lessons from the south saskatchewan river ... - World Scientific

Journal of Environmental Assessment Policy and Management Vol. 13, No. 4 (December 2011) pp. 567–590 © Imperial College Press DOI: 10.1142/S1464333211004012

ADVANCING WATERSHED CUMULATIVE EFFECTS ASSESSMENT AND MANAGEMENT: LESSONS FROM THE SOUTH SASKATCHEWAN RIVER WATERSHED, CANADA BRAM F. NOBLE*,‡, POORNIMA SHEELANERE†,§ and ROBERT PATRICK*,¶ *Department

of Geography and Planning School of Environment and Sustainability 117 Science Place, University of Saskatchewan, Saskatoon, Saskatchewan S7N 5C8, Canada ‡ [email protected] § [email protected] ¶ [email protected] †

Received 10 January 2011 Revised 25 June 2011 Accepted 29 June 2011 Watersheds are under increasing pressures from the cumulative environmental effects of human actions. Reviews of recent practice suggest that cumulative effects assessment and management (CEAM) has failed to capture the full range of stressors to Canada’s watersheds. Indeed, the limitations to CEAM have been well documented; yet, there has been limited constructive evaluation to help explain why CEAM has failed to advance. In this paper we examine the underlying challenges to the assessment and management of cumulative effects in a watershed context. Based on lessons emerging from the South Saskatchewan watershed, Canada, challenges to CEAM in watersheds include stakeholder understanding and interpretation of cumulative effects; limitations in the scale of current EA practices in watersheds; data challenges; the lack of established thresholds for watershed effects; and lack of clarity regarding watershed science and regulatory capacity. The merits of a watershed-based approach to CEAM to help address these challenges to practice are explored. Keywords: Watersheds; cumulative environmental effects; watershed cumulative effects assessment; South Saskatchewan watershed. ‡ Corresponding

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B. F. Noble, P. Sheelanere & R. Patrick

Introduction Canada is a freshwater-rich country, but its watersheds are under increasing pressures from the cumulative environmental effects of natural change and humaninduced disturbance (Schindler and Donahue, 2006). Climate change, landscape disturbance, and large-scale development of water resource infrastructure such as dams, pipelines, irrigation, and industrial development are contributing to deteriorated water quality and significant withdrawals of freshwater resources (see Gleick, 2003; Schindler and Donahue, 2006; Seitz et al., 2011). In the Athabasca River watershed, Alberta, for example, Squires et al. (2010) report that between the period 1966–1976 and 1996–2006 operating oil sands leases increased from two to 3,360; water withdrawal increased from just over 12 million m3/yr to nearly 600 million m3/yr. Cumulative environmental effects are often defined as the effects that originate from the combined actions of anthropogenic disturbances over space and time, and have the potential to alter environmental conditions. In a watershed context, cumulative effects include any changes that involve watershed processes, and are influenced by multiple land-use activities (Reid, 1993). Almost all land use activities in a watershed directly alter environmental parameters, including soil, topography, and vegetation, which, in turn modify the transport of water, sediment, organic matter, and pollutants that culminate in river systems (Reid, 1993; Johnson et al., 1997; Schindler, 2001). As such, river system health is largely a function of the types of interactions and processes that occur on the landscape within the boundary of the watershed (Seitz et al., 2011). Thus, cumulative effects to watersheds also include landscape disturbances or impacts that occur in the drainage area that are not necessarily due to watershed processes, but still have the potential to adversely affect water quality or quantity. There is growing recognition of the need to assess and manage the cumulative effects of human actions in watersheds (e.g. Reid, 1998; Culp et al., 2000; Brismar, 2004; Schindler and Donahue, 2006; Seitz et al., 2011). In principle, cumulative environmental effects are addressed under the regulatory-based environmental assessment (EA) process. In practice, however, EA has been heavily criticised for failing to capture the full range of effects to watersheds and river systems. Though cumulative effects assessment and management (CEAM) has experienced continuous improvement since it first appeared on the scene in the early 1980s (Duinker and Greig, 2006; Canter and Ross, 2010), recent reviews of CEAM in Canada have illustrated a project-by-project approach with little regard for broader cumulative environmental change (see Dubé, 2003; Duinker and Greig, 2006; Harriman and Noble, 2009), and a disconnect between the science of

Advancing Watershed CEAM: Lessons from the South Saskatchewan River Watershed

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cumulative effects assessment and conventional EA practice (Squires et al., 2010; Seitz et al., 2011). Land use planners and managers have been heavily criticised for failing to consider the cumulative effects of multiple stressors to Canada’s watersheds (see Schindler, 2001; Schindler and Donahue, 2006). The limitations of current CEAM and the need for better practice have been well documented; however, there has been much more criticism than there has been constructive evaluation as to why CEAM for watersheds has failed to advance. In this paper we identify the underlying challenges to the assessment and management of cumulative effects in a watershed context, and the opportunity for a more watershed-relevant approach. To accomplish this, we focus on CEAM in the South Saskatchewan, a transboundary watershed reaching across the southern portions of the provinces of Alberta and Saskatchewan, Canada. In the following sections we first introduce the South Saskatchewan watershed context as a model watershed for CEAM implementation. We then examine the nature and current constraints to CEAM in a watershed context, and the potential for a watershedbased CEAM framework. Lessons and observations emerging from the South Saskatchewan experience for a more watershed-relevant approach to CEAM are then discussed.

