12030-20/site c brian murphy, executive project director ... · section 4 - project description...

Ministry of Forests, Lands and Natural Resource Operations

Regional Operations North Area

Mailing Address: PO BOX 9352 Stn Prov Govt Victoria, BC V8W 9M1

Tel: 250-952-0596 Fax: 250-356-2150 Website: www.gov.bc.ca/for

12030-20/SITE C April 4, 2013

Brian Murphy, Executive Project Director Environmental Assessment Office Linda Jones, Panel Manager Canadian Environmental Assessment Agency By email: [email protected] [email protected] Dear Mr. Murphy and Ms. Jones: RE: Proposed Site C Clean Energy Project Environmental Impact Statement (EIS) Review

Thank you for the opportunity to comment on the EIS for the proposed Site C Clean Energy Project. The following package represents the collated comments of the BC Provincial Government Natural Resource Sector (NRS) Agencies, which are comprised of the Ministry of Environment, the Ministry of Aboriginal Relations and Reconciliation, the Ministry of Energy, Mines and Natural Gas, the Ministry of Agriculture, and the Ministry of Forests, Lands and Natural Resource Operations and all of the associated divisions within these agencies that participated in this review. The BC Ministry of Transportation and Infrastructure has also provided comments to be submitted with the NRS agencies as part of this review. It should also be noted that our review has been focused on the sections and Valued Component’s (VC’s) relevant to the mandates of our various ministries. BC Hydro has completed a variety of studies, conducted extensive analyses and collected significant amounts of data on many values to support this project. This has resulted in a comprehensive package that contains significant information that, regardless of the outcome of this Environmental Assessment process, provides great value to the Province of BC. Many of the NRS agencies have been working with BC Hydro staff on various aspects of this project and we are aware that more detailed permitting level information related to this project is still under development and has not been included in the EIS as it is not required by the EIS Guidelines. Our review has focused on the content of the EIS as provided, and where information appears to be incomplete or missing; comments have been included to that effect. It should also be noted, that, while not the focus of this exercise, in some cases spelling or grammatical errors have been identified by staff, these have been included for completeness.

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Throughout our review it was noted that many comments are directed at clarifying if and where in the report, additional information on a subject may be available. It is suggested that BC Hydro include more complete references as to where additional information can be found, as it is not always clear when reading a section that additional information is available elsewhere in the document. It was also noted that the EIS did not always effectively use the available data referenced in appendices to support the conclusions made within the sections of the EIS. Commenting on the EIS is an important step in ensuring all projects are subject to careful and rigorous environmental review by the NRS agencies. Our review has identified the following areas of concern, in addition to our attached detailed comments. Level of detail contained within the Mitigation and Management Plans

We have noted that the EIS contains varying levels of detail regarding the mitigation plans, management plans, and follow-up programs. We understand that many of these plans are provided at a more detailed level at the permitting stage. Therefore, the NRS agencies take the view that as long as the proposed mitigation is feasible, reasonable or the proposed technology or approach has been used successfully elsewhere, then we are fine with the level of information provided at the EIS stage knowing that detailed plans would be required prior to permitting decisions. However, in some instances, these plans were heavily relied on as rational for assumptions and findings. To address this, the NRS agencies request BC Hydro include any developed plans, and specifically those plans that have been used as rationale for findings, into the amended EIS. Additionally, the NRS agencies request BC Hydro to provide a schedule of when the remaining mitigation and management plans will be available for review as part of the permitting process. Governance Structure for Mitigation and Compensation funds and Programs

Various forms of compensation programs have been identified in the EIS for many different VC’s. The NRS agencies note that use of common governance structures for these mitigation and compensation funds and programs would be helpful to increase efficiency and reduce confusion due to differences in programs wherever possible. For example we are aware that BC Hydro currently funds programs such as the Peace Williston Fish and Wildlife Compensation Program, and we encourage BC Hydro to explore synergies with existing programs or develop new ones as required. Consistency with standard data collection analysis procedures and guidelines

While BC Hydro has collected significant baseline data on several indicators and values, and conducted extensive analyses on these values, it appears in many cases that BC Hydro has used different standards than usually used by the province to collect and analyze these data. Examples include; hydrologic assessments, base mapping for ecosystems, and fish and fish habitat assessments. While it is possible that the standards used for data collection and analysis of these values are equivalent to or better than those commonly used in BC, limited rationale or background has been provided to support this. It is recommended that BC Hydro include

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rationales for the methods used so that it is clear that the appropriate standards are met or that the proposed equivalents are documented as being equal or better in quality and reliability. This information would also further support the assessment of findings. Implementation of Effects Assessment Methodology with regards to Fish, Wildlife and Ecosystem Resources

A large portion of the NRS agency comments contained in the attached table relate to how the Effects Assessment Methodology outlined in the EIS Guidelines was implemented with regard to fish, wildlife and ecosystem values. We look forward to receiving BC Hydro’s responses to our comments; however, the NRS agencies may request further discussion on this issue in May or June so that we may gain a better understanding of the processes used and the information that went into the findings. Project Access Road

It is not entirely clear at this time that BC Hydro has provided sufficient rationale to support the construction of a new access road to the project site in addition to the existing infrastructure. Additional rationale will be required to justify the expectation that access and use of this road be restricted to the public and other industry. While analysis of alternatives was conducted and included in the EIS, it is not clear that BC Hydro has fully considered the potential impacts of constructing this road, and how reliance on this road could be reduced through further use of rail, as well as upgrading existing infrastructure. Further work on this issue may be required to determine if construction of this road as proposed is the best option, not just from a financial perspective, but also from an environmental and social perspective. We believe that many of our concerns and issues with the EIS can be addressed by BC Hydro in the coming months prior to the establishment of a Joint Review Panel. Should EAO or CEAA require follow up on any of the comments or questions contained in this response, please feel free to contact me so that you may be directed to the appropriate agency contact. Sincerely,

Gary Reay Executive Director, Strategic Projects Natural Resource Sector Lead, Site C Project ec: Natural Resource Board Members NRS Assistant Deputy Ministers

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April 4, 2013

Site C Clean Energy Project

Environmental Impact Statement Review Comments

Comments provided by the following BC Provincial Government Natural Resource Sector Agencies:

Ministry of Environment Ministry of Aboriginal Relations and Reconciliation Ministry of Energy, Mines and Natural Gas Ministry of Agriculture Ministry of Transportation and Infrastructure Ministry of Forests, Lands and Natural Resource Operations

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B.C. Natural Resource Sector Agencies Site C Clean Energy Project

EIS Review Comments

Section # Page # Line #Comment

# Comment EIS Guidelines

n/a n/a 1

Various forms of compensation programs have been identified in the EIS for many different VC’s.

The NRS agencies note that use of common governance structures for these mitigation and

compensation funds and programs would be helpful to increase efficiency and reduce confusion

due to differences in programs wherever possible.

Exec

summary Pt

2

63 2

Table – Key Mitigation Measures Bullet 2 - Bullet notes stockpiled surplus available to other

aggregate users. It should be noted that in MoTI pits and quarries, these will only be available to

BCH and MOTI

2.3 9, 10 11, 17 3

For ease of reference please further define which document readers are being redirected to as

there are multiple individual documents within Appendix C and F. i.e. - "see Appendix C for

discussion on definition of merchantable forest"

2.6.2 14 28 4

Please Clarify - Would Land Filling as a method of non-merchantable debris disposal be considered

for areas that are to be inundated? If so, have potential adverse effects of this to water quality

been assessed?

4 23 1 5

The re-alignment of Highway 29 proposes an 11 meter span pipe arch at Dry Creek. Indications are

that Dry Creek has significant bed load deposits. Has aggredation at the crossing and the potential

for it to reduce the ability of the structure to pass the required water flows and any floating debris

in the upstream pond been considered? Note: This scenario caused the plugging and the

subsequent failure of the Holdich Creek Pipes, resulting in the loss of several hundred meters of

Highway 23 in 1999.

Section 1 - Introduction - No Comments

Section 2 - Proponent Description

Section 3 - Project Overview - No Comments

Section 4 - Project Description

Volume 1

Final April 4, 2013 1


EIS Review Comments



4.1.4 6 6

"Peace River-Boudreau Lake Protected Area" - please note this spelling should be used consistently

throughout the EIS. p. 35 S. 8.5.3.2

4.1.4 6 7

The EIS guidelines identify that the proponent is proposing to search for projects and activities that

will be carried out within the RAA to be taken into account in the Future Case without the Project

and in the Project Case.

The proposed Peace River-Boudreau Lake Protected Area is mentioned in several locations of the

EIS, but with the exception of the information in the Outdoor Recreation section, no direct analysis

of the Project’s impacts to the proposed protected area’s values has been provided. Should the

Project be approved, a reduced area (and associated values) would be available for provincial

protection. Request: Please clarify

the effect of the project on the proposed Peace-River Boudreau Lake Protected Area both in the

text, and spatially (where appropriate). A listing of specific values can be found in the Fort St. John

and Dawson Creek Land and Resource Management Plans. Outdoor Recreation section analysis

located in Vol. 3, S. 25 (page 25-25) lines 1-9 and Table 25.14.

p. 35 S. 8.5.3.2 s

4.3.5.2.3 3026 to

298

In the report there is a statement for the West Pine Quarry “The source of this permanent riprap

and bedding material is the West Pine Quarry, located on provincial Crown land approximately 75

km southwest of Chetwynd along Highway 97 (approximately 160 km from the Project site).” There

is nothing indicated in the report that States BC Hydro will prove out a suitable quantity and quality

of rock from the BC Hydro portion of the quarry to replace the material they will remove from the

MO TI portion of the quarry. This has been brought this to BC Hydro’s attention prior to this

review. Please address in the EIS.

4.3.7.1 37 10-19 9

Request - Figure 4.34 Map – it appears that this map omits 271 Road to Wuthrich quarry and "Howe

Pit entrance". Please add all appropriate access roads.



EIS Review Comments



4.3.7.2.1 37, 3839-41,

1 - 510

"Access to the dam site area via the Project access road would be controlled 24 hours a day, seven

days a week throughout the construction period, so that only authorized traffic would use the

road." - Please provide a rationale for requesting restricted access to the Project Access Road.

