Exemption of Stormwater Reuse from Licensing Requirements
IT IS THEREFORE RESOLVED THAT Alberta Municipalities urge Alberta Environment and Parks (AEP) to exempt stormwater use from licensing requirements provided that the stormwater use does not exceed the difference between pre and post development volumes.
WHEREAS municipalities in Alberta are in need of additional water sources for non-potable water-use activities such as irrigation, dust control, and landscape maintenance;
WHEREAS the current regulations pertaining to stormwater make it very difficult for municipalities to use stormwater for outdoor non-potable water-use activities;
WHEREAS Alberta Environment and Parks is proposing to change how stormwater is made available for municipalities and is requesting feedback on exempting a certain volume of stormwater from the Water (Ministerial) Regulation license requirements; and
WHEREAS municipalities in Alberta would support the exemption of stormwater from the Water Regulation license requirements thus reducing the burden on water licensing in Alberta.
Stormwater use is interpreted as a diversion requiring authorization from the province under the Water Act. In the current changing climate, the impact of drier summers puts pressure on the water systems in Alberta to keep up with the demand of a growing population, especially in basins with a moratorium on new water diversion licenses. Drier conditions increase the need for the irrigation of landscaping, both commercially and residentially. Municipalities end up using potable water to irrigate sports fields, control road dust, and to maintain municipal landscaping and tree canopies. Treatment of water to render it potable uses a large amount of energy, which not only increases costs but also contributes greenhouse gas emissions through the use of fossil fuels in the Alberta energy grid.
Through development, additional stormwater volume is diverted from hard surfaces to receiving watersheds which results in a difference between pre and post development release volumes. The release volume calculations are based on rates of evaporation, annual rainfall, transpiration, and percolation. Post-development volumes of stormwater run-off are greater than pre-development volumes due to a significant increase in impervious surface areas that prevent the water from seeping into the ground. In allowing reuse of the excess stormwater, municipalities would save money and resources, and reduce greenhouse gas emissions by no longer having to treat water for irrigating sports fields and road dust control, or for transporting potable water for landscape maintenance. Through stormwater capture and reuse, municipalities would be proactive in mitigating and adapting to the impacts of climate change in Alberta.
AEP has conducted hydrological modeling showing that municipalities would have specific amounts of stormwater available for use without having a negative impact downstream or on the surrounding ecosystem.
In spring 2022, AEP engaged stakeholders to learn about the current desire or need for stormwater reuse in regions of the Province. Changes to how stormwater reuse is accessed are being proposed by the government in order to lessen the barriers to its use.
In 2014, Alberta Municipalities urged the Government of Alberta to review and make changes to the Water Act to provide a regulatory framework that made it easier to pursue stormwater reuse projects, including streamlining the project implementation process.
The proposed action would support the possible changes that are being put forward by the Alberta Government to remove barriers for the reuse of stormwater by municipalities in Alberta.1
Per a September 2023 letter, Minister Rebecca Schulz, Alberta Environment and Protected Areas, agrees that reusing stormwater is an important strategy for increased water resiliency. She referred to the May 2022 amendment to the Stormwater Use Regulations allowing certain low risk stormwater ponds to be reused.
ABmunis’ Rating of the Government’s Response
Intent partially met—further action will be taken at a medium level of engagement.
ABmunis’ Notes and Actions
On April 28, 2023, the province amended the stormwater reuse regulations to allow for 6,250 cubic meters to be diverted from stormwater ponds without a water license. This partially meets the intent of the resolution.