Two similar renewable energy projects recently sought regulatory approval in Alberta. Both the Saddlebrook and Foothills solar arrays were proposed for sites just a few minutes southeast of Okotoks, in Foothills County. Both were utility-scale projects. Both of their footprints were huge. TC Energy’s Saddlebrook project was to occupy more than 300 acres. Elemental Energy’s Foothills project, near Blackie, was to be five times bigger still.
Their production potentials were equally impressive. Saddlebrook’s approximately 185,000 solar panels would generate 81 megawatts (MW) of electricity, enough power for 20,000 homes. Foothills’s capacity was to be 150 MW.
But their differences were more striking. Saddlebrook was intended for a brownfield, land that has already tasted industrial activity of one form or another. For decades the land immediately east of Highway 2A between High River and Aldersyde has been zoned for industry. Cargill has been processing meat in this corridor since 1989. Its vast slaughterhouse and associated infrastructure sits only 2.5 km south of the middle of the TC Energy project.
The most noteworthy previous tenant at the Saddlebrook site was magnesium processor MagCan. This much-ballyhooed economic diversification venture is infamous for having sucked more than $100-million from Alberta citizens, then shutting its doors in 1991 little more than a year after opening. Today only bad memories and MagCan’s massive red brick building remain. In the Saddlebrook proposal, this edifice looms over hundreds of perfectly aligned rows of solar panels, many literally a stone’s throw from Highway 2A.
Foothills, on the other hand, coveted farmland. Since the provincial government doesn’t allow utility-scale renewables on public land, developers seek private land, often farms or ranches, for their projects. Elemental Energy proposed to lease some of Foothills County’s best land for growing spring grain.
That food-producing promise was largely hidden during my mid-spring 2023 drive to the Foothills site, less than 10 minutes east of High River. I saw no indication that several thousand migrating snow geese annually feed on waste grain in these fields.
The snow geese migration signals another key difference between Foothills and Saddlebrook—the former’s proximity to Frank Lake. A 3,100-acre low-lying wetland, Frank Lake is also an Important Bird Area (IBA), an international designation for significant bird and biodiversity habitat. The IBA regards the lake as “the most important wetland in southwestern Alberta for breeding water birds.”
These differences between the projects guaranteed that Foothills would be controversial. Saddlebrook, on the other hand, wasn’t. The Alberta Utilities Commission (AUC), the independent quasi-judicial agency responsible for evaluating power projects, approved Saddlebrook. It rejected the Foothills application in its entirety.
In August 2023 the province slapped a seven-month moratorium on all renewable power approvals. Premier Danielle Smith suggested the AUC wasn’t adequately addressing social, economic or environmental concerns in determining whether projects are in the public interest. But to disprove this you’d need only compare the Saddlebrook and Foothills applications. The approval of the one and rejection of the other shows how ham-handed the moratorium is, threatening billions of dollars in investment. In fact, as proven by the AUC this year, Alberta can green its grid while respecting other land uses and values.
One was intended for land that’s already tasted industrial activity; the other, for farmland.
Fossil fuels still provide most of Alberta’s electricity. But this truth hides dizzying change. In the blink of an eye, coal’s decades-long dominance in this province vanished. In 2014, 55 per cent of Alberta’s electricity came from coal. By 2022 this had collapsed to 17 per cent. By the end of this year, likely no electricity in Alberta will come from coal. Natural gas now wears coal’s crown, supplying 64 per cent of electricity to Alberta’s grid in 2022.
But the real revolution is the rapid rise of renewables. The Alberta Electricity System Operator (AESO), the non-profit manager of the province’s electricity market, reports that renewable generation is growing “by leaps and bounds.” Thirteen new utility-scale wind facilities came online over the course of 2021 and 2022, as did 25 new utility-scale solar projects. This boom will soon see wind and solar delivering 30 per cent of Alberta’s electricity supply. Rystad Energy predicts we will overtake Ontario as Canada’s largest producer of utility-scale wind and solar power by 2025.
Policy and economics join Alberta’s bounty of wind and sunshine in explaining these shifts. On the policy front, Rachel Notley’s Climate Leadership Plan (2015) signed the death sentence for coal-fired electricity. It committed to phase out all coal-fired generation by 2030 and to increase the amount of electricity supplied by renewables to 30 per cent. Coal’s phase-out will happen seven years ahead of that schedule.
But technological change is probably more important to understanding the swiftness of the (now paused) renewables boom. The falling cost of solar and wind generation has been eye-popping. In April 2023 the price tag for an unsubsidized utility-scale solar facility was 83 per cent lower than in 2009.