4.3.7.2.1 37, 3840-41,2-

411

"After Construction..." Decisions on the level of access post project construction and

decommissioning of alternate access routes should be made prior to final design and application for

tenure of the Project Access road, as these considerations may factor into road design, cost, and

details and conditions of a potential tenure, and will have effects on the public and other tenure

holders.

4.3.7.2.1 38 6-8 12

It is not clear that the existing rail access and construction of the rail siding was considered in the

analysis of Alternate Access Routes in section 4.3.7.2.2. Please clarify if the level of rail use was

included in the analysis. If more concentrated effort is put onto moving construction materials and

equipment by rail transport to the site, are lower impact access road options being considered?

4.3.7.2.1 38 4-5 13

Please Consider adding additional description of deactivation and reclamation options for existing

road network after the Project Access Road is constructed and in service.

4.3.7.2.2 38 21-41 14

Alternative Access Routes Considered: Please consider adding additional information on

consideration of the alternatives to the Project Access Road. Efforts should be made to minimize

project footprint wherever possible, please discuss if consideration was given in the analysis to

building the Project Access Road to a standard that allowed for all anticipated industrial and public

traffic to the vicinity of the Project construction site.

4.3.7.2.2 38 21-41 15

Alternative Access Routes Considered: Section 4.3.7.2.1 - Page 4-38, Lines 9-11 discuss upgrading

the existing road network to a suitable standard until the Project Access Road is constructed.

Please clarify if the cost and impact of upgrading the existing road network was included in analysis

of this section.



EIS Review Comments



4.3.7.4 39 35-36 16

“Some additional access roads may be required to individual structures and work sites.” EIS

Guidelines states that: “The EIS will describe all the facilities ... including access roads required for

clearing, construction and maintenance of the transmission line.” Please add the additional detail

required for consistency with the EIS Guidelines.

3.3.4

4.3.7.5 40 1-11 17

This section describes the construction of access to the proposed Hudsons Hope berm, but does not

reference a map. Please consider adding a map for clarity.

4.4.3 44 2-3 18

Schedule of activities in Figure 4.40 shows “Construct temporary facilities (including camps)“ and

“Clear and grub north and south banks” (presumably provincial jurisdiction) before “Federal

authorizations”. Please clarify what Federal Authorizations are referred to in this graphic. Is it

anticipated that any of these Federal authorizations would be required for the construction of

temporary facilities or for the clearing and grubbing of the north and south banks?

5 1923 to

2519

Please elaborate on the three bullets that discuss the issues with capacity from the market.

5 15 1 to 4 20

Re. Table 5.9 - What percentages of capacity savings forecast by 2021 (1400 MW) are attributed to

energy-focused vs. capacity-focused measures?

5 15 1 to 4 21Re. Table 5.9 - What prospective capacity measures have been considered for the commercial and

residential sectors in the analysis?

5.2.2.3 22 1 to 6 22

To what extent have any delays in timing (i.e. to potential delays in the EA process, permitting,

construction, etc.) to the in-service date of the Project been factored into this analysis?

Section 5 - Need for, Purpose of, and Alternatives to the Project



EIS Review Comments



5.3 22 1 to 4 23

For clarity, consider adding explanations to tables 5.13 and 5.14 as to why the 5,100 Gwh/year of

energy and the 1,100 MW of dependable capacity from the Project do not appear to factor “in full”

starting with the in-service date in 2022.

5.3.1 24 6 to 7 24

Please restate the first Clean Energy Act Objective in Table 5.15 as it appears in the table in full as

amended by July 24, 2012 Order In Council No 572 “ British Columbia’s Energy Objectives

Regulation”

5.4.2.4 3711 to

2325

Has BC Hydro considered the experiences of other jurisdictions in terms of addressing DSM

uncertainties and Is BC Hydro's treatment of DSM uncertainty in line with the practice of other

utilities?

5.5.4.2 68 19 26

For clarity, please consider adding an explicit explanation to the EIS that in Fig 5.12 Effective Load

Carrying Capability of wind resources does not count as dependable capacity and that this is

consistent with standard utility practice

6 n/a n/a 27

General comment on section - Based on the information provided in the EIS Section 6 and

appendix E, it is not clear how the environmental benefit of leaving the Moberly River free-flowing

(i.e.- moving the dam upstream of the mouth of the Moberly) was evaluated. Please clarify what

values were considered and how were these incorporated. The assessment is potentially clouded

by evaluating each option against a myriad of parameters that may not be relevant to the key

question re: the feasibility and cost-benefit of moving the dam upstream of the Moberly.

Section 6 - Alternative Means of Carrying out the Project



EIS Review Comments



6 n/a n/a 28

General comment on section - The information provided in the EIS Section 6 and appendix E

suggests that the magnitude of the impacts on the Moberly River was not represented correctly as

it is not consistent with the fisheries evaluation that reasonably predicts that the Moberly River

stock of Arctic grayling have a high likelihood of going extinct. Further, back-flooding the mouth of

this river will have a cascade of effects that will substantially change the Moberly at the ecosystem

level and the loss of these ecosystem values has not been considered. While it is appreciated that

there was a sensitivity analysis that includes weighting the Moberly very heavily, the inputs need to

be credible to ensure that the weighting is meaningful

6 n/a n/a 29

General comment on section - The information provided in the EIS Section 6 and appendix E

indicate that the evaluation of benefits and effects was undertaken using expert solicitation

approaches. It does not appear that NRS agency staff who are very familiar with this watershed

were included in the expert approach. Please clarify who was involved in the environmental

evaluation for the alternative assessment. Please re-evaluate be using the full range of impacts

that would be avoided by relocating the dam.

7.1.2.1 3 12 30

“Within the 97% Clean Energy Act clean or renewable Target” – this statement is incorrect, Part 1

Section 2 (c) states B.C.’s energy objective as: “(c) to generate at least 93% of the electricity in

British Columbia from clean or renewable resources and to build the infrastructure necessary to

transmit that electricity” – Please change 97% to 93% or rationalize why 97% has been used here.

7.1.3 5 4 to 14 31

In explaining the expected annual cost to rate payers when comparing the portfolios, please clarify

the material differences between the assumptions for expected recovery of the Project’s annual

cost and the assumptions for the expected recovery of the costs of the alternative portfolios.

Section 7 - Project Benefits

Section 8 - Assessment Process



EIS Review Comments



8 19 32

EIS Guidelines “This subsection will include a list of supporting references used in this section of the

EIS.” It appears that this information is not included in the EIS, Please add.

6.5

8.4 12 24-28 33

“Under Section 32 of the Hydro and Power Authority Act, R.S.B.C., 1996, c. 212, except as otherwise

provided under that Act, BC Hydro is not bound by any statute or statutory provision of British

Columbia." A list of potential key federal and provincial permits that would be required by BC

Hydro for construction or operation is shown in Table 8.1. There are several acts and authorizations

listed in Table 8.1 that are not listed under Section 32 of the Hydro and Power Authority Act.

Consider providing a rationale for that legislation that BC Hydro has noted that does not apply to it

under section 32 of the BC Hydro & Power Authority Act.

8.4 12 24-28 32

Please clarify if there are any instances or circumstances in which BC Hydro may not apply for the

standard authorizations as noted in Table 8.1, and if so, please consider discussing what standards

would BC Hydro follow in these instances.

App A2 of

1086 33

Does the calculation of wood utilization/disposal include sites required for temporary

accommodations. Additionally, as the majority of wood utilization/disposal is anticipated to occur

early in the project, within the reservoir activity zone, how will natural re-vegetation be dealt and

would such re-vegetation be a wildlife year-round/seasonal attractant prior to reservoir infilling?

App A Exec

Summaryii of xv 20 - 21 34

For clarity, please reword "as defined by British Columbia's Ministry of Forests, Lands and Natural

Resource Operations" to reference the Interior Appraisal Manual, Table 1-1 Interior Merchantability

Specifications.

App A

Introduction

1 of

10810 - 12 35

Correction Required: "based on Historic utilization by the forest industry within the Peace Region”

–Merchantable timber is not based historic utilization, please remove this statement

Section 9 - Information Distribution and Consultation - Not Reviewed

Appendices for Volume 1



EIS Review Comments



App A

Introduction

1 of

10810 - 12 36

Correction required: Merchantable timber is defined by the Cruising Manual as authorized under

the Forest Act not by the Ministry of Forests Lands and Natural Resource Operations.

App C1 4.5 10 37

“...the future use of the site should be considered in relation to the official community plans of both

the regional and local government.” Please consider discussing final use and reclamation in more

detail at this stage so that measures to reclaim the land can be built into the plans. (Eg: plans to

save and store topsoil so it can be used in reclamation later need to be made before the topsoil is

stripped. Also final safe contours should be planned before excavation.)

App C2 3.0 410th

bullet38

“Setback boundaries range from 5 to 44 metres from the property line.” Figures 4.2 shows well

sites immediately adjacent to the southern boundary, which in the figure appears to be one of the

narrow (5m) setbacks. Please clarify if consideration has been given to blasting in this quarry in

regards to the 5m setback from existing development.

App C3 4.1 7 39

Information Requested - Area proposed (yellow line) is very much larger (~10x) than area for

proposed use (purple line, Green polygon and Roads). This area also overlaps a drainage, a

separate ridge and an existing road. Please provide a rationale for the large size identified or

reduce the area identified to more closely reflect what is actually needed. Also, Please clarify

whether analysis and assessment of potential effects reflected the larger identified area, or the

smaller area actually identified for use.

App C3 5.1 81st

paragra

ph

40

Appendix C2 P4, App C3 P8, For the percentages of yield vs. wastage discussed in the various quarry

development plans, please identify the standards and parameters that BC Hydro is using and

discuss - i.e. Portage Mountain Quarry (appendix C3) - 35% yield / 65% wastage, Wuthrich Quarry

(appendix C2) - 20% yield / 80% wastage



EIS Review Comments



App C3 5.1

and 5.68 & 11

2nd

paragra

ph

41

5.1:“The site would remain an active quarry under the control of BC Hydro for its use.” And 5.6:

“BC Hydro would continue to operate the Portage Mountain Quarry. ...” For clarification, future use

of these sites would likely be the subject of future applications and statutory decision. Please

propose reclamation appropriate for possible/eventual closure of the quarry.

App C3 5.2 81st

paragra

ph

42

“as shown in Table 6.1” There does not appear to be a Table 6.1. in this appendix, it seems that

this reference should be to Table 5.1, please correct or clarify.

