823 Central Avenue, Prince Albert S6V 4V2
Suite 202, 220 20th Street West, Saskatoon S7M 0W9
www.cpaws-sask.org

Date: 18 July 2019
Government of Saskatchewan
&
City of Saskatoon
To:
Cc:

Geoff Meinert, Saskatoon Freeway Project Manager
Hon. Lori Carr, Minister of Highways and Infrastructure
Hon. Dustin Duncan, Minister of Environment
Charlie Clark, Mayor of Saskatoon
Randy Donauer, City Councillor (Transportation)
Sarina Gersher, City Councillor (SEAC)
Re: Saskatoon Freeway Project

We write in respect of the Saskatoon Freeway Project, a 55km stretch of divided highway that in part is
proposed to cut through the “ecologically sensitive area” (Saskatoon Freeway website) of the Swales in
the north east quadrant of the City of Saskatoon.
The Canadian Parks and Wilderness Society - Saskatchewan Chapter (CPAWS-SK) raises concerns that in
its current location this proposal has the potential to significantly impact critically important habitat.
Native grasslands are among the most endangered ecosystems on the planet and here in Saskatchewan
there has been a steady if not rapid decline of this increasingly rare habitat, seeing nearly 90 percent
lost to the cumulative effects of development and the broader cultivation of land. With only fragments
of this habitat remaining across the prairies of Saskatchewan it is imperative we do all we can and that is
necessary to cease any further degradation, loss and fragmentation of this critical habitat. We
encourage the Government of Saskatchewan and the City of Saskatoon to ensure major highway
operations, residential developments and other associated infrastructure in this location are subject
to the most stringent of environmental assessments and ensures, where critical habitat and at-risk
species are identified, avoidance measures (first solution) and robust/long-term mitigation plans (last
solution) are a requirement for any subsequent approval/decision.
LACK OF ENVIRONMENTAL DATA
With a lack of any detailed environmental assessment prior to determining the Freeway’s routing,
CPAWS-SK is concerned decisions and endorsements are being made without the necessary information
and without a complete and robust environmental assessment of the impact the Saskatoon Freeway
could have on the ability of this ecosystem to naturally function and to its potential negative impact on
important habitat and species, including Species at Risk. We are aware several minimal studies are being
undertaken during this summer (2019). Yet we remain concerned the purpose, timing and detail of such
studies will lead to inadequate data to determine the full extent of what is present across the area. This
includes the potential limitations of the ecological assessment boundary and how this assessment would

 best inform on the project’s wider impact and any subsequent mitigation plans. We therefore seek
further clarification on the extent of these studies and any additional research that will be used to
best determine and inform the location of the freeway and its likely impact.
Work already undertaken by the Meewasin Valley Authority (MVA) has identified numerous key species,
notably Species at Risk (SAR) and Species of Conservation Concern (SOCC), within the broader area,
highlighting the vital role this critical ecosystem is providing to the many species that rely on these rich
mosaics of wetland, riparian and grassland habitats. A recently published article looking at the
ecosystem services of the northeast Swale considers previous MVA assessments of the ecosystem which
identified “the planning and future development of adjacent residential neighbourhoods is an enduring
threat, that will shrink and further impact the Swale”1. Considering these studies alone, including work
undertaken by UoS PhD candidate Warrick Baijius2, who has identified current gaps in knowledge and
outstanding concerns, a healthy and functioning ecosystem plays a pivotal role in providing positive
benefits to society and biodiversity. It is concerning decisions have been and continue to be made on
this ecosystem where “there remains no serious discussion about the implications of climate change,
biodiversity, or conservation in any of the studies to this point” (Baijius, 2019).
The Saskatoon Freeway website states, as part of its environmental considerations, “through the
functional planning study, the Ministry of Highways & Infrastructure will work closely with stakeholders
to reduce or eliminate potential impact to this ecologically sensitive area.” Without access to the
project’s business case or any study or engagement plan addressing the economies of alternative
routing, we are left to hypothesis as to what these economies truly mean. We therefore must question
the above quote that looks to “eliminate” potential impacts. When we talk about the elimination of
potential impacts it is with the intention that any negative impacts to an ecosystem could and should be
avoided. We therefore remain concerned that no alternatives are being considered or presented.
We are further concerned to hear that the City of Saskatoon and the RM of Corman Park have endorsed
this project through the Swales before a comprehensive ecological assessment has been undertaken.
We would certainly like to better understand the City of Saskatoon’s position on this project, especially
in relation to the relevant environmental policies and further processes to be considered.
While we welcome any intention to reduce and eliminate potential impacts to this ecological sensitive
area, without a comprehensive ecological assessment and mitigation plan there remains a likelihood of
harm to this critical habitat as a result of this project. Therefore, the direct loss, degradation and
fragmentation of wetland, riparian and grassland habitat remains of critical concern to CPAWS-SK.
CONCLUSION
Our urban environments are not immune to the effects of climate change. We place ourselves at even
greater risk to the effects of climate change when we degrade, fragment and eliminate important
natural spaces. Municipalities are clearly engaged in the need to develop a response in the form of
policy and strategy to address their role, impact, and solutions to this very real and pressing issue. The
Federal government has also underlined the pressures our urban and wilderness environments are
experiencing by declaring a climate emergency, and Canada alone is already reporting higher than
normal warming compared to other parts of the world.
We have separately acknowledged work under way on an ‘offset scheme’ by the province to address
GHG emissions and have provided concise comments centred on the need for nature-based solutions.
1