The South Saskatchewan River Watershed, Canada: A Context for Watershed Cumulative Effects Assessment and Management The South Saskatchewan Watershed is 148,000 km2 (Martz et al., 2007), spanning the southern portions of the provinces of Alberta and Saskatchewan, including also approximately 1,800 km2 in Montana, USA (Fig. 1). Originating on the eastern slopes of the Rocky Mountains, the South Saskatchewan River flows for approximately 1,392 km before it joins the North Saskatchewan River, which empties into Hudson Bay, Manitoba. More than 2.2 million people live in the watershed, with approximately 80% of the population in urban areas (Rothwell, 2007; Bruneau et al., 2009); all of which depend on the river and its tributaries to varying degrees for food supply and irrigation, power generation, recreation, household and industrial use, and waste disposal. There are a variety of human land use activities and disturbances in the watershed, the majority of which are not subject to any form of environmental impact assessment (see Schindler and Donahue, 2006; Seitz et al., 2011). The primary land-use is agriculture, including crop production and livestock grasing (Martz et al., 2007). Water use is predominately for irrigation (82%), followed by municipal use, thermal electric, industrial, and livestock. Agricultural activities account for approximately 85% of total water withdrawals (Martz et al., 2007).

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Fig. 1. South Saskatchewan Watershed and sub-basins. Source: Adapted from Atlas of Canada and Martz et al. (2007).

Major point sources of pollution include intensive livestock operations and septic seepage. Non-point sources include livestock grazing and chemical, fertiliser and manure application. Other land uses and significant sources of anthropogenicinduced stress include: pipelines and oil and gas extraction; urban development; storm water drainage and sewage discharge; industrial effluent from various manufacturing and processing operations; coal-fired and hydroelectric power generating stations; gravel mining, and several potash mines (see Saskatchewan Watershed Authority, 2006; Martz et al., 2007). The river’s major tributaries are also subjected to multiple impoundments and large withdrawals for irrigation, municipal, and industrial uses (Schindler and Donahue, 2006). Under an intraprovincial agreement, 50% of flow must be passed on from Alberta to Saskatchewan. In dry years this is a significant management challenge given water demands in the Alberta portion of the watershed (Schindler and Donahue, 2006). Institutional arrangements for assessing and managing the effects of human activities in the watershed are complex, including the federal government, two provincial governments, and several regional quasi-governmental organisations such as watershed boards and agencies. Environmental assessment falls under the legislative requirements of either the province of Saskatchewan or Alberta, with many projects subject to the federal Canadian Environmental Assessment Act, each with different requirements for EA, including the types of activities subject to assessment, and the assessment of potential cumulative environmental effects (Table 1). Under all three jurisdictions cumulative effects, when assessed, are assessed on a project by project basis.


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Table 1. Environmental assessment requirements and provisions for cumulative effects assessment in the South Saskatchewan Watershed.

Authority

Legislative instrument

Requirements for cumulative effects assessment

Responsible agency

Canadian Environment Canadian Environmental Every screening or Assessment Agency Assessment Act comprehensive study Section 16(1)(a) shall include a consideration of any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out. Alberta Environment, An environmental impact Alberta Environmental Alberta Energy and assessment report shall Protection and Utility Board and include a description of Enhancement Act Natural Resource potential positive and Section 49(d) Conservation Board negative environmental, social, economic and cultural impacts of the proposed activity, including cumulative, regional, temporal and spatial considerations. Saskatchewan Environmental No explicit legislated Saskatchewan Ministry Assessment Act requirement. of Environment Draft guidelines for EA In an environmental impact reports, Section 5.0 statement, long-term and cumulative effects should be considered. Federal

Source: Canada (1992), Alberta (1993), Saskatchewan (1980).

Research Methods A document review was used to identify and synthesise current provisions, guidelines, and frameworks for EA practice and watershed management in the South Saskatchewan, with specific attention to guidelines or requirements for the consideration of cumulative effects. Documents included EA legislation and