App C3 5.3 95th

bullet 43

If the locations of structures and facilities have been contemplated or are know at this time, such as

offices, maintenance and storage areas for fuel and explosives etc. please consider including on the

associated map (figure 4.1) in this and other similar sections of the EIS. This statement also

indicates that explosives may be stored on site, which contradicts other statements in this section

to the contrary. Please clarify or correct.

App C4 7 9 44

Request: report notes that “The Ministry of Transportation and Infrastructure and BC Hydro have

agreed that BC Hydro can develop the lower ridge along the Canadian National Rail line as well as

stockpile and load in areas contained within their map reserve tenure.” There is nothing indicated

in the report that States BC Hydro will prove out a suitable quantity and quality of rock from the BC

Hydro portion of the quarry to replace the material they will remove from the MO TI portion of the

quarry. MOTI has brought this to BC Hydro’s attention prior to this review.

App C4 All 45

There is no mention of truck/equipment wash station or washroom facilities in this section, as has

been described in other appendices. Please clarify if this was overlooked, or if these facilities will

not be established at these sites. If these facilities are not going to be established, please consider

providing a rationale why not.

App C4 1, 2,

4.2

6, 7,

11

Para2,

P2, P146

throughout this section, the map is referred to as both “Figure 1.1.1” and “Figure 1.1" please

correct for consistency.



EIS Review Comments



Appendix C1

- C547

Quarry Development Plans - Reclamation and Future Use & References: It is not clear, based on

section 8.4 or Table 8.1 that BC Hydro will apply for a Notice of Work under the Mines Act, or

whether or not this legislation applies to these sites. In either case, it is suggested that BC Hydro

include reference to the "Health and Safety Reclamation Code for Mines in BC". This should also be

the standard used for devlelopement, reclamation, safety and other associated activities unless

stated otherwise for the quarries in question.

Appendix C1

- C548

Quarry Development Plans - Reclamation and Future Use: It is not clear in the EIS whether the

Quarries are considered to be "temporary construction facilities" or not, however if this is the case,

section 3.3.11 of the EIS Guidelines states that the EIS will describe "Decommissioning of temporary

construction facilities and any associated reclamation" . The appropriate sections of the Plans do

not go into detail regarding proposed reclamation. Please consider including additional

information.

Appendix C1

- C549

Quarry Development Plans - Temporary and final slopes: Please clarify the standards or criteria

that have been used to identify the final temporary (1.5H:1V etc.) and final slopes (2H:1V etc.) and

face heights. A rationale discussing adequacy of these slopes including discussion of angle of

natural repose would be helpful.

10 50

Pedogenic soils are not identified as a valued ecosystem component nor are they addressed in

relationship to ecosystems or forestry. Productive soils were not selected as a VC. Instead, soil is

addressed under VCs Agriculture. Enduring features and geodiversity have not been identified as VC

or addressed.

8.3

Volume 2Section 10 - Effects Assessment Methodology



EIS Review Comments



10 51

Description of VCs - Overall Methods

Issue: The Definitions section of Volume 2 defines "baseline" as follows: "Air quality conditions, in

terms of emissions or ambient concentrations, associated with existing sources in the study area,

including all human-caused and natural sources."

Concern: This definition is incorrect; baseline is described for more values than Air Quality.

Request that the Proponent:

Expand the definition of "baseline" under Definitions to include more than air quality.

10 52

Overall Methods

Issue: It is not clear how uncertainty has been considered and incorporated into the assessment.

Concern: Given that information used to assess values will be imperfect, considering that

environmental and ecological processes are stochastic and constantly changing, and considering

that activity impacts have a certain likelihood of occurring, there are a number of uncertainties that

play into the assessment of each VC.


Clarify how uncertainty has been evaluated throughout the various stages of VC selection and

assessment.



EIS Review Comments



10.1 10 30-31 53

Overall Methods

Issue: Section 10.1 refers to the preparation of "A framework for environmental management to

be implemented during construction and operation of the Project." (pg 10-1 line 30 - 31)

Concern: The framework for environmental management is introduced in section 10.1 without

information on what it is and how it was developed.


Provide more information about the “…framework for environmental management…” (section

10.1). What is this framework based on? What does this look like?

10.2 54

Selection of VCs - Overall Methods

Issue: Section 10.2 sets out a list of questions used to identify candidate VCs (page 10-2 line 14) but

does not provide more information on how candidate VCs were selected.

Concern: The process of identifying VCs reported needs to be described in more detail for

transparency.

As a general comment, it is counterintuitive that things like “contaminated sites”, “greenhouse

gases”, “noise and vibrations” are considered as Valued Components. These are not components

that are valued, they are disturbances to mitigate against.


(a) Clarify if there is a standardized process for the identification of candidate VC’s based on the

questions listed in Section 10.2. Was the identification of VC’s based simply on “considering” the

questions listed?

(b) Consider aligning approaches for VC selection with Provincial Values initiatives like

Environmental Mitigation, Cumulative Effects Assessment, and Values work.



EIS Review Comments



10.2.2 55


Issue: The assessment of interactions is described only in very general terms in section 10.2.2.

Concern: It is not clear how interactions were assigned to each candidate VC. The Proponent will

be working with imperfect information so it is important to describe how uncertainty is managed.


Clarify the following:

(a) What is the definition of an interaction for the purposes of these assessments?

(b) What spatial and temporal boundaries were used when considering interactions between

project components and VC’s (e.g., LAA only or LAA and RAA?) Did this process consider

interactions where there may be a significant lag time between the activity and the effect e.g., as

with watershed processes.

(c) How was uncertainty incorporated into this analysis of interactions?



EIS Review Comments



10.2.3 56


Issue: From the EIS: "Step 3 in VC selection involved the question of whether the effect of an

interaction on each candidate VC carried through could be effectively assessed under a separate

and related, but “more appropriate”, candidate VC." (Section 10.2.3). Thus, individual candidate

VCs, such as “migratory birds”, “ungulates”, or “bats” are merged into “Wildlife Resources”.

Concern: Aggregating VCs leads to a significant challenge in interpreting the ecological

consequence to individual VCs. Aggregation of VCs results in a mixing and lack of clarity as to which

Project activities result on which adverse effect on which individual VCs; how effectively the

resulting Residual Effects are mitigated; and how “significance” can be determined for residual

adverse effects related back to specific VCs.


(a) Individual species groups should be considered as separate VCs so that mitigation measures,

residual adverse effects, and significance can be determined and demonstrated – and effectiveness

tracked – by species group (or species) instead of being generalized across the aggregated VC of

Wildlife Resources.

(b) What were the principles and process used to determine which VC’s can be appropriately

represented within another assessed VC?

(c) What other considerations were used to assess for alternate VC representation aside from the

similar effects pathway?



EIS Review Comments



10.3.1 4 20 57

Assessment of Impacts - Overall Methods

Issue: The spatial boundary of the Project Activity Zone (PAZ) does not include existing

infrastructure “that will be used without modification” (Page 10-4, line 20, Table 10.1).

Concern: It is likely that portions of existing infrastructure, while not requiring

modification/upgrades, will experience increased duration/frequency of vehicle traffic.


Clarify whether there has been an assessment of the potential impacts to wildlife resources of

increased duration and frequency of vehicle traffic on existing roads outside of the PAZ. Is this issue

addressed in the assessments for the LAA and/or RAA?



EIS Review Comments



10.3.1 58


Issue: From the description in section 10.3.1 Spatial Boundaries (pg 10-4 lines 6 - 19) it appears

that a spatial assessment unit is attached to the VC (i.e. wildlife resource, vegetation and ecological

community) but multiple “groups” are assessed within a VC (eg. For the wildlife resource VC, groups

like butterflies & dragonflies, migratory birds, ungulates, carnivores, etc. are assessed as indicators).

Concern: The spatial assessment unit for localised dragonflies would be considerably different than

that for wide-ranging ungulates. This will ultimately misrepresent the actual condition of the

assessed group depending on spatial ecological factors for each group assessed. Also, it is not clear

how “characteristics” for VC’s were compiled to define the LAA; again, groups within a VC are

ecologically very different from one another so its difficult to know if the LAA is appropriate for all

groups assessed.


(a) Clarify how the EIS reconciles the differences in spatial scales appropriate to organisms that

vary considerably in size and home range.

(b) Describe how aboriginal traditional knowledge was used to inform spatial scales and extent of

potential changes.

(c) Describe the inputs to the definition of the LAA boundary.



EIS Review Comments



10.3.1.1 6 59


Issue: The assessment area for Harvest of Fish and Wildlife Resources in the PAZ defined in as

“within reservoir impact lines and the Peace River downstream to the Alberta border” (Page 10-6

line 10 Table 10.2).

Concern: Displacing harvesting (fishing and hunting) effort in the Project Area Zone may increase

harvesting pressure in adjacent areas. The assessment of impacts to hunting and fishing and,

therefore, to wildlife, need to look at areas outside of the PAZ.

Request that the Proponent: Clarify if the assessment includes an analysis of the implications of

displaced harvesting of fish and wildlife from the PAZ; will this increase and/or initiate harvesting

pressure in other areas? If so, what are the anticipated impacts?

10.3.2 6 10 60

Mitigation and Monitoring - Overall Methods

Issue: Section 10.3.2 Temporal Boundaries, states that "construction will occur over an eight-year

period, and the Project is intended to be operated and maintained over the long term with no

future decommissioning contemplated.

Concern: Long term monitoring is essential, especially if future decommissioning has not been

considered.

Request that the Proponent: Clarify intentions regarding long-term monitoring of VC’s given the

timelines described for Project construction and operations e.g., relating to potential lag time of

effects, species with multi-year cycles, effectiveness of mitigation?



EIS Review Comments



10.4.1 61

Description of VCs - Overall Methods

Issue: Section 10.4.1 does not provide a definition of what is meant by "baseline condition".

Concern: Section 10.4.1 describes the information that accompanies the baseline descriptions (the

relevant legal framework, methods used to collect baseline data and the sources of baseline

information) and states that "an overall baseline description is provided" (from the EIS Guidelines

section 8.5). However section 10.4.1 does not provide details as to what the baseline includes.

