It is hoped that this document provides a basis for dialog going forward and that the AEPA survey is just the start of some meaningful progress in water management in Alberta.

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