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associated regulations under Saskatchewan and Alberta provincial and Canadian federal environmental assessment systems (e.g. Saskatchewan, 1980; Canada, 1992; Alberta, 1993; Canadian Environmental Assessment Agency, 2007; Alberta Environment, 2008, 2010); and watershed legislation, plans and reports including watershed management policies and plans, source water protection plans, and watershed monitoring reports (e.g. Johnson and Gerhart, 2005; Saskatchewan, 2005; Saskatchewan Watershed Authority, 2006, 2010; Martz et al., 2007; Waterwolf, 2008; Halliday, 2009; Dubé et al., 2010). The review was supplemented by semi-structured interviews with four groups of key informants, namely: government representatives responsible for EA and regulation; watershed agencies responsible for watershed management plans and source water protection initiatives; practitioners who carry out EAs in the watershed on behalf of project proponents; and members of the scientific community (e.g., academics and scientists from environmental non-government organisations) involved in cumulative effects science research in the South Saskatchewan. A total of 30 interviews were conducted — 15 in Saskatchewan, 12 in Alberta, and three representing federal authorities. Potential participants were identified based on information available in impact statements and watershed reports, and as suggested by other participants. Interviews focused on current approaches to CEAM and challenges to implementation, and the merits of a more watershed-based approach to CEAM. All interviews were audio taped and analysed thematically using ATLAS — ti© for qualitative data analysis. In the sections that follow we identify five specific challenges to current CEAM practice that emerged from the document review and interviews, followed by participant’s views on the merits of a watershed-based approach to help address these challenges.

Perspectives on Watershed Cumulative Effects Assessment and Management Understanding cumulative effects Cumulative effects were variably defined, characterised by either the source of change or from the perspective of the impacted system. Interview participants provided diverse interpretations of cumulative effects and understandings of cumulative effects varied considerably. Some suggested that cumulative effects were “outcomes” or simply the accumulation of stressors on watershed components and processes. For example, one academic participant explained that a cumulative effects is “… the accumulation of a whole variety of stressors and they might be additive but they also might behave non-linearly too if there is synergistic effects.”


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Similarly, others noted that cumulative effects are the sum of effects on an ecosystem component or indicator. As one interviewee explained, a cumulative effect is “the net result of a series of independent events on an indicator of interest.” Cumulative effects were defined independently of individual project actions. Other participants emphasised that although a cumulative effect is a net effect on the watershed, cumulative effects are best defined in terms of individual projects that contribute to cumulative change. Cumulative effects were viewed as “inputs” or combined actions. For example, one EA practitioner explained that CEAM means “looking at the project scale and working with clients to minimize or reduce the use of the resources… and take into account the other existing sources within the existing regulatory framework.” Another participant, a provincial EA administrator, described cumulative effects as something that occurs primarily within the context of large projects. Interestingly, this participant, and the majority of participants, identified agricultural practices, urban development pressures (e.g. storm water drainage, sewage seepage, water withdrawals), and small industrial developments as the main drivers or sources of cumulative effects in the watershed. The majority of these land uses and activities does not fall under any regulatory requirement for EA, and are not captured in project assessment, environmental monitoring programs, or CEAM. In others’ view, a cumulative effect was an arbitrary concept, defined with respect to a “set target” or level of acceptable change, and that the guidelines that define acceptable and unacceptable activities are always shifting. Another interviewee, from a federal government agency, also described cumulative effects as an arbitrary concept but more so in terms of how a cumulative effect is measured. For example, this individual explained that “when looking for cumulative effects” it is important to determine first what the measurements are going to be in order to define how a cumulative effect will be recognised and understood because “… everyone has a different idea of what change constitutes… if you are going to try and portray cumulative effects across a watershed.” Scale issues Though the academic literature argues for a valued ecosystem component (VEC)centered approach to assessing cumulative effects (see Duinker and Greig, 2006), study participants noted that the focus of current practice, especially under projectbased EA, is largely on a project’s incremental stress and not necessarily on the total or cumulative effects acting upon VECs of concern. As a result, project-based EA in the watershed, under all three regulatory jurisdictions, was identified as insufficient to effectively consider the implications of other actions or effects

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that could potentially affect watershed processes. As one EA administrator noted, “…we ask them [proponents] to justify the site selection, describe the existing environment, describe the effects of the project on the environment, and describe cumulative effects.” The participant went on to explain that these effects are “…not really cumulative effects at all, but it’s just the incremental, additive effect of this particular development on top of whatever else is out there already or known to be proposed within the immediate vicinity, and what measures have been taken for mitigation”. Another interviewee from government identified temporal scale as an equally important challenge, noting that forecasting future developments and their impacts over time in the watershed, “is complicated by the narrow scope or narrow focus of project-based EA”. Practitioners were quick to explain that the scales selected for project-based EA are approved, and sometimes determined, under project-specific terms of reference developed by the regulator, and any goodwill by a proponent to examine cumulative effects is inherently restricted. For example, one practitioner explained that at the project scale, “…you are only looking at one event in the isolation of basically everything else, so it doesn’t give you the opportunity to look at the total change or the effective change in your indicator as driven by all land uses and all natural disturbance regimes.” The participant went on to explain that within any EA the focus of a proponent is on their own “…individual project, generally in a small area and generally in a small chunk of time.” The participant was quite critical of current practice, driven by current regulations, expressing that “it doesn’t help society understand the full spectrum of benefits or liabilities that are caused by land use practices.” All participants agreed that the current project-based approach, although it helps to deal with the incremental effects of point sources that may account for specific contaminant or effluent inputs, overlooks many other non-point sources in watersheds that usually fall outside the scope of EA requirements. In this regard, one practitioner described the current state of CEAM in the watershed as “by and large ignoring the non point sources, and those that take place over the long time frames and larger spatial extents …and non-point sources are becoming the problem for some of the major drivers and for some indicators.” At the same time, several participants cautioned that this does not mean that individual projects are not collectively responsible for cumulative effects in a watershed. As a member of one watershed environmental organisation explained, “…if you look at the impact of each project… in terms of people living downstream, each project may be deemed to have an acceptable level of impact; …collectively such activities have resulted in significant adverse watershed effects.” The participant went on to note that these impacts often “…can’t be