Section 10.1.5.2 identifes a demarcation date (September 5, 2012) for the Baseline Case for

Cumulative Effects Assessment (CEA). It is not clear whether the baseline conditions outside of the

CEA are similarly demarcated. It is also not clear what spatial area the baseline describes for a

given VC - the PAZ? the LAA? Is the RAA applied for assessments outside of the CEA?

In general, the current conditon of all VCs should be described or presented in a manner that allows

a reasonable assessment of Residual Effects. Baseline conditions should be described in the context

of a spatial scale relevant and appropriate to each VC being assessed. To the extent possible, this

information should allow a quantitative assessment of Residual Effects in comparison to current

condition.


Provide a more detailed definition in Section 10.4.1 of a "baseline description". This should include

a description of the spatial and temporal boundaries applied to each VC.



EIS Review Comments



10.4.2 62


Issue: From the EIS: "All project/VC interactions noted as “2” were carried through to the effects

assessment (where “2” = Interactions may result in adverse effect and the nature of the effect

and/or effectiveness of mitigation measures is uncertain)" (Section 10.4.2, pg 10-8 lines 5 - 11;

Appendix A Matrix Table 2).

Concern: There could be potential to miss some adverse effects and thus cumulative effects

where project/VC interactions noted as “1” are not carried forward to the assessment phase

because they are assumed a priori to not exist or be negligible. (“1” means that adverse effect may

result from an interaction, but the effect is well understood and standard measures to avoid and

minimize are available and effective, therefore are no, or negligible, residual adverse effects)

(Section 10.4.2 pg 10-8 lines 1 - 4).


(a) Describe the implications of being mistaken when making an a priori assumption that potential

project interactions can be fully mitigated (i.e., assigning a rank of "1" when it should be a "2")

(Section 10.4.2).

(b) Provide rationales for the assignment of ranks to individual species or species groups to assess

potential project interactions since Appendix A reports ranks for Wildlife Resources as a whole and

rationales for all VCs together.



EIS Review Comments



10.4.2.1 8 34-40 63


Issue: Generally speaking, mitigation measures are not given as measurable and verifiable.

Mitigation measures include things that are vague and undefined, or not, in themselves, actions to

“mitigate” adverse effects. Batching mitigation measures for aggregated VCs compounds the lack

of clarity as to what will be done for mitigation, and how effective the measures may be.

Concern:

From the EIS: “Mitigation” and “mitigation measures” are defined as per s. 2(1) of CEAA 2012:

“measures for the elimination, reduction or control of the adverse environmental effects of a

designated project, and includes restitution for any damage to the environment caused by those

effects through replacement, restoration, compensation or any other means”(Section 10.4.2.1 pg

10-8 lines 34 - 40). Section 10.4.2.1 lacks a clear set of procedures for the development and

reporting of mitigation measures (e.g., requiring that mitigation measures link back to adverse

effects on specific VCs).


Provide clear procedures, a structured approach, and clear demonstration of how steps in the

mitigation hierarchy were considered (avoid - minimize -restore on-site - offset), and corresponding

mitigation measures selected, with respect to adverse effects on specific (i.e., individual, not

aggregated) VCs.



EIS Review Comments



10.4.2.1 64


Issue: Mitigation measures (see “proposed mitigation” in several tables) include things that are

not, in themselves, actions to “mitigate” adverse effects.

Concern: Where mitigation plans are used as rationale for findings, enough conceptual detail

about proposed mitigation is needed to be able to evaluate the effectiveness of mitigation

proposals and use that to estimate Residual Effects. The EIS Guidelines, s. 8.5.2.2 requires an

evaluation of effectiveness and, where there are uncertainties, and description of the potential

risks related to these measures; this is not possible without some level of conceptual detail.

Creating a plan is not a mitigation measure.

Examples of mitigation measures in the draft EIS include:

o Provide inputs to the final design phase (e.g., known wetlands, bat hibernacula) so that further

reductions and avoidances can be considered. (This is about planning and actions that may be

considered but may not happen.)

o Incorporate locations of rare species along rights-of-way into GIS-based mapping.

o Implement Environmental Management Plans. (What specific actions would the Plans include?

Itemize those actions / mitigation measures.)

o Consider the use of supplemental ungulate feeding programs during severe winters (this is

contrary to provincial government policy).

o Maintain a spatial database of wildlife features. (Then what? What specific action or mitigation

measure does this relate to, for what VC?)


Where mitigation plans are used as rationale for findings, please provide sufficient detail about

proposed mitigation to enable an evaluation of mitigation effectiveness and estimation of Residual

Effects.

8.5.2.2



EIS Review Comments



10.4.2.2 9 4-5 65


Issue: Section 10.4.2.2 states that "Residual adverse effects are the effects of the Project that may

remain after taking into account the implementation of mitigation measures, including

compensation" (page 10-9 lines 4 - 5).

Concern: If compensation counts towards reducing Residual Effects to zero (i.e. if there’s enough

compensation than Residual Effects are nullified), there are still likely to be “functional” impacts

that contribute to cumulative effects.

Request that the Proponent: Clarify the process for determining where, when, and how much

compensation (offsetting?) should be applied, and how compensation will address adverse effects

on VCs.

10.4.2.2 66

Estimate of Residual Effects - Overall Methods

Issue: Basing the assessment of the Residual Effect to conditions of the value on September 5,

2012 may not adequately take into account the ecological context of that condition and overall risk

to maintaining the value..

Concern: The ecological context of the current condition/baseline is missing from the estimate of

Residual Effects i.e., what the current condition of VCs represents in terms of risk to maintaining the

VCs.

Request that the Proponent: Clarify the baselines that residual adverse effects are characterized

against (after all mitigation including compensation/offsetting). What are Residual Effects

measured against, in relation to what changes in the environment for each VC. See also the request

for clarification of the definition of "baseline condition".



EIS Review Comments



10.4.2.3 67

Determination of Significance - Overall Methods

Issue: The definition of “Significance” and the methodology to determine significance (or non-

significance) of residual adverse effects, including thresholds, is unclear. This lack of clarity is

compounded because residual adverse effects themselves are generalized, and characterization is

descriptive and may encompass aggregated VCs.

Concern: More detailed explanations should be provided for each determination of significance (or

non-significance) of residual adverse effects.


Include a description of the steps used to derive significance based on quantitative descriptors used

to characterize Residual Effects in future iterations of the EIS.



EIS Review Comments



10.4.2.3 68


Issue: Although species-specific Residual Effects and significance determinations are mentioned,

the ultimate determination of significance is for “Wildlife Resources” as a Valued Component.

Concern: Aggregating VCs in the determination of significance could result in a loss of detail and

individual effects being swamped when wildlife are considered as one group. “Significance” (or

non-significance) of residual adverse effects for any one species cannot be understood when

multiple species are aggregated (for example, into “Wildlife Resources”) and “Significance” applies

generally to the broad category.


(a) Provide a rationale for why the final determinations of significance were made for Wildlife

Resources as a Valued Component, rather than for individual Species Groups and, (preferably)

species or species guilds.

(b) Describe the limitations and uncertainties associated with reporting significance for 'Wildlife

Resources" as a whole.

(c) How is the measurement of the indicators (e.g. species groups for the “Wildlife Resource” VC)

rolled-up to actually define the VC? How are such disparate indicators and information brought

together to report out on Wildlife Resources as a single VC?



EIS Review Comments



10.4.2.4 11 1-5 69


Issue: Follow-up Programs are proposed (in accordance with section 23.5 of the EIS Guidelines) to

verify the accuracy of the assessment or the effectiveness of mitigation measures. Follow-up

Programs have been developed where the likelihood, nature, or extent of a predicted adverse

Residual Effect on a VC, or the effectiveness of a recommended mitigation measure, is uncertain

(section 10.4.2.4 page 10-11 lines 1 - 5). Technically feasible, cost-effective, and environmentally

sound measures (e.g., alternative mitigation method, adaptive management) are proposed.

Concern: It is appropriate to scale the level of monitoring with uncertainty; however, to only

commit to Follow up Programs where uncertainty is identified is too limiting (e.g., re. opportunities

to improve mitigation methods through adaptive management).


Consider a broader range of criteria for monitoring the accuracy of the assessment or the

effectiveness of mitigation measures than are currently described in Follow-up Programs in the EIS

(section 10.4.2.4 page 10 - 11 lines 1 - 5).



EIS Review Comments



10.5 22 7-13 70

Cumulative Effects Assessment - Overall Methods

Issue: The EIS states that, in accordance with EIS Guidelines in s. 8.5.3: "assessment of potential CE

of the Project on a VC has been conducted if a potential residual adverse effect of the Project on

that VC has a spatial and temporal overlap with a Residual Effect of another project or activity"

(section 10.5 pg 10-22 lines 7 - 13). The EIS defines “cumulative effects” by potential Residual

Effects of other projects and activities from the baseline date (September 5 2012).

Concern:

The comparison of the Future Case without the Project and the Project Case does not adequately

evaluate the significance of the incremental effect of the Project. Reasons include the following:

o It is not clear how the Residual Effects of other projects (that may be in early stages of

application) are determined.

o It is not clear if any potential interactive effects among the Project and these other

projects/activities would be considered, or possibly missed.

o Adverse effects may be missed since this approach only considers effects that meet the definition

of residual adverse effects. Smaller effects resulting from “minimizing’ or not fully offsetting still

result in residuals that accumulate incrementally into cumulative effects over areas and time.

o There is no direct mention of desired future conditions or objectives for VC’s. Cumulative effects

assessment is meaningless without objectives for VC’s.

Comment Continued in next box



EIS Review Comments



10.5 22 7-13 70

Comment Continued


(a) Clarify the following:

(i) How is the baseline case is compared to the residual cumulative effects to describe the

significance of the effect on the VC?

(ii) How are the Residual Effects of other projects and activities (that may be in early stages of

application) determined?

(iii) Are potential interactive effects among the Project and these other projects/activities

considered?

(iv) How does the CE assessment identify and address smaller effects that result in residuals that

accumulate incrementally into cumulative effects over areas and time.

(v) What are the desired future conditions for VCs in the context of the CE assessment?

(b) Consider running a number of CE “scenarios” with varying degrees of parameters (e.g. tenures,

time periods, severities) included to get a sense of best and worst case.

(c) Provide justification for the determination that some projects are not expected to have

cumulative effects.

(d) State more clearly that only Project habitat alteration and fragmentation are carried forward

into the Cumulative Effects assessment.

