Part 1: Water Act Engagement Survey
Response due June 30th
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:
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.
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.
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:
Undermine certainty for landowners, regulators, and downstream users.
Create precedents for incremental deregulation of basin-based water controls.
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.
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:
Limit scope strictly to contiguous parcels within the same sub-watershed.
Require a hydrologic and ecological impact assessment, including modeling of return flow scenarios.
Mandate public notice and appeal rights for affected licence holders and communities.
Prohibit expanded use where WCOs are not currently being met, or where basins are closed to new allocations.
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:
Must remain within the same sub-basin or hydrologic unit.
Must undergo full hydrologic and ecological assessment, including modelling of flow impacts and return flows.
Public notice and appeal rights must be triggered automatically.
Changes must support or enhance WCO compliance and must not be permitted in closed basins.
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:
Encourage a group application process for licensees with shared circumstances to apply for amendments collectively — with full transparency and regulatory review.
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:
Require that both applicant and authorization holder receive written notice at all major decision points.
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:
Maintain discretion for Directors and reviewers to set case-appropriate timelines.
Introduce target timeframes, not statutory deadlines, for low-risk applications with built-in safeguards.
Increase transparency and accountability by:
Publicly reporting average review times,
Identifying causes of delay,
Publishing queue metrics and decision timelines online.
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):
Create a tiered process:
Simple applications (e.g., low-volume renewals) follow a streamlined path,
Complex applications allow for full discretion on supplemental requests.
Provide clear guidance and pre-application checklists to help applicants submit complete information up front.
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.
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.
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.
Inappropriate Uses Should Not Be Exempted
Some proposed uses are clearly consumptive and commercial, such as:
Dust control for industry,
Borrow pits in the Green Area,
Bridge and sign washing by contractors.
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:
The only category we support for exemption — with conditions — is riparian vegetation restoration by municipalities and community-based watershed stewardship groups.
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:
Require reporting or registration of all exempt uses through a central digital registry.
Establish a cap on exempted water volumes per basin or sub-basin.
Require environmental assessments for any new exemption category in sensitive or closed basins.
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:
Apply a phased approach to legacy licence holders, with technical support for metering and reporting.
Ensure clear public guidance on what must be reported and how.
Integrate reporting into a digital, publicly accessible water data platform.
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:
Phased implementation to allow legacy users time to adapt.
Provide technical support and low-cost tools for older infrastructure to meet reporting requirements.
Ensure that new reporting conditions are reasonable, proportional, and tailored to the type and size of the licence.
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:
Co-development with water users and Indigenous Nations, ensuring practicality and cultural alignment.
Regional tailoring based on watershed stress, ecological flow needs, and basin closures.
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:
No Change to Allocation Volumes or Purposes:
Amalgamation must not alter the total volume, purpose of use, or points of diversion for each original licence.
Public Transparency of Amalgamated Licences:
Each licence within the amalgamated record must retain publicly visible priority dates and conditions.
No Transfer Without Review:
Transfers of any portion of the amalgamated licence should be subject to the same review and public notice as before.
Apply to Related Licences Only:
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.
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.
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.
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.
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:
Adopt or improve upon the 2014 Administrative Guideline as the foundation, but embed it in regulation or legislation to ensure clarity and enforceability.
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.
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:
Mandatory reporting of:
Price paid per cubic metre or total transfer amount;
Volume of allocation transferred;
Source and receiving location;
Purpose of use (e.g., irrigation, industrial, municipal).
Make data publicly searchable and geolocated through Alberta’s water licence viewer or a new water transactions dashboard.
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:
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).
Historical use data and compliance summaries (including reporting frequency and any enforcement actions).
Integration with Alberta’s existing geospatial water viewer and broader digital regulatory systems.
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.