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linked back to any individual project, but they can absolutely be linked to the cumulative impacts of what has happened.” Data limitations All participants indicated that assessing cumulative effects to watersheds requires data from a much larger variety of sources than for assessing individual project effects, particularly data over a much larger spatial and temporal scale, including also information about other existing and planned activities. For example, as one EA regulator explained, an assessment of the cumulative effects of a proposed mining operation in a watershed would require information about existing land use activities affecting watershed processes, such as oil and gas activity, roads and trails, agricultural practices, and other types of surface disturbance, past, present, and future. But, at the same time, study participants noted that information about those “other” projects and activities, past, present or future, and information about environmental baselines in general, is seldom available and when available seldom shared amongst or between project proponents, regulators, researchers, and other interests. From the perspective of the individual proponent, obtaining the necessary data to assess and monitor cumulative effects is challenging. As one participant explained, one of the most significant challenges to CEAM in watersheds is the lack of availability of “regionally relevant geo-spatial information including such things as land use plans, regulatory controls, existing or proposed developments; environmental monitoring data.” The participant went on to note that where such data does exist it is disparate and there are few, if any, common systems or platforms for consolidating this information for use by practitioners. Another participant, an experienced EA practitioner, expressed that you cannot undertake a valid cumulative effects assessment “when you are not sure of your data, when you are not sure of who is doing what now or even into the future.” This individual went on to note that “…if a project assessment is done, the proponent is happy, he gets his permission and goes away; but who is adding that into the database and who is coordinating with the regional level or at the watershed level and providing that information…” for future impact assessment and monitoring programs? As a result of the basic lack of relevant baseline data, or access to such data, and the limited information available to proponents about other projects, inconsistencies prevail in CEAM. As one EA administrator noted “quite often the data that is used is not always transferable, even if you do have a number of projects.” The participant explained that there are several instances where multiple projects are located in a single watershed or river reach; each has gone through an EA, but

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each proponent has collected and used their own data, which are all analysed differently and characterised by inconsistent spatial or temporal scales or accuracy. Under this type of practice, “it becomes very difficult to compare across the different projects, because of the lack of standardization in how data is collected and how data is analyzed.” Lack of cumulative effects thresholds Closely related to the above was the issue of threshold determination – either determining the right thresholds for cumulative effects, or the complete lack of thresholds and acceptable levels of change. Theoretically, if a project’s effects exceed a threshold then the effect is considered significant. In practice, however, participants noted that it is difficult to define appropriate thresholds for the cumulative effects of an individual project in a watershed. As expressed by several participants, project EA raises a number of important questions with regard to cumulative effects thresholds, such as whether a small contribution from a single project should be considered significant, regardless of whether or not it crosses a watershed-based threshold; and whether the cumulative effects of multiple projects and activities should be considered insignificant if they are still below the specified project-based threshold, but exceed a watershed-based threshold. As one CEAM practitioner described, “…on a marginal basis, most things look like a very small change.” The participant raised two important questions regarding the cumulative contribution of individual actions: “Does this small measure of change put you over the top?”, and “Is that small marginal change on top of everything unacceptable?” An EA practitioner similarly argued that there currently are no appropriate thresholds for assessing and monitoring cumulative effects in a watershed, explaining “…if people are just looking at their incremental contributions, which is the current state, …[that contribution] is almost always insignificant in CEAM language because there is no standard to relate to.” A provincial government regulator further added that, even where thresholds do exist, there is a lack of agreement on those thresholds, noting that “most [cumulative effects assessments] lack context; you need a measure against something and must have common agreement that this is the appropriate context.” A similar view was expressed by another government participant, who said that “if we’re going to measure, we are going to have to define what cumulative effects are and what are the measurements we are going to use to track; …you have got to define what you are going to measure right at the beginning and do it in terms that will be of vested interest to your participants.” The lack of thresholds for assessing and monitoring cumulative effects, the lack of clarity in defining thresholds, and the lack of