(e) Crown Range tenures (authorized by FLNRO) and associated activity are not considered in the

cumulative effects assessment, but may contribute to cumulative adverse effects on some wildlife

taxa (page 14-91). Consider other projects such as ZED Septimus wind park in the CE assessment.



EIS Review Comments



10.5.5 22 11-15 71

Mitigation Measures - Overall Methods

Issue: From the EIS: "BC Hydro has recommended a number of possible regional approaches to

mitigation of CE ... which may involve government departments and/or third parties in independent

and/or collaborative initiatives"(sec 10.5.5 g 10-22 lines 11 - 15).

Concern: Question about the expectation of government department involvement in mitigation of

cumulative effects.


Clarify:

a) What is the expected role of the provincial government in mitigating adverse effects or

cumulative adverse effects of the Project?

(b) Would BC Hydro fund all such mitigation (through compensation or offsetting)?

11 72

The EIS Guidelines state that he narrative will include... "the description of any existing studies of

changes to the environment resulting from those projects that are similar to potential changes

resulting from the project, including any mitigation measures that were implemented, and any long

term monitoring or follow up program that were conducted. The effectiveness of those mitigation

measures and key results of monitoring or follow-up programs would be described . This

narrative discussion should include historical data, where available and applicable, to assist

interested parties to understand the potential effects of the Project and how they may be

addressed." - The effectiveness of mitigation measures and key results of monitoring or follow-up

programs is not clearly addressed in Section 11. Please add the appropriate information.

9.1 Previous

Developments

Section 11 - Environmental Background

11.1 - Previous Developments



EIS Review Comments



11 73

The EIS Guidelines state: "should include historical data, where available and applicable, to assist

interested parties to understand the potential effects of the Project and how they may be

addressed." This topic is not adequately addresses in terms of soils, agriculture, and terrain

inventory. There are existing studies and data that were not referenced or used. For example,

studies summarizing loss of ecosystems, previous terrain and soils mapping. Please include in the

EIS.

Historical data was addressed in terms of previous geotechnical studies.

9.1 Previous

Developments

11.1.1 74

The EIS Guidelines state : "An understanding of those facilities, of the environmental changes

understood to have resulted from those facilities, and of the mitigation measures employed may

provide information that could be used to better assess the potential effects of the Project..."

Please provide additional historic data on the regional state of values prior to installation of the

WAC Bennett Dam and the Peace Canyon Dam in addition to the baseline information used.

Productive agricultural land in the Peace Valley has already been lost due to these 2 other dams as

well as other projects and this should be made clear in the Executive Summary so that it will not be

lost to stakeholders and decision-makers.

Baseline information collected by the proponent for the previous dam projects is not summarized

or provided, or could not be found.

9.1 Previous

Developments



EIS Review Comments



11.1.2 75

The EIS Guidelines state : "An understanding of those facilities, of the environmental changes

understood to have resulted from those facilities, and of the mitigation measures employed may

provide information that could be used to better assess the potential effects of the Project..."

Please provide additional information summarizing the historic regional state of VC's and the total

regional loss to VC's from this and other projects past and present for reference. e.g., How much

agricultural land of the various classes has been lost in the region (using data that predates

reservoirs in the region)? What proportion of the productive agricultural lands has been lost from

previous projects? What proportion of the productive land does this represent for the region? for

the province? These same questions could be asked for ecosystem, soils, etc.

Regional historic baseline descriptions should predate the 2 existing dams. regional loss of values

should address loss of values from the 2 existing dams and the additive losses from the proposed

dam. and the additive loss from the proposed Project should be summarized.

9.1 Previous

Developments

11.1.3 76

This is a very brief section that references some monitoring programs on the existing reservoirs. It

does not cross reference monitoring recommended or described in appendix B part 2. 9.1 Previous

Developments

11.2.3.8 77

EIS Guidelines state: "Characterization and classification of the proposed reservoir shoreline will be

carried out," - Shore line classification is outlined in section 11.2.3.11 cross references Volume 2

Appendix B Part 2. Data for the classification of the shoreline was not delivered to the province

however an overview of the data was presented to the province. Shore line is classified into broad

material type groups in order to make material specific assumptions for the erosion models. The

Model description and results are found in Appendix B part 2 sections 7.

9.2.1 Geology, Terrain

and Soils

11.2 - Geology Terrain and Soils



EIS Review Comments



11.2 78

This section provides an overview of the terrain and geology. The terrain description emphasizes

surficial materials. It touches on landforms but does not cover all relevant landforms (e.g., fans). For

geomorphic processes landslides (bedrock mechanisms) are covered extensively but other

processes such as seepage, earthflow, gullying, etc. are not expanded upon and their relevance to

the project not described. V2 Appendix B parts 1 and 2 are cross referenced. Some key findings

described in Appendix B Part 2 are not adequately covered in this section. For example, the

number, percentage and volume of landslide features with active slow mass movement processes

(e.g., earth flow) below the reservoir level should be summarized in section 11.2.


and Soils

11.2.2 79

EIS Guidelines state: "The EIS will contain a description of bedrock and surficial geology..." - An

overview of bedrock and surficial geology is covered in section 11.2.2. There is a good cross

reference to section 11.2.2.4 where more detailed description of potentially unstable bedrock

features near the dam site are described.


and Soils

11.2.2.3 80

EIS Guidelines state: "This will include....Regional bedrock and surficial geology" This section

emphasizes terrain stability as it relates to road construction and logging practices. There is a lack of

follow-through to mitigation sections. There is an overemphasis on initiation zones of landslides

and not on other geomorphic hazards and constraints or erosion potential. It is stated (11-17

line13) that this study is superseded by geotechnical analysis. However, the results of the

geotechnical analyses would be more useful if it was used to update the terrain mapping.


and Soils

11.2.2.4

11-17

to 11-

20

81

This section describes a huge variety of potential failure planes in the bedrock and surficial

materials at the dam site: bedding planes with low frictional resistance, shear zones, fractures,

seepage zones, steeply dipping relaxation joints with water flow near valley walls, and other

weaknesses, and a buried channel connecting Moberly creek and the Pine river (a potentially

permeable zone? – ground water implications on stability?). This section lacks a clear statement of

impact on the reservoir and the dam. There needs to be a cross reference to mitigation measures

including how these findings are taken into consideration in the dam design and monitoring

programs.


and Soils



EIS Review Comments



11.2.3.2 82


carried out, including: Descriptions of geological materials and/or thickness of colluvium and a

description of the underlying geological materials located at the normal maximum reservoir level;" -

There is a cross reference to Volume 2 Appendix B Part 2. The lumping of 'sand and gravel' units

makes the interpretations in section 11.2.3.2 very broad. This is appropriate for geotechnical

calculations.

The implications to shoreline erosion and slope stability are addressed but not the implication of

upstream/slope geomorphic processes. Recent geologic materials are a key to these processes and

are not covered. See other comments relating to cumulic landforms.


and Soils

11.2.3.3 83


carried out, including: Inventory of landslides, including their estimated mechanism, volume and

current degree of activity; " - Landslides within the project activity zone are summarized. Slow

mass movement processes are not adequately described in this section. Details are present in

Appendix B Part 2.


and Soils

11.2.3.3 84


carried out, including: Site-specific characterization of significant historic and pre-historic landslides

based on the results of surface mapping, geotechnical drilling, instrumentation monitoring, and

slope stability analyses, where available;" This topic is summarized in section 11.2.3.3 with details

in Volume 2 Appendix B part 2. Tributary streams were not investigated for landslides relevant to

debris dam and flood potential. Investigation was limited to the project impact area. Potential

impacts to the project were not fully explored.


and Soils



EIS Review Comments



11.2.3.3 85

There are significant landslides and stability issues in the valley. These are described in detail. The

mitigation of these issues is not cross referenced and is covered very poorly in section 35 with some

significant gaps in requirements (see comments related to WCB regulations below). The presence

and implication of slow mass movement processes is not adequately covered in this section.

Including what factors contribute to transformation from slow deformation to rapid movement.

Details present in Appendix B Part 2 section 4.1.2 regarding the active movement along failure

plains and in the landslide deposits are not mentioned in section 11.2.3.3. These facts and their

implication to the project need to be summarized and addressed in section 11.


and Soils

11.2.3.8 86


carried out, including: Description of the geology at select representative cross-sections and

extrapolation along the shoreline using borehole and surface mapping observations to produce

geological fence diagrams;" - Section 11.2.3.8 summarizes boreholes and detailed cross sections.

The data has not been delivered to the province. Some example cross sections are provided.


and Soils

11 87

It would be very helpful if sections were cross referenced. For example ecosystem mapping is

referred to in section 11 but not properly referenced so that it is easy to find. Text refereeing to

Terrestrial Ecosystem Mapping is found on line 26 page 11-94 and line 15 page 11-151 but no tie to

ecosystem baseline in the Environmental Background section. Surficial materials and soils are

critical to ecosystem distribution and health. Similarly, it does not appear that the ecosystem

section adequately references the geology and terrain information or the limited soils information

in the agriculture section. Volume 5 Section 37.1.5 was particularly useful to put the geomorphic

findings into perspective but is not referenced from section 11 or related sections that were

reviewed.


and Soils

11 88Pedogenic soils are not addressed. 9.2.1 Geology, Terrain

and Soils



EIS Review Comments



11 89

EIS Guidelines state: "The EIS will contain a description of ... geotechnical and geochemical

processes (such as erosion, slope stability and acid rock drainage) that may affect land or resource

use" - Erosion and terrain stability were reviewed as much as possible without the full data set

(vector and LiDAR). Slope stability issues where investigated in detail by the proponent and are

described in Volume 2, Appendix B parts 1 and in more detail in part 2. These issues need to be

summarized in a clear and concise fashion in section 11 and related sections so that the information

critical to decision makers in clear and tradeoffs are outlined. This section should also cross

reference other sections that take the geotechnical findings into consideration.

The focus of the geotechnical studies was on the impact of the reservoir on stability and

displacement wave modelling. The scope needs to be expanded to cover the potential impacts of

the inherent instability on the project and activities. Stability issues outside the project activity zone

that could detrimentally impact the project should be fully explored. This includes but is not limited

to:

• potential impacts of landslides outside the stability impact line

• investigating potential debris damming and outburst floods in tributary streams

• investigating evidence of past catastrophic flood and debris events in sediment records present in

wetlands and fans; and

• investigating/monitoring large slow mass movement features in the activity zone.