A GIS-based model of ecosystem services for the Northeast Swale in Saskatoon, Saskatchewan - Spatial Knowledge and Information Canada,
2019, 7(1), 4, RONG SHEN, HONGHAO YU, ET AL - http://ceur-ws.org/Vol-2323/SKI-Canada-2019-7-1-4.pdf
2
Comprehending Swale Ecosystems: Research Synthesis and Analysis, Warrick Baijius, 2019 https://artsandscience.usask.ca/news/articles/3737/_Nature_needs_space_New_USask_report_makes_recommendations_t

 This would see the protection and better management of forests, wetlands and grasslands by
governments as the ideal solution. Nature-based solutions offer a valuable and overdue strategy for
combating climate change while protecting the province's unique biodiversity, for which the Swales
represent a strong and robust example of this solution.
With the implications of a major development proposal through the Swales, it is essential that the longterm interests of grassland, wetland and riparian habitat and their associated species, including species
at risk, are a priority consideration for the Government of Saskatchewan and municipalities in the
decision-making process. Whilst economic development in our province is necessary, the unnecessary
degradation, loss, disturbance and fragmentation of one of the most endangered ecosystems on the
planet is not. We see this project as having the potential to negatively impacting critical native grassland
habitat, important wetland and riparian habitat and their key species. We feel there must be a decisive
voice when it comes to tackling climate change and biodiversity loss from all levels of government in
Saskatchewan on this matter.
We see the prioritization and protection of this ecosystem as critical for its value to broader climate
action, to society as an important cultural and natural space, and to the species that make it the
ecologically and culturally important area it is and has been for thousands of years. We would suggest
there is significant value (social, cultural, economic, environmental) to be harnessed from the long-term
protection of this natural ecosystem for the benefit of all.
With only 11.8% of Canada’s land and freshwater protected as of Spring 2019 – less than 10% in
Saskatchewan – as part of the internationally agreed 17% protection target by 2020, it is abundantly
clear – we can and should be protecting much more. “…Its achievement will require the collective
contribution of federal, provincial and territorial governments, Indigenous organizations, municipalities
and local governments, non-profit organizations and the private sector” (CCIUCN)3 to adequately meet
this target and to continue in the same vane towards the milestone CPAWS advocates to protecting 30%
of land and freshwater by 20304.
The greater conversation that should come from this is providing this important ecosystem the
protection it deserves and ensuring we are leaders in environmental protection and the fight against
climate change. Should you have any queries regarding these comments, please do not hesitate to
contact us.
Yours sincerely,

Stewart Coles
Manager of Operations and Programs (southern region)
Canadian Parks and Wilderness Society – Saskatchewan Chapter
scoles@cpaws.org

3
4

IUCN Canadian Committee (CCIUCN), Pathway to Canada Target 1 - https://cc-iucn.ca/category/pathway-to-canada-target-1/

Canadian Parks and Wilderness Society (CPAWS), July 17, 2019 - https://cpaws.org/cpaws-calls-for-urgent-and-ambitious-action-to-tacklecanadas-nature-emergency/?fbclid=IwAR3qcoKvlS96nlmz-euemyjE3C4DeEe2emelKcpWyG_M5eg3K7Vb-Q9TjZo