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agreement about those thresholds that do exist, was identified by all interview participants as challenges to the assessment of cumulative effects to watersheds under current practice. Capacity, roles, and regulatory constraints A lack of clarity in establishing the boundaries of assessment, combined with the lack of necessary information and unclear thresholds for assessing cumulative effects, was seen as limiting the capacity of an individual proponent to determine the cumulative effects of their project on broader watershed processes. Many participants thus argued that, notwithstanding the current regulatory environment, the onus of CEAM cannot be placed on individual project proponents; project proponents simply lack the capacity and authority to apply the tools necessary for conducting good assessments of cumulative effects. Several participants indicated that there is limited guidance to proponents as to what past activities and what future activities in a watershed need to be included when assessing the cumulative effects of a project, and often these are activities that proponents may know little about or have no control over. For example, an EA administrator explained that even though proponents are supposed to be taking into account cumulative effects in their EAs, they can only take into account “…what is existing at that point of time and what is known to be considered for the future.” The participant explained that when considering the effects of future projects, “there is too many unknowns, so they [proponents] are not able to provide any context into where their project will fit as far as all of the other future things going on — a lot of which are not regulated.” Other participants agreed. For example, one participant from academia noted that it was “…not fair to expect proponents to look at everything around them in the past and in the future… they don’t have the capacity to do it, it is too expensive, and it is not their responsibility.” Regulators too said they are constrained by the lack of capacity to assess cumulative effects to watersheds. Participants noted constraints in baseline and monitoring data and appropriate indicators to establish “terms of reference” for individual projects; the lack of resources to monitor cumulative change; and the lack of regulatory instruments to enforce standards and thresholds where they do exist. A federal EA administrator argued that both proponents and those reviewing impact statements within government agencies are working against time lines and “there is limited ability or capacity to go out and try and piece together the full range of information that would need to be brought on proper or adequate cumulative effects assessments.” He added that should a proponent or regulator have such capacity, information about land use planning and regulatory controls in

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watersheds is simply not readily available. Another EA administrator, at the provincial level, emphasised the same problem noting that cumulative effects are “commonly beyond the boundaries of what a regulator might want to look at or …have the legislative authority to act on.” As a result, regulators too are currently constrained in addressing the breadth of the cumulative effects problem. Merits of watershed-based CEAM All interviewees identified potential benefit to a more watershed-based approach to CEAM as a means to address many of the challenges to current practice. Many participants suggested that the watershed provides an ideal geographic unit for understanding the cause and effect relationships of cumulative effects to freshwater systems; for identifying the type and location of the stressors as well as the total effect of those stressors on watershed components. As one interviewee explained, “it is easier to tackle the problem if you know where the things are coming from, what its impacts are going to be if everything is coming together.” Participants noted that a broader watershed-based approach to CEAM could potentially support land use planning and development decision making. One participant from a federal EA regulatory agency described CEAM at a watershed scale as “…a tool to generate information to feed into other decision making processes” and that “information of this nature is used by a multi-disciplinary team usually to try and determine the carrying capacity … of any geographic region, its ability to host various activities …and what it seeks to do is provide management decisions to those activities where best, to what extent, to what volume…” In this regard, participants identified watershed-based CEAM as providing a methodology to identify thresholds and direct prioritisation of restoration and watershed planning and management opportunities. For example, one EA practitioner explained that “…if you are looking at the watershed scale you can see changes and you can see again more effective utilisations of resources by focusing on the things that really matter.” Several participants, particularly those from watershed agencies and the academic community, suggested that a watershedbased approach to CEAM could be a useful way to mobilise interests and support from individuals, groups and multiple governments to focus on common problems and develop an overall strategy to plan for and guide development in a watershed. Government participants cautioned that adopting a watershed-based CEAM framework would not replace the need for regulatory-based, project-specific EA as “the need for project assessment is still going to be there, but it will be in a different context.” One provincial EA regulator explained that “if we are doing assessment at a regional scale, in doing those assessments we should be aligned in


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addressing some of the data needs and data standardisations… and the project [proponents] would have to follow those kinds of protocols in assessing the impacts of their project.” Various CEAM scientists agreed, noting that the scale, data and threshold challenges to project EA can be addressed in a more watershed context, which in turn can better define the scoping and assessment attributed to the individual project. As a representative from one of the watershed organisations explained, watershed-based CEAM “…will give you the context in which your project is happening; the sort of baseline information that will tell you [the] project impact in the broader context of this entire watershed” Supporting this perspective, an EA practitioner stated that such a broader scale assessment could “…set what a desired outcome is and build some objectives in terms of what is going to be acceptable or not, so that before a proponent spends a lot of money planning to do a project they can actually identify whether or not to even feasible for them to go or not”. Closely related to the above, participants identified the importance of a two-way relationship between project-specific EA and watershed-based CEAM, and the value of project EA in supporting a more watershed-based approach. For example, interviewees from government and the scientific community noted that the integration of information derived from project-based assessments could inform watershed-scale assessment and planning exercises, which, in turn, could increase the efficiency and effectiveness of development decision making. For example, a federal EA administrator explained that “project specific information could be used to help determine effects at a larger scale that then could feed to planning exercises …so it [project-based EA] is really an information feed into a broader exercise.” As one scientist who specialises in aquatic cumulative effects processes noted, individual project proponents “…need to be told how to do it [cumulative effects science and monitoring] so the way they do it fits into a larger regional CEAM framework, so their information becomes part of the bigger picture, but they are not responsible themselves for the bigger picture”. In this way, information from project-based assessment could be used to help determine effects at a watershed scale. A few participants were much more cautious about the merits of a watershedbased approach, and noted that a watershed-based approach is suitable only when the focus of CEAM is on watershed processes. One provincial EA regulator explained that a single watershed may not necessarily form an ideal unit to study effects on certain environmental components, such as biodiversity, or air quality, and hence different levels of assessment may be required to manage cumulative effects. Similarly, an EA practitioner expressed concern that CEAM conducted at the watershed-scale alone may miss important stressor information that can be