This combination catapulted renewables investments to record levels. Recent changes in the mix of major power project investments are remarkable. Natural gas dominated Alberta’s investment ledger in 2016: $4.9-billion in natural-gas-fired electricity projects were on the books in April 2016, nearly four times the total investment in wind. At the time, the Brooks solar project, with an estimated price tag of $30-million, was the only utility-scale solar venture proposed.
The picture couldn’t be more different today. The investment balance has shifted strongly in favour of renewables. When the UCP government announced its renewables approvals moratorium in August, the Alberta Major Projects website reported that $11.5-billion in investment was being considered for solar and wind. Utility-scale solar had accounted for next to nothing in major project investments in 2016; in July 2023 it led the investment intentions pack at $8.2-billion. At that time the AESO predicted solar’s importance would continue to grow.
Humanity has forever converted landscapes to satisfy our ambitions, with Alberta renewables just one more chapter in that history. Utility-scale renewables compete for a place on the land with other human priorities, such as agriculture, oil and gas production, urban development and natural areas.
Southern Alberta, the preferred terrain for most of our province’s solar and wind projects, is already a very busy landscape. All the aforementioned uses plus more figure in 2014’s South Saskatchewan Regional Plan, ostensibly a land-use management blueprint for the region.
Land conversion is a downside of the renewables boom. The first generation of Alberta solar panels and wind turbines often were erected on lands previously set aside for agriculture. Native grasslands are Canada’s most threatened ecosystem. The Nature Conservancy of Canada estimates that since 1867 the prairie provinces have lost 75–90 per cent of their native grasslands. In southern Alberta, those grasslands, already sacrificed for cities, farms, ranches and oil and gas wells, have a fragile hold on the landscape. Only 1.3 per cent of the province’s grasslands are legally protected in a way that satisfies the International Union for the Conservation of Nature’s protected area definition. This dramatic shrinkage and these weak laws are why most Alberta species at risk are from grasslands. Utility-scale renewables threaten their further decline.
Between provincehood in 1905 and the Second World War, grasslands were converted to farming and ranching. Some of this land was later used for petroleum exploitation and urban expansion. Albertans became concerned about the loss of farm and ranch lands, so the South Saskatchewan Regional Plan was designed to “(m)aintain an agricultural land base by reducing the fragmentation and conversion.” In addition to threatening native grasslands, utility-scale renewables threaten farming and ranching livelihoods.
We can green our electricity grid while respecting agriculture and wildlife habitat.
The AUC decides the fate of utility-scale electricity projects. Its decisions can’t be overturned by the provincial cabinet; they can only be brought before the Alberta Court of Appeal on questions of jurisdiction or law. The commissioners who make the call on proposals such as Saddlebrook and Foothills are provincial government appointees. Most are lawyers, with engineers a close second, and most have joined the AUC since 2020.
The AUC has considerable discretion to decide the extent of public involvement in its proceedings. Generally, participants must show that a project “may directly and adversely affect” them. The law must recognize whatever right they assert. The AUC can allow still more Albertans to participate if they might contribute “relevant information.”
Taken together, the AUC decisions in the Saddlebrook and Foothills cases are promising. They tell us that a robust renewables future in Alberta doesn’t have to come at the expense of wildlife or agriculture. Saddlebrook’s approval was arguably an ideal utility-scale project, increasing renewable electricity supply without converting land otherwise useful for farming or wildlife habitat.
The MD of Foothills’s development plan forcefully commits to protecting farm and ranch lands. The Saddlebrook project respected that priority; the MD didn’t need to defend its farming and ranching heritage before the AUC. Heather Hemingway, the MD’s director of planning, considered Saddlebrook a good use of lands already zoned for industrial purposes.
Saddlebrook’s brownfield location also reduced its threat to wildlife. The government’s Wildlife Directive for Alberta Solar Energy Projects identifies site selection as “the first and most critical factor” in preventing harm to wildlife habitat. Saddlebrook wasn’t risk-free from this perspective, but wildlife managers concluded Saddlebrook presented few issues.
The project was a “win–win,” promising green electricity at a minimal cost. It met the AUC’s public interest test and was approved on December 17, 2021.
Elemental Energy’s Foothills project, however, was a very different story, and faced opposition on agricultural and environmental grounds. The MD, as a landowner in the project’s immediate vicinity, obtained standing to participate in the hearing. Hemingway told the AUC the MD couldn’t support Foothills, as the project failed the responsible-development test by proposing “to take high quality farmland out of production when there are other locations available on marginal land and outside of the area.”