Detailed landslide inventory data was not available to the province. An overview was presented


and Soils

11.2.5 90

EIS Guidelines state: "The EIS will contain a description of ... existing and predicted changes to

seismic conditions" - Seismic hazards are covered in section 11.2.5. Reference to increased Seismic

activity caused by hydrocarbon extraction (BC Oil and Gas Commission 2012) is stated in Volume 2

Appendix B part 2 section 3.2.1 paragraph 5 but not mentioned in section 11.2.5.


and Soils

11.2.3.10 91Please Clarify the extent and scope of the geotechnical investigation that are still to be completed. 9.2.1 Geology, Terrain

and Soils



EIS Review Comments



11.2.4 92

The EIS and Acid Rock Drainage and Metal Leachate Management Plan discuss monitoring and

reporting during construction activities, however there is no mention of monitoring or reporting to

be implemented during operation. Please Clarify if BC Hydro intends to implement any monitoring

for Acid Rock Drainage or Metal Leachate beyond the construction period of the dam and into

operations for any of the Project components.


and Soils

11.2.5 93Questions and follow-up: Suggest that an expected situation of "harmless seismic events" be

confirmed; yes or no and if no, qualified in simple illustrative terms?9.2.1 Geology, Terrain

and Soils

11.2.3.9 30 17 – 26 94Please provide details of the “hybrid modelling approach” and model results. 9.2.1 Geology, Terrain

and Soils

App B, Part

295

Field investigation was focussed on refinement of the stability impact line. The Cache Cr slide was

not selected for detailed drilling and slope movement monitoring as the failure plane of this large

slide is well above the reservoir level. However, further investigation and monitoring of this slide is

recommended as it poses sedimentation and landslide risk in an area where the reservoir is

relatively narrow and confined.

Historically toe erosion of the feature has likely removed material downstream. Could this feature

potentially ‘pinch off’ or fill in this section of the reservoir? See bathometric map. Also consider

untrained loading of the saturated landslide deposit from upslope movement.

029_v1_s4_fig_04-23_site-c-rsvr-bthymtry-tls-5of6.pdf


and Soils



EIS Review Comments



11.2,

mostly

11.2.2.2

96

EIS Guidelines state: "The EIS will contain a description of ... key landforms (such as mountains,

uplands, slopes, terraces and streams)" There is a very general overview scattered between the

sub-sections in 11.2, mostly 11.2.2.2. The location and relevance of major glacial and post glacial

landforms is not clearly summarized with statements of relevance to the project. Where is the 'so

what?' in section 11.2.2.2.This section lacks cross reference to other relevant sections and

appendices. There is no section on post glacial terrain (landforms include: fans, modern floodplain,

wetlands, colluvial slopes, earth flow features, etc.). Many of these cumulic landforms hold the key

to Holocene sedimentation rates and major events. Coring of wetlands and fans may provide

valuable information to the project.


and Soils

11 97

In general it is difficult to find specific mitigation measures related to the issues summarized in

section 11. e.g., unstable slopes and large landslide features are identified in the studies but the

summary does not cross reference how these are addressed in section 35 or other sections.

Similarly other section (e.g., groundwater 9.3) does not adequately reference the stability summary

or appendices.


and Soils

11 98

Pedogenic soils are not addressed in section 11. Engineering soils are covered with regard to terrain

stability, groundwater etc., in section 11. Instead, soils are only addressed in the section on

agriculture as they relate to agricultural capability. Soils should be described in section 11 including

their distribution, classification, age, chemistry. Discussion on soils should include their relationship

to other valued components such as the base of terrestrial ecosystems, forest productivity, water

quality and storage, carbon storage and sequestration capacity, base line representation and loss

due to reservoirs over time. Cross reference should be made to soil background information from

sections that address erosion, forestry, ecosystem, agriculture, mitigation and reclamation section.

Basic soils survey and inventory information can be used to inform planning and mitigation

processes.


and Soils

11.2 99

"Geology, Terrain and Soils" - This section is mis-named as it does not deal with soils. Soils are

discussed under Agriculture. - Please correct to avoid confusion. 9.2.1 Geology, Terrain

and Soils



EIS Review Comments



11.2.1 100

This section provides a good overview of the physiography and topography in the area. The

relevance of these to the proposal is not clearly stated in each section. Please add this information.

Previous terrain and soils mapping were not referenced.


and Soils

11 101

EIS Guidelines state: "This will include....and soil conditions" - Soils survey and descriptions of soil

development, classification and properties are not covered or cross referenced in section 11 nor are

they covered in the terrestrial ecosystems section. Soils are only addressed with relationship to

agriculture capability.


and Soils

11.2.3.8 &

11.2.2.3102

EIS Guidelines state: "The EIS will describe... the stability of the terrain within the project activity

zone" - This topic is covered in 11.2.3.8 and 11.2.2.3. The latter lacks relevance to the project as a

whole as there is an emphasis on road construction and logging.

Detailed terrain stability inventory data has not been provided to the province delivered although

an overview has been presented to staff.


and Soils

11 103

Investigation focuses on the life of the reservoir up to 100yr. What will happen to stability after that

time period? Stability issues should be considered for the full life span of the reservoir. The scope of

the geotechnical investigation should also include the decommissioning or ongoing maintenance of

the project.


and Soils

11.3.1.1 53 33-34 104

"Wherever possible, farmland, and ranchland acquired by BC Hydro is being maintained in a

productive state, either by leasing back the property to the original owner or to another tenant" -

Please clarify the portion of BC Hydro owned farmland that is in production vs. not in production.

This statement does not appear to be quantified or discussed further in this section. Please provide

a rational and information supporting this statement.

9.2.2

11.3 - Land Status, Tenure and Project Requirements



EIS Review Comments



11.3.1.1 54 15 105

3rd bullet in the Notes section of the table: "Additional Crown or private lands may be purchased in

fee simple for sources of construction materials or mitigation. The construction material lands may

be available for redevelopment post-Project." Please provide additional information on how much

additional land is being contemplated (by Crown and Private). If exact numbers amounts are not

known at this time, please provide a range. Also, please consider providing additional information

concerning the mitigation types that may required additional fee simple land.

9.2.2

11.3.1.1 54 15 106

For completeness and clarity, please consider summarizing tables 11.3.1, 11.3.2 and 11.3.3 into one

table showing total area required for the Project by project component broken down into fee

simple categories and long term, and short term Crown tenure. Having total footprint identified by

category summarized would be useful. Grand totals should also be provided for each individual

table.

9.2.2

11.3.1.1 54 15 107

Please Clarify - Title (Estimated Fee Simple Tenure Required) is unclear. It appears, from context

that BCH intends to acquire all the land area in the table as fee simple, including area of Crown land

to be inundated (4523ha). In this table and elsewhere through the document the word “Tenure”

used with “Fee Simple” is potentially confusing. Please consider clarifying.

9.2.2

11.3.1.3 55 6 & 7 108

“Rights to the underlying Crown land for the reservoir would be acquired through the issuance of a

Water Act permit from the Province.” This appears to contradict first line of Table 11.3.1 (Land

acquired in fee simple for inundation, including Crown land) - Please Clarify 9.2.2

11.3.2 55 23 109

A BC Hydro Statutory Right of Way may be appropriate for application on land that is currently fee

simple (agreement between proponent and current landowner), but a Statutory Right of Way may

not fulfill BCH’s needs as it relates to a tenure issued by the Province on Crown land. Further

discussion on appropriate tenure types for the desired purposes is required for this and other

tenures.

9.2.2

11.3.2 56 1 110Information Requested - Transmission tie in at Site C is listed as 51 ha, while at Peace Canyon, it is

32ha. Please clarify the reason for the difference at the 2 sites. 9.2.2



EIS Review Comments



11.3.2 56 1 111

Project Access Road - a Statutory Right of Way may not be the correct type of tenure for this

project component. Further discussion on appropriate tenure types for the desired purposes is

required for this and other tenures.9.2.2

11.3.2 56 1 112

Table 11.3.2 Impact Lines are mentioned in Line #1, and then Stability Impact Lines are discussed

separately in line 2. Please clarify if there the difference between the two, or correct the overlap if

one exists.9.2.2

11.3.2.3 57 37-38 113

“road would be classified as a private road to restrict public access to ensure safe operation. ... BC

Hydro would obtain a permanent statutory right-of-way from the Province and...” It should be

noted that a Statutory Right of Way does not restrict public access unless conditions are added to

that effect. Having the road classified as a private road is not necessary to restrict public access

during construction. Other tenure instruments may better suit BC Hydro’s needs.

9.2.2

11.3.2.3 57 37-38 114

In other sections of the EIS it is suggested that the existence of the access road may be a reason to

decommission other roads in the area. Please provide a rationale for the need to keep the road as

private and to restrict public access after construction. 9.2.2

11.3.3.3 59 37 115

“Where exclusive use of the land is required, e.g., for worker accommodation, BC Hydro

would enter into a lease agreement for specific areas.” Note - Most industrial work camps on

Crown land are tenured under a Licence of Occupation. Further discussion on appropriate tenure

types for the desired purposes is required for this and other tenures.9.2.2



EIS Review Comments



11.3.460 &

61

22 – 26,

1 – 2 116

Table 11.3.4 and Reference to Volume 2 Appendix C MAPS, Figures 6 and 7:

The current presentation of information related to Petroleum and Natural Gas subsurface title

versus surface activity approvals makes it difficult to perceive distribution of each and therefore

potential impacts and mitigation solutions. This can be corrected as described below:

a) Figure 6 “Ministry of Energy, Mines and Natural Gas tenures” contains a layer titled “Petroleum

Title Tract”. This layer appears largely incomplete when compared to the subsurface tenures seen

in the “Petroleum Active Titles” layer available from DataBC (GeoBC) and the BC Geographic

Warehouse (BCGW), and also differs from the “Tenures” layer seen in Figure 7.

b) Figure 7 “Oil and Gas Tenures” appears to indicate, in the main, surface activity permits, such as

well drilling permits, issued by the Oil and Gas Commission (“OGC”) and only a few of potentially

affected subsurface Petroleum and Natural Gas title issued by the Ministry of energy, Mines and

Natural Gas (“MEMNG”).

