November 14, 2020
IDP Chairman and Partners
Sylvan Lake IDP Committee
Sylvan Lake Intermunicipal Development Plan
Municipal Government Building,
5012 48 Ave, Sylvan Lake AB, T4S 1G6
Dear IDP Chairman and Municipal Partners:
Thank you for the opportunity to submit additional comments on your draft proposal Sylvan Lake Intermunicipal Development Plan. The following remarks supplement our detailed review of the 2019 draft document.
We understand that you must submit the plan to comply primarily with a requirement of the Municipal Government Act and not other Alberta legislation that protects, enhances and regulates the environment and natural assets on both public and private property. Nevertheless, we take note that your team of municipal partners has expressed an intention to do so as a recognition that stewardship of Sylvan Lake is a critical waterbody within the IDP-defined area.
As the Sylvan Lake Watershed Stewardship Society (SLWSS), we represent the interests of several hundred members who are dedicated to protection and conservation of the lake and watershed. The scope of our stewardship activities and expertise is well established and recorded on our website pages https://slwss.org and in a collection of articles published by the Sylvan Lake News in 2019. Our sampling, analyses and reporting on the condition of the lake and tributaries over two decades is the basis for understanding the state of the watershed.
As a first concern, your IDP has avoided a commitment to on-going routine measurement, analysis, and public reporting to monitor the end effects of the municipal expansion plans which your IDP would promote and facilitate. While the MGA does not require that you do so, your independent watershed and lake monitoring would be responsible ways to demonstrate that risk management is a core principle and obligation of the IDP.
Your attention to land use regulation and protective classification is admirable. However, Sylvan Lake receives surface and groundwater flow from the surrounding land and its water quality directly affects property valuation and in turn the potential for municipal economic performance. Voluntary monitoring to the existing Alberta Environment and related Alberta Lake Management Society standards combined with mandatory public reporting will help to ensure that municipal partners will not share in a liability for lake eutrophication.
As a second concern we note the great population, land area, and economic value, revenue and expense mismatches among your municipal partners that have potential to create divisions and disputes, notwithstanding your stated earnest hope for proactive cooperation.
For example, your reported municipal profile data show that the Town of Sylvan Lake (TSL) has 7.5 times the sum of the populations of all the other partner land areas within the proposed IDP boundary. The similar ratio of Equalized Assessment is about 2.7. The TSL dominates in all other economic categories.
As written, IDP management committee representation and votes are not proportional to municipal population or property valuations. The proposed governance structure will effectively disenfranchise taxpayers of the largest partner, the Town of Sylvan Lake. Your IDP text description of the organizational structure and intermunicipal financial arrangements are limited and critical matters are deferred to ill-defined future subsidiary agreements. Provision for an independent expert champion and voice for environmental stewardship is missing.
Our SLWSS opinion is that IDP urbanization, economic optimization, and environmental stewardship must be seamlessly integrated. Cumulative effects should be monitored, data consolidated and publicly reported.
As presented, your IDP does not inspire confidence in your concept of peaceful coexistence to achieve your stated goals.
We recommend that you address these two topics, lake monitoring and intermunicipal governance, with substantial changes to the text of your proposed IDP.
Graeme Strathdee, Ph.D., FCIC
President Sylvan Lake Watershed Stewardship Society,