But ultimately it was the potential environmental and wildlife harms of Foothills, not its appetite for farm and ranch lands, that sank the project. These revolved around Frank Lake.
For someone who spent much of his youth on Kootenay Lake in southeastern BC, I found Frank Lake’s environmental significance well hidden at first glance. Approaching the lake on Highway 23 just after dawn, it struck me as most prairie lakes do—small, shallow, unremarkable. But I stopped at the lake’s edge and was treated to the birdsong signalling its importance. American coots grunt and croak while cruising through reeds and grasses near the shoreline; courting northern shovellers bob their heads up and down; common terns hover in the air above the shallows before diving to chase a meal. But the American white pelicans, avian versions of Hercules air transports, were the most impressive that morning. They flew effortlessly, silently, just above the water before gliding to land amidst dozens of their kin.
Of the 256 bird species that frequent Frank Lake, 60 are at risk. Greg Wagner, the lake’s volunteer IBA caretaker, was a vital participant in the Elemental project’s hearing. The AUC described him as “a credible, helpful witness” who provided “material and relevant information” derived from decades of professional and volunteer experience.
The “lake effect” hypothesis made the Frank Lake site controversial. The phrase theorizes that, to certain birds, solar panel arrays resemble waterbodies; they become life-threatening attractants, especially to waterfowl. Birds will collide with the panels. If they aren’t killed outright, their injuries make them easier prey. This effect can be especially threatening to water-obligate species—species that can’t take off from land. Grebes, cormorants, coots and loons are among the water-obligates frequenting Frank Lake.
The AUC commissioners didn’t hear definitive answers about whether the Foothills project would lure many waterfowl to injury or death. Foothills’s consultant, referring to data from Alberta and the US, concluded “there are no data to better suggest that the [project] represents high risk to water-obligate birds than to suggest it does not represent high risk.”
Wagner agreed: no data definitively proved the project would threaten birds. But he wasn’t sanguine about this. He told the commission he viewed uncertainty, and the absence of mortality data from a comparable case to Frank Lake, as reasons to exercise caution. He reiterated Alberta Environment and Parks’s own conclusion that the project posed a high risk to birds. He cited the Canadian Wildlife Service’s conclusion that the location was too risky. Consequently, Wagner said, it would be poor land-use planning to allow Foothills to be built so close to an important conservation site.
Elemental Energy argued it had followed to the letter the legal standards. One of these is that a “solar energy project must not occur within 1,000 m of a named lake…” The Foothills proposal followed this standard… with six metres to spare. The southwest corner of its array would sit 1,006 m from Frank Lake.
The province’s wildlife directive also lists best management practices (BMPs) that “may assist” with site selection. These “are provided for information and consideration in the planning of solar energy projects to support better conservation and protection of wildlife and wildlife habitat.” But they’re not mandatory. Only one BMP pertains to site selection: “(T)he solar energy project should not occur within 1,000 m of a wetland-based Important Bird Area…”
Elemental Energy ignored this recommendation. Roughly 50 per cent of the Foothills site was within the IBA, and only 20 per cent was beyond the BMP’s 1 km buffer. The buffer error apparently was due to an environmental consultant’s having conflated this Frank Lake with another Frank Lake in northern Alberta.
The Commission wasn’t satisfied that Foothills, with 80 per cent of its project lying within the BMP’s 1 km setback from the IBA boundary, could justify ignoring the recommended buffer. This failure, together with Frank Lake’s significance to birds, concerns about the lake-effect hypothesis, and other direct and indirect negative impacts in the vicinity of Frank Lake, was enough to doom the project.
The Commission rejected Foothills. The project posed “an unacceptably high risk to the environment and is not in the public interest.” The AUC found the environmental risks so compelling, in fact, that it based its decision only on these grounds.
An orphan well site in southern Alberta that’s now a “brightfield,” with solar panels.
This decision is striking. The AUC has never before rejected a utility-scale solar project. Its 2022 Brooks Solar Farm decision reduced that project’s footprint but nonetheless approved the rest of the proposal. The array had initially been partially sited on native grasslands, and the AUC concluded this posed an unacceptable risk to grasslands-reliant species. The approved project excludes those lands.
In the face of uncertainty about the lake effect, the Commission effectively invoked the precautionary principle, a favourite of conservationists. The principle shifts the burden of proof from project opponents to proponents. The latter must demonstrate that their actions will not create unacceptable harm. The potential risks to birds compelled the Commission to reject Foothills. Caution won the day.