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seen only at a finer scale and are important to managing individual project effects.

Challenges and Opportunities for Watershed CEAM There have been constant and consistent messages that CEAM in Canada’s watersheds is simply not working and, in response, there are calls to advance CEAM beyond the scope and scale of project EA (see Schindler and Donahue, 2006; Seitz et al., 2011). This recognised need for a more spatially relevant CEAM model is not new (see Sonntag et al., 1987; O’Riordon et al., 1988; Spaling and Smit, 1993) suggested that the essential purpose of CEAM has always been to move EA to a more “regional” application. Why then has CEAM in Canada’s watersheds failed to advance in any meaningful way? Based on lessons and experiences from the South Saskatchewan, a number of observations can be made concerning the challenges to CEAM and the potential for a more watershedbased approach. CEAM challenges First, the most basic challenges to CEAM concerns the level of understanding and agreement about the nature and definition of a watershed “cumulative” environmental effect. Recent reviews of CEAM practice in Canada and internationally have found disagreement on a basic definition of cumulative effects (e.g., Bérubé, 2007; Harriman and Noble, 2009; Seitz et al., 2011) and, as a result, the assessment of cumulative effects is often “inadequately distinguished from [project-based] EA” (Baxter et al., 2001, p. 253). This should not be surprising; the academic literature itself is divided on the nature of cumulative effects. Those grounded in project-based EA often characterise cumulative effects in watersheds based on the source of stress and contributions of individual development projects, whereas those engaged in watershed cumulative effects science and monitoring tend to focus on responses or changes in environmental parameters as an expression of cumulative change (see Dubé, 2003; Harriman and Noble, 2008). In the South Saskatchewan, cumulative effects were variably defined and characterised based on either the source of change (i.e. stressors, or combined actions) or from the perspective of the impacted system (i.e. outcomes, or combined environmental effects’). Cooper and Sheate (2004) caution that such variability in interpretation may negatively influence how cumulative effects are assessed and subsequently managed. Arguably, both perspectives are “right” and must be considered in a watershed context. For example, if water quality is the issue of concern then a


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watershed level understanding of the total or cumulative effects on water quality, regardless of the individual sources of stress, is an appropriate to view of cumulative effects. At the same time, and for project proponents, the stress of the individual project is an appropriate view when the focus is on mitigation or avoidance of actions that contribute to deteriorating water quality conditions. The current “division” of cumulative effects and pitting cumulative effects practice and regulation against watershed cumulative effects science (see Seitz et al., 2011) is counterproductive to advancing CEAM in watersheds. Second, scale is a significant challenge pertaining to CEAM in a watershed context (see Seitz et al., 2011). Project-based EA is currently the de facto instrument for assessing cumulative effects (Kennett, 2000), but various authors have suggested that the scale of project EA is not well suited to cumulative effects understanding (e.g. Dubé, 2003; Duinker and Greig, 2006; Therivel and Ross, 2007; Seitz et al., 2011). As Reid (1993) explains, under the project-based approach, if the on-site effects of a project are held to an acceptable level, then the project is considered acceptable. A consistent message in the South Saskatchewan was that the restrictive spatial and temporal scales currently used for CEAM under existing EA practices often results in the individual contributions of many projects being deemed “insignificant”, when the total effects are cumulatively significant. Project EA was considered a valuable instrument to address the incremental effects of certain development initiatives at their source, but many of the non-point sources that contribute to cumulative effects in a watershed fall outside the scope of EA requirements. Notwithstanding constant messages to expand the reach of CEAM, project proponents cannot be held accountable to lead such initiatives; neither can they be held accountable for managing effects to watersheds that are not associated with their project (see Therivel and Ross, 2007). As a result, watershed cumulative effects go unchecked in spite of legislated CEAM under project-based EA. Third, the long-term water quality monitoring databases required to assess and manage cumulative effects do exist in many watersheds (see Dubé et al., 2006); however, the same cannot be said for data concerning those parameters that affect watershed processes. Watershed-relevant geospatial data of land use activities, associations to water quality parameters, and environmental baseline data are often not available. When available, such information is seldom shared amongst or between project proponents, regulators, and researchers. Currently, data are collected for the purpose of identifying and mitigating project-specific stress and monitoring local conditions, and not necessarily for assessing and understanding cumulative effects to the watershed. Some have argued that proponents need to collect data beyond their immediate project impact mitigation and monitoring requirements in an effort to aid better understand cumulative effects to watersheds