This information, and that listed in Table 11.3.4, could be much better illustrated by separating

surface tenures and permits issued by the OGC from subsurface titles issued by MEMNG, through

the creation of two different map layers. One layer would contain OGC approvals and permits

issued under the Oil and Gas Activities Act and its authority to issue permits under five Specified

Enactments (see OGAA section 1, “specified enactments”). OGC issues approvals for surface

activities. Another layer could show subsurface Petroleum and Natural Gas title issued by MEMNG.

This data is available in the “Petroleum Active Titles” layer from DataBC (GeoBC) and BCGW, or

from this FTP site:

ftp://ftp.mem.gov.bc.ca/CSGISS/PNG_Tenure/

Table 11.3.4 could then list the content of each layer’s data set.

9.2.2

11.3.460 &

61

22 – 26,

1 – 2 117

Table 11.3.4 identifies potential conflicts with a total of 74 tenures issued by the Ministry of Energy

Mines and Natural Gas, however does not differentiate between types of tenures or the Acts

associated with those tenures. Please ensure that all coal and mineral tenures are identified and

conflicts are resolved. For further information, please contact MEMNG.

9.2.2



EIS Review Comments



11.4.2.3 66 11 118

The data provided in Tables 11.4.3 and 11.4.4 and associated figures appears to be inconsistent

with the suggestion that there is considerable attenuation. The identified change of -40 to + 179%

appears to be substantial. Please clarify.

9.3.1 Surface water

regime

11.4.6 83 119

Climate change – modeled changes should be presented given the life of project. This section reads

as if this analysis has occurred, if so, please include this information in the EIS. 9.3.1 Surface water

regime

11.4.2.4.2 68 3 120

Normal operations will have an influence on hydrologic regime but spills may have the greatest

influence. Consider providing more investigation/discussion on spills, particularly larger spills that

have been experienced at the facility and the influence of these spills on downstream conditions.9.3.1 Surface water

regime

11.4.2.4.3 68 7 - 21 121

Please clarify why the timeframe of 2008-2010 was chosen? These years do not include the

greatest range of releases from the facility. Consider looking at both normal operations and spills

to determine potential downstream effects on both the channel and its surrounding infrastructure. 9.3.1 Surface water

regime

11.4 69 12 122

Please clarify why the water years used here for modeling are different than others used through

the report. Consider using complete and similar record length to avoid confusion and for ease of

comparison. 9.3.1 Surface water

regime

11.4 69 2 - 40 123

Please consider modeling the Approach and Methods identified in Section 11.4.3.1 for spill

response as well.9.3.1 Surface water

regime

11.4 76 124Please consider presenting a summary of historical inflow information and modelled findings as it

would aid review. 9.3.1 Surface water

regime

11.4 76 125

Please provide additional detail on the how spills from dams upstream could influence site C. Also,

recommend that historical frequency information be blended into subsequent analyses rather than

Generalized Optimization Model (GOM) only.

9.3.1 Surface water

regime

11.4- Surface Water Regime



EIS Review Comments



11.10

p.11-

171

throug

h 11-

186

126

Please clarify if any stations will be maintained for longer term meteorological and climate

monitoring and if the same standards would be used as other stations operated by BC Hydro. Also,

please consider providing information real time through BC Hydro's weather station network. 9.3.1 Surface water

regime

11.4 127

No mitigation is relevant here or proposed other than upping the minimum flow release in

accordance with the added mean annual discharge through increased catchment area by 100 cms. 9.3.1 Surface water

regime

11.4 128

Reporting of averages over the period of record should refer to the long-term mean annual flow (LT

mad) to make a distinction to the mean annual discharge for a single calendar year. More

importantly, the data treatment describes large differences in natural versus regulated flows that

are already imposed by existing dams. The values could have been better qualified using Tennant-

type coefficients to provide common or equivalent metrics to other know flow determination and

contrasts. What does the minum flow of 283 cms mean in %TL mad at Hudson's Hope and is lower

than that prescribed by rivers with significant braids and side-channels (>50%TL mad). An

equivalent flow of 24%TL mad on a POD or Site C TL mad of 1276 cms is 306 cms which is lower

than the proposed minimum of 390 cms.

9.3.1 Surface water

regime

11.584 to

91129

Please provide a more complete summary of the Technical Appendix E (Water Quality Baseline).

Condensing this subject area to 7 pages from the 233 pages in Appendix E has left out much

information. Please consider revising similar to other Appendices (such as App H) in the

Environment Background Report.

9.3.1 Surface water

regime

11.4.2.1 63

6-12 &

figure

11.4.1

130

Consider adding additional detail to describe the flow interactions with the lakes (Claire lk, Baril

Lake, Mamawi lk., etc. ). 9.3.1 Surface water

regime

11.4.2.1 63 26-33 131

It appears that all that is described for baseline conditions for Site C is that "seasonal runoff

patterns are similar for Site C as... those described for Williston Reservoir" This is not a sufficient

description for this report since the focus is on Site C. Please Clarify if there is additional

information available elsewhere in the EIS. If this information has been collected and not included

in the EIS, please consider including.

9.3.1 Surface water

regime



EIS Review Comments



11.4.2.1 63 26-33 132

It is unclear how the numbers presented are calculated. Please clarify if all the tributaries gauged

and the source of this data was not presented in the report, or was this description of flow

components based on an estimation? If based on an estimation, please discuss uncertainties and

yearly variability.

9.3.1 Surface water

regime

11.4.2.1 63 26-33 133Please clarify what the tributary inflow is in comparison to the mainstem flow. 9.3.1 Surface water

regime

11.4.2.1 62 37-39 134

Please Clarify, it does not appear that an overview of the Peace River was included in Volume 2

figure 11.4.1 as stated, as this is a map depicting watershed boundaries. Please include a map

depicting an overview of the Peace River.9.3.1 Surface water

regime

11.4.2.1 63

6-12 &

figure

11.4.1

135

Please consider revising Figure 11.4.1, as it appears to contain inaccuracies. i.e., some lakes are

amalgamated. The watershed boundary also appears to be in error and lake Athabasca is depicted

as one large lake instead of a number of smaller lakes (Claire lk, Baril Lake, Mamawi lk., etc. ). The

Watershed boundary goes through the middle of the amalgamated lake. This leads the reader to

wonder, does the Peace flow into Athabasca lk and then does the Slave river leaves the Athabasca

lk ... or perhaps as it is on Google Earth does it just changes names at the junction of the outflow

from Athabasca?

9.3.1 Surface water

regime

11.4.2.1 63 4-5 136

Please provide additional detail and description of flow of the Peace River between the Peace

Canyon Dam and the BC/Alberta border.9.3.1 Surface water

regime

11.4.2.1 63 26-33 137

Please provide additional details for this section. It appears that this paragraph is all that describes

tributaries and the mainstem flow regime below Peace Canyon dam to proposed Site C. Please

provide additional detail for this section as more content and depth are needed. As presented in

the EIS, this section is currently insufficient. It is also not clear that any streamflow data was

collected, please clarify if this is the case.

9.3.1 Surface water

regime



EIS Review Comments



11.4.2.1 63 26-33 138

Request the proponent provide the range of inflows and the range of annual variability in addition

to the average range of inflows of 110m3/s that has been identified. 9.3.1 Surface water

regime

11.4.2.1 63 13 139

Although it does not appear to be required by the EIS Guidelines, please consider providing a range

of values, such as min-max, median and 95% C.I. In addition to the mean. This information can be

more valuable, particularly for inflows as they can influence the frequency and magnitude of spills.9.3.1 Surface water

regime

11.4.2.265

Table 1-2 140

For Table 11.4.2, Please provide a rationale for only using data from 1992-2010. 9.3.1 Surface water

regime

11.4.2.3 65 12-13 141

Please clarify how far down the Peace the zone of influence is. Also, please clarify what the zone of

influence is on daily flows? 9.3.1 Surface water

regime

11.4.2.3 65 11-13 142

Please provide additional detail - What is the number of observations in the respective time

periods (pre and post). Is this based on instantaneous or max/min daily mean value? 9.3.1 Surface water

regime

11.4.2.4 66 5-13 143

Please clarify if higher discharges = higher release from the dam. Why would night be less discharge

than the day? Explanation as to cause would be helpful to understand releases and seasonal

patterns.

9.3.1 Surface water

regime

11.4.1 62 12 144

Please provide the data to confirm the assertion that flow is not affected by project rather than

stating it is “expected” to be negligible. 9.3.1 Surface water

regime

11.4.1 64Table

11.4.1145

Table 11.4.1 – indicates Peace R. above Hudson’s hope is approximately 25% of watershed area, yet

contributes close to 58% of mean annual discharge according to table. This appears to conflict with

the argument made in this section that influence of discharge from above Hudson’s hope is not

noticeable at Peace Point, please clarify.

9.3.1 Surface water

regime



EIS Review Comments



11.4.2.1 63 24 - 25 146

"Only 9m3s-1 of inflow is associated with local tributary inflow into Dinosaur Reservoir

Downstream of the W.A.C. Bennet Dam." Please provide the times scale and clarify what the

annual contribution and variability. This statement also appears out of place as the paragraph

discusses the Williston reservoir inflows.

9.3.1 Surface water

regime

11.4.2.1 63 39 147

The data presented is a limited period of record that appears to be missing 20 years of data after

dam construction. Can the limiting station (i.e. 1992) be excluded or two series of records

assessed? The reduced record may influence subsequent analysis.9.3.1 Surface water

regime

11.4.2.2 63

35-45

and

table

11.4.1

148

Although it does not appear to be required by the EIS Guidelines, please consider providing

additional data in table 11.4.1. such as Median flows, monthly Maxs, Mins , Lows, Monthly statistics

(medians and Means) and / or exceedances as well as supporting discussion.

9.3.1 Surface water

regime

11.4.2.2 63

35-45

and

table

11.4.1

149

Please provide a rationale for basing the characterization on only WSC data. In other sections of

this EIS, data was collected and it appears that no streamflow data was collected beyond the use of

WSC sites.

9.3.1 Surface water

regime

11.4.2.2 64 2-10 150Please provide a more in-depth discussion of the data presented in table 11.4.1. 9.3.1 Surface water

regime

11.4.2.2 64 2-10 151Please provide a rational for choosing a partial data set. If the system’s Mean is altered by including

more data, this change should be discussed and explained in the report. 9.3.1 Surface water

regime

11.4.2.2 63

35-45

and

table

11.4.1

152

There are a number of tributaries that are not described or accounted for in this report. Please

clarify if streamflow data was collected to characterize background below the Peace Canyon dam.