Taken together, the Saddlebrook and Foothills decisions point to how Alberta can increase clean electricity generation without compromising other values. They model an approach to renewables where “win–win” outcomes are more likely. They suggest that Alberta’s approval process isn’t flawed, and that a moratorium on renewables isn’t needed.
These decisions should push our government to insist that solar installations be built on brownfields. Saddlebrook shows that placing utility-scale solar on such sites significantly reduces potential harm to agriculture or the environment. Foothills suggests that environmental values should figure importantly in AUC decision-making.
Small solar arrays can accelerate oil and gas reclamation and reduce costs by over 50 per cent.
Putting solar installations on brownfields converts them to “brightfields,” a label the Bill Clinton presidency attached to a 1999 climate change initiative. That government called for repurposing old industrial sites and locating solar arrays there, thus converting them to sources of pollution-free electricity. Today, US president Joe Biden’s Inflation Reduction Act appears to be accelerating such conversions.
This is the path Alberta should follow once the misguided moratorium is lifted—especially given the alarming growth of oil and gas liabilities and brownfields in the province. In March 2023 the Auditor General reported that we now have more than 100,000 inactive oil or gas wells, more than twice as many as in 2004. The Alberta Energy Regulator estimates the closure liability of these wells—the cost to clean up and restore the land to its original condition—at $30-billion.
Keith Hirsche, founder and president of RenuWell Energy Solutions, wants to tackle this blight by converting abandoned oil and gas properties to brightfields. In the MD of Taber, RenuWell spearheaded a pilot project on two Orphan Well Association sites, called Barnwell and Fincastle. The MD plus a handful of governmental, corporate and educational actors support the project. The province’s Municipal Climate Change Action Centre and the Irrigation Canal Power Co-op invested $2.3-million and $1.5-million, respectively, in the project. The Power Co-op owns both small solar projects and uses the electricity generated to offset power used for irrigation.
A few minutes southwest of the town of Taber, the Barnwell site sits in the middle of fields branded with the telltale circular patterns of centre-pivot irrigation. Just north of it a canal cuts through the land, supplying Chin Lakes water to the pivots. During my informal tour of the Barnwell site in June, I heard that, since coming online at the end of March 2023, Barnwell has exceeded both its power and its revenue-generation predictions. Unlike some oil and gas companies that have reneged on their legal duty to pay taxes to MDs and make lease payments to landholders, the Barnwell project is no deadbeat. And its panels aren’t going to negatively affect the adjoining potato field that my boots sank uncomfortably deep into.
I asked Keith Hirsche about RenuWell’s claims that these brownfield-to-brightfield conversions would accelerate oil and gas reclamation and reduce costs by more than 50 per cent. He said the cost savings are related to the transfer of access roads, power lines and the vegetation restoration responsibilities from the oil and gas company to the solar operator. Removing roads and restoring vegetation are the most costly and time-consuming steps in the reclamation process.
This pilot project offers a small, sweet taste of what’s possible. If only half of the 3,000 inactive wells in the MD of Taber were converted to brightfields, 465 MW of electricity could be generated. This is how much power the Travers solar project, Alberta’s largest installation, produces. But Travers took 3,330 acres of farmland out of production; brownfield conversions wouldn’t remove one acre.
A variety of measures could put Alberta firmly on the brownfield conversions path. Our government should create a version of the US Environmental Protection Agency’s “RE-Powering Mapper.” This interactive online tool provides data for over 190,000 brownfield and related sites in that country. The US National Renewable Energy Lab has developed criteria for this tool to identify sites with renewable project potential. The EPA is working with the Lab to produce feasibility studies of where brownfields could profitably be converted to brightfields.
Tax and regulatory changes would help too. Alberta could follow the example of Biden’s Inflation Reduction Act and offer tax credits for renewable electricity projects on brownfields. Regulatory change could treat smaller-scale brownfield conversion projects (generating less than 5 MW) like large-scale micro-generation (between 150 kW and 5 MW). This would relieve proponents from paying interconnection and meter infrastructure costs and make investing more attractive.
The Saddlebrook and Foothills projects provide a clear lesson: brownfield conversions allow us to generate more renewable electricity while avoiding much of the controversy and harms that come from the conventional project-siting path. If Alberta’s UCP government and rural municipalities are genuinely concerned about losing valuable farmland to renewables, this is the path forward.
Ian Urquhart is a professor emeritus of political science at University of Alberta and former editor of Wild Lands Advocate.
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