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(see Dubé, 2003). However, the focus of project proponents is to assess and monitor project stress so as to avoid or mitigate, to the extent possible, their project’s contribution to cumulative change — not to develop scientifically defensible causeeffect relationships for understanding watershed processes or to monitor the effects of others’ projects (see Noble and Storey, 2005; Therivel and Ross, 2007). Fourth, CEAM requires consistency in those parameters and data that are collected. But, terms of reference for CEAM in Canada’s watersheds, when included in assessment practices, are typically developed on a project-by-project case with data collection standards and protocols often determined by the consultants hired to complete the assessment. More consistency could be achieved by adopting and building upon standard protocols for aquatic parameters, such as those established by the Canadian Council of Ministers of the Environment (1999) and under the Canadian Environmental Effects Monitoring Program (Environment Canada, 1998, 2001), but additional standards and guidelines are required for data concerning other watershed stressors and landscape metrics. That being said, even at the watershed scale, beyond the discipline of EA, there has been no attempt to quantitatively isolate important water quantity and quality variables that can potentially affect the health and condition of a river system over the long term (Squires et al., 2010). In their work on cumulative effects analysis for river reaches in the Athabasca watershed, for example, Squires et al. (2010: 122) report that “despite the examination of almost 5 million data points, the number of water quality variables available for examination over our selected temporal and spatial boundaries was limited due to the frequency of collection and the changes in analytical methods of analyses over time.” This is not a failing of current EA or CEAM per se, but it is a significant constraint to advancing practice. Fifth, and closely related to the above, is the issue of cumulative effect thresholds — specifically, determining the right thresholds and, in most instances, the complete lack of thresholds. Thresholds are commonly used to classify effects as “acceptable” or “unacceptable” (Kilgour et al., 2007), but what is acceptable at the level of each individual project may be unacceptable at the watershed scale. For this reason, unfortunately, some view thresholds as arbitrary and of limited value for assessing cumulative effects. The Canadian Environmental Effects Monitoring Program does provide some guidance and thresholds for detecting the effects of pulp mill and metal mining effluents on water quality, and mills and mines conduct localised effects-based assessment on a recurring basis (see Dubé, 2003), but many indicators for evaluating cumulative effects to river systems do not have thresholds (see Dubé et al., 2006; Schindler et al., 2007; Squires et al., 2010). The problem is only exacerbated for those indicators associated with landscape disturbances in watersheds that affect watershed processes, as opposed


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to water quality or aquatic indicators per se. Seitz et al. (2011) argue that in order to understand cumulative effects to watersheds it is important to define what a river system is most sensitive to and to establish thresholds that are based on ecologically relevant spatiotemporal scales, such as a river reach. Such thresholds are not likely to pre-exist in watersheds, neither are they likely to emerge from project CEAM. Thresholds, when used in project CEAM, are typically informed by local public input and stakeholder values rather than watershed science. As Duinker and Greig (2006, 156) note, “the research needed to understand thresholds demands attention over ecologically meaningful time and space scales and is simply beyond the capacity of project-level …[cumulative effects assessments] to address”. Unless such thresholds for watershed cumulative effects are addressed by CEAM scientists, and subsequently adopted by regulators, meaningful thresholds for cumulative effects to watersheds remain an unlikely scenario. Finally, the capacity and roles of proponents and regulators, as well as the ability to capture cumulative effects under current EA regulation, presents considerable challenges to CEAM. Assessing cumulative effects requires knowledge about other past, present, and proposed projects and land use activities (Kennett, 1999; Baxter et al., 2001). Most often these projects and activities are ones that individual proponents have little to no control over (see Creasey and Ross, 2009). Information about other projects and activities occurring in a watershed is difficult, if not impossible to procure. As a result, project assessments often lack the proper knowledge, data, and quantitative methods for CEAM where effects interact with other anthropogenic and natural disturbances (see Kilgour et al., 2007). This is particularly the case for small projects, such as those assessed under federal screening requirements (see Noble et al., 2011), for which assessments are too restricted in both time and resources to effectively integrate CEAM considerations of other, interacting land use activities (Seitz et al., 2011). Even more problematic is that many projects and land uses that contribute to cumulative effects in watersheds are not subject to CEAM – federally or provincially. For regulators, this poses a significant challenge in terms of associating land use activities and processes with observed cumulative change in watershed parameters and regulating those activities most responsible for adverse cumulative effects. CEAM opportunities The potential for a more watershed-based approach to CEAM as a means to overcome the constraints to project-based approaches is gaining momentum. In the South Saskatchewan context, all interviewees identified potential benefits to CEAM