If so please include the data in the EIS.

9.3.1 Surface water

regime

11.4.2.3 66 1-6 153Consider including a discussion of the range of flows pre and post. 9.3.1 Surface water

regime

11.4.2.3 66 1-6 154

Please clarify how and why the average Max’s are calculated. Are these daily or monthly or

instantaneous values? Please consider providing rationale for this in the EIS as well as discussing

how other drivers (co-variants) are parsed out of this approach. Please clarify why this approach

was used over more conventional approaches.

9.3.1 Surface water

regime



EIS Review Comments



11.4.2.3 65 11-13 155

Please clarify why the EIS is averaging the maximums and the minimums in this example and how

many observations are in the sample. With no discussion on potential climatic changes and other

flow drivers this procedure is very unconventional. Consider revising this section so that changes

expressed via changes in the exceedance statistics for return period flows of certain magnitudes

(pre and post). Also, consider providing monthly exceedance statistics based on daily avg data

compared to return period (1 in X yr flood) or exceedance values between pre and post (i.e., the 80

(20)% exceedance values pre and post). Please provide additional data so that conditions can be

fully described.

9.3.1 Surface water

regime

11.4.2.3 66 1-6 156

Please consider comparing pre and post flows using probability and exceedance based calculations

based on developing those relationships with pre and post data respectively. Also, please consider

providing a comparison via the return period of flows of certain magnitudes. 9.3.1 Surface water

regime

11.4.2.3 66 1-6 157Please include a discussion and analysis of climatic variables (annual ppt) and the effects that

climatic variability on the pre/post periods selected. 9.3.1 Surface water

regime

11.4.2.3 66 1-6 158

Please provide additional data so that conditions can be fully described. Please clarify why absolute

max and mins are compared in this manner. Please provide a rationale / justification for use of this

approach.

9.3.1 Surface water

regime

11.4.2.3 65 6-8 159

Please provide additional detail as the parameters of the means are not characterized. Is this

referring to daily means, monthly means or Instantaneous mean maximums and minimums?

Also, please clarify what the spring summer means are? Is this April to Sept? Please be explicit with

respect to what mean represents and data used to calculate (i.e., Daily or monthly and measured,

estimated or modelled). The difference between daily means and monthly means can be important

to consider, particularly in the seasons where flow is increasing or decreasing.

9.3.1 Surface water

regime

11.4.2.4 65 16-25 160

This section doesn't fully describe baseline flows, rather it describes BC Hydro operations and effect

on flows. Additional data and discussion of variability in water levels here would be helpful. 9.3.1 Surface water

regime



EIS Review Comments



11.4.2.4.1 67 29-31 161

"the relative contribution of regulated flows to the total flow at downstream locations is the

highest in the winter" - this statement does not appear to be supported or explained in the figure

as identified. Please provide further explanation and consider revising the graphics to clarify this

point.

9.3.1 Surface water

regime

11.4.2.4.1 67 22 162

Increase in discharge during low flow periods of winter may alter ice dynamics along mainstem and

perhaps tributaries as well. Please clarify if there is a discussion about ice dynamics and influence

on downstream damming/flooding elsewhere in the EIS.9.3.1 Surface water

regime

11.4.2.4.1 67 15-31 163

This paragraph presents a figure 11.4.6 that is meant to convey knowledge of seasonal flows and

regulation effects to the reader. Please provide additional description, also, alternate graphics and

data presentations, and additional data would be helpful in providing more clarity 9.3.1 Surface water

regime

11.4.2.4.1 67 30 164Please clarify, it appears that what is actually meant here is Figure 11.4.6 here as 4.7 is a spill trace.

9.3.1 Surface water

regime

11.4.2.4.3 68Table

11.4.5165

Please Clarify: Are the values provided in the table ("daily water level changes" for the three years

2008, 2009, and 2010) annual averages, maxima, or some other statistical measures

11.4.4.2.3 75 166

This section it describes the method of analysis however does not appear to address the issue of

"Spill Frequency, Magnitude, Duration and Seasonality. Please provide additional information on

how the project will address spills of frequency X and what the potential effect on downstream

hydrology is. It is also noted that modeled spills are considerably less frequent than historical

records indicate. Please ensure that modeling is consistent with historical records, or provide

rationale as to why not.

9.3.1 Surface water

regime

11.5.1 84 9 – 17 167

BC-approved water quality guidelines take precedence in BC. Where guidelines for certain

substances are not available working water quality guidelines should be used.

11.5 - Water Quality



EIS Review Comments



11.5.2.1 87 10-39 168

This summary of the report does not report location and dates when TSS exceeds guidelines – this

is a key piece of information that should be presented in this summary (as is done for metals). The

information in the appendix should be brought forward here. 9.3.2

11.5.2.2 84 NA 169

During reservoir infilling, what is the anticipated duration and impact (i.e. dissolved oxygen,

nutrients) to aquatic life of organic material (i.e. leaf litter, branches, bark) that will become

suspended in the water column and/or float on the surface?

11.5.2.2 86 26-227 170

Water quality summary states Williston and Dinosaur reservoirs “show evidence of weak

stratification occurring in the summer period”. However the thermal gradient in the summer near

the dams is significant with surface temperatures up to 17C and the thermal stratification in this

period (as is predicted for Site C Reservoir) has implications for biological and chemical processes

(like DO Depletion) and the significance of the thermal stratification should not be minimized. It

should be noted that the Site C Reservoir is likely to be quite different than either of the upstream

reservoirs for a number of reasons, and further discussion of anticipated differences should be

discussed.

9.3.2

11.5.2.3 87 6 – 8 171

30-day DO concentrations are based on 5 approximately evenly spaced samples over a 30 day

period. Please clarify if this requirement has been met. (see Volume 2, Appendix E).

11.5.2.4 22 – 24 172

BC guidelines state “Change from background of 10 mg/L at any time when background is 25 to 100

mg/L during high flows or in turbid waters; Change from background of 10% when background >

100 mg/L at any time during high flows or in turbid waters”.

11.5.2.4 25 – 35 173

Mean TSS concentrations should be calculated based on 5 samples in 30 days. Please clarify if this

was done. Calculations of mean TSS concentrations over all seasons do not provide insight to when

TSS may be of concern.



EIS Review Comments



11.5.2.4 87 14 – 15 174

Please refer to BC approved water quality guideline for turbidity, suspended and benthic sediments -

http://www.env.gov.bc.ca/wat/wq/BCguidelines/turbidity/turbiditytech.pdf.

11.5.2.5 88 8 – 9 175

Please refer to BC working water quality guidelines for alkalinity.

http://www.env.gov.bc.ca/wat/wq/BCguidelines/working.html#table1

11.5.2.6 88 29 – 30 176

BC’s water quality guidelines for nitrogen include total ammonia nitrogen. Guidance on the

application of the guideline is provided in Table 16 of this document. This should be followed for

water quality assessments in BC.

http://www.env.gov.bc.ca/wat/wq/BCguidelines/nitrogen/nitrogentech.pdf

11.5.2.6 88 – 8941 – 44,

1 – 10177

Please refer to the BC water quality guidelines for nutrients and algae for this assessment. The

guideline of 0.01 mg/L specified in Appendix E of Volume 2 (p. 8) is not a 30-day mean value to

protect aquatic life; it is a maximum value to protect drinking water sources in lakes. The guideline

to protect aquatic life in lakes is within a range of 0.005 – 0.015 mg/L. B.C. does not have a total P

guideline for streams, but do have a maximum value for chlorophyll a of 100 mg/m2 (this

information is summarized in the Water Quality Criteria (i.e., Guidelines) for Nutrients and Algae

Overview Report.

11.5.2.7 89 38 – 40 178

5 samples in 30 days are needed to determine if chronic guidelines are met. Please Clarify if this

was done.

11.5.2.7 89 21 – 24 179

Please clarify which guidelines are being used. Many parameters have both chronic and acute

values (e.g. Al, Co, Cu, Pb, Ag, Zn). A minimum of 5 samples, evenly spaced over 30 days, are

required to determine if average guidelines are met.



EIS Review Comments



11.5.2.7 89 24 - 28 180

The authors refer to CCME (1999) on the development of water quality guidelines. Please be

advised that BC has its own protocol for developing water quality guidelines that should be

followed. BC’s guidelines for aquatic life are developed to protect the most sensitive species, at the

most sensitive life stage, for an indefinite period. BC also allows for the development of site-specific

water quality objectives in situations where the approved guidelines are not appropriate. Guidance

is provided in MacDonald (1997), but it should be noted that we are currently updating our

procedures.

11.5.2.7 89 21 181

The BC water quality guideline for aluminum is for dissolved Al, not total Al.

http://www.env.gov.bc.ca/wat/wq/BCguidelines/aluminum/aluminum.html#tab1

11.5.2.7 90 1 – 29 182

There does not appear to be enough information to do a proper assessment of baseline water

quality conditions. Monitoring should included at least 2 5-in-30 periods (high/turbid flow and

low/clear flow) in order to determine if chronic guidelines are being met. This approach may have

resulted in lower frequencies of guidelines being exceeded (see Table 11.5.2). Clear and turbid flow

periods should be assessed separately.

Appendix E 183

Reference should be made to the approved BC standards for designing water quality studies or

interpreting water quality data (http://www.ilmb.gov.bc.ca/risc/pubs/aquatic/design/index.htm)

(http://www.ilmb.gov.bc.ca/risc/pubs/aquatic/interp/index.htm) 9.3.2

Appendix E 3 184

Section 2 - Data Souces: Report indicates that older data were treated separately using the

rationale that laboratory analytical methods have changed, and earlier data may not be directly

comparable to more recent data. These older data are valuable and in many cases are comparable

to present data and are essential in assessing trends over longer time periods – which may not be

possible with recent data. The older data seems in this case to be discounted – Was this data's

value and relevance assessed prior to being discounted. If so please provide further information on

the rationale for discounting it.

9.3.2



EIS Review Comments



Appendix E

3.6.112 185

TKN is defined as being the bioavailable N fraction using McNeely et al 1979 as a reference. Below

(section 3