RE:  PEI Watershed Alliance response to water withdrawal from Dunk River, August 19 – 26th, 2020.  

The board of the PEI Watershed Alliance was disappointed to learn that the province granted approval for agricultural producers to extract surface water from the Dunk River during August 19 – 26th, 2020.   At this time, the river’s water levels were well below the posted maintenance level (45.5 cm), a value that is meant to protect the ecological integrity and natural flow of the river.  The King Government’s decision to allow pumping when river levels were below maintenance flow went against the conditions outlined in the Environmental Protection Act Watercourse and Wetland Protection regulations and Water Extraction Permitting Policy.  On August 18th (4:00 pm) prior to water extraction, the Dunk river water level was recorded as 40.53 cm (~5 cm below maintenance flow) on the PEI Government Water Level information website  and once water extraction commenced on August 20th the water level dropped approximately 5 cm to 35.98 cm1 (~ 10 cm under maintenance flow).

The board of the PEI Watershed Alliance realizes that drought like conditions have put strain on our agricultural producers, however, low stream flows negatively affect the quality and quantity of habitat for aquatic life and entire ecosystems.  We are discouraged that this water extraction decision was made without consideration of the efforts of the local watershed group (Bedeque Bay Environmental Management Association) in improving the ecological health of the Dunk River which is home to an endemic population of Atlantic salmon (COSEWIC listed as Special Concern). The Dunk is one of the last remaining rivers with native salmon populations in central PEI.  Low flows within river systems are detrimental to salmon and trout due to increased predation risk and decreased food availability. We also recognize the significant effect that water withdrawal via multiple low or single high capacity wells can have on surface water quantity,.

The board is upset by this shortsighted approach of the Premier as it counteracts the purpose and goals of the Water Act in “ensuring quality, quantity, allocation, conservation and protection of water is managed in the interests of a common good that benefits and accommodates all living things in the province and their supporting ecosystems.”  The PEI Watershed Alliance and our constituent watershed groups strive for environmental betterment and spend countless energy and resources to improve our Island’s ecosystems through watershed planning and management practices towards goals laid out in the PEI Watershed Strategy. We believe in the precautionary principle and work together with various stakeholders including governments, industry and other partners to find solutions for environmental issues. The Agri-Watershed Partnership is a recent example of this collaborative approach.

Environmental sustainability must be a priority. Unfortunately, we do not feel that this is the viewpoint of the King Government as demonstrated by the Dunk River surface water extraction approval. The ability of an industry to have undue influence on our government is unacceptable and the precedence of the premier in making this decision goes against his oft repeated saying that a ‘co-operative approach is critical to the success of our government.’ Other recent approvals such as Irrigation Holding Ponds and the Eastern Kings Wind Farm further highlight our concerns.  We are requesting an immediate meeting with Premier King and Ministers Jameson and Thompson to discuss our concerns on these issues.

Sincerely,

Mike Durant

Chair, PEI Watershed Alliance

1 https://www.princeedwardisland.ca/en/service/find-stream-level-information

2 https://www.princeedwardisland.ca/en/legislation/environmental-protection-act/watercourse-and-wetland-
protection-regulations

3 https://www.princeedwardisland.ca/sites/default/files/publications/water_extraction_permitting_policy_2013.pdf

4 https://bbema.ca/

5 https://www.dfo-mpo.gc.ca/species-especes/profiles-profils/Salmon-saumon-DU12-eng.html 6 https://www.salmonconservation.ca/resources/renewed-conservation-strategy-atlantic-salmon-prince-edward- island/

7 https://www.researchgate.net/publication/271732215_River_flow_as_a_determinant_of_salmonid_distribution_ and_abundance_a_review

8 https://www.nature.com/articles/s41586-019-1594-4

9 http://www.gov.pe.ca/photos/original/cle_yefang2.pdf

10 https://www.princeedwardisland.ca/en/information/environment-water-and-climate-change/water-act