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conducted at the watershed scale — noting in particular the opportunity to associate better land and water use activities with cumulative effects to river systems. Canter and Ross (2010) similarly note the need for creativity in CEAM, identifying regional programs with multiple stakeholders, creating new knowledge and building upon existing knowledge, as an opportunity to improve practice. There are a number of watershed-based CEAM initiatives ongoing in Canada, funded by the Canada Water Network and the Social Sciences and Humanities Research Council of Canada, and several watershed-based CEAM studies have been completed over the past decade (e.g. Culp et al., 2000; Munkittrick et al., 2000; Wrona et al., 2000; NRBS Board, 2002; Dubé et al., 2006; Squires et al., 2010). All of these initiatives recognise the limits to current CEAM practices, and illustrate the complementary relationship between project-specific CEAM under current regulations and emerging watershed-based CEAM initiatives. In other words, whilst a watershed-based approach is seen as an essential solution to current CEAM limitations, project-specific EA remains a requisite to its success. Conducted at the project scale alone, CEAM may miss important interrelationships that can only be revealed at broader scales; but, at the same time, CEAM at the watershed scale alone may miss important stressor information that can be observed, and effectively mitigated, only at the local project scale (see Magee and Carroll, 2006; Therivel and Ross, 2007). Watershed-based CEAM may be useful to measure the overall condition of an environmental component due to the variety of stressors acting on it in the watershed (see Dubé, 2003), but project-based assessment can provide important stressor information. Reid (1993), for example, explains that in order to understand the cumulative effects of sediment loading acting on a stream channel and to restore that stream channel, it is important to characterise the individual stressors originating from single projects that contribute to the overall effect of sediment loading. This sort of information, in turn, can provide important input to increase the efficacy of project-specific EA by setting thresholds (see Rees, 1995; Braat, 2001; Kilgour et al., 2007) and allowing proponents to determine their project’s actual contribution to watershed cumulative effects. Watershed-based CEAM provides an opportunity for the scale, data, and threshold constraints to current CEAM to be addressed in a broader and more collaborative watershed context, which, in turn, can better define the scoping, monitoring parameters, and impact management actions of the individual project (Baxter et al., 2001; Seitz et al., 2011). Environmental effects monitoring at the watershed scale (see Dubé, 2003; Kilgour et al., 2007), as part of watershed CEAM initiatives, would also ameliorate the proponent’s burden of defining current baseline conditions, accessing scientifically credible information, and


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accounting for projects planned by others (see Grzybowsky & Associates, 2001; Bérubé, 2007; Creasey and Ross, 2009).

Conclusion There is now general consensus in the CEAM literature that CEAM practice must focus beyond the individual project, to encompass also broader regional-scale considerations of the sources of cumulative environmental change (e.g. Dubé, 2003; Duinker and Greig, 2006; Harriman and Noble, 2008). This regional scale for CEAM is defined by ecologically significant boundaries, such as watersheds or eco regions, and not ones necessarily defined in terms of project or administrative boundaries (Reid, 1993; Duinker and Greig, 2006; Kilgour et al., 2007; Thérivel and Ross, 2007; Seitz et al., 2011). In practice however, it seems that CEAM in Canada’s watersheds has failed to advance to this level of practice (see Schindler, 2001; Schindler and Donahue, 2006; Seitz et al., 2011). In this paper we set out to examine the current challenges to the assessment and management of cumulative effects in a watershed context, and the opportunities for a more watershed-relevant approach. The opportunities for watershed-based CEAM are real, assuming that adequate research and governing capacity are provided, but so are the constraints. This paper identified a number of underlying challenges that must be addressed to advance CEAM from the project-scale to the watershed-scale. We believe that these challenges, though derived based on the South Saskatchewan watershed context, are applicable broadly to CEAM in other Canadian watersheds and internationally. However, developing real solutions to these challenges has received little, if any, attention in CEAM literature — other than the recognised need to it. Further, though the relationship would seem almost intuitive, projectbased EA remains largely divorced from broader watershed-based cumulative effects science and planning initiatives. In conclusion, we believe that the EA community is demanding all of the right things of CEAM; but, we have spent much more effort criticising current practice than we have delineating the root challenges and demonstrating viable solutions. Assessing and managing the cumulative effects to watersheds requires innovation in science and CEAM methodologies based on watershed boundaries; a focus on watershed processes; an understanding of the linkages between landscape metrics, project disturbance and river system health; and, perhaps most importantly, champions to drive the watershed CEAM process. We suggest that research initiatives must be dual focused if CEAM for watersheds is to advance in any meaningful way – development of the science of cumulative effects in watersheds, and building creativity and capacity to implement and sustain watershed CEAM.

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Acknowledgements This research was funded by the Social Sciences and Humanities Research Council of Canada under the Canadian Environmental Issues research program. We wish to acknowledge the interview participants for contributing their perspectives and time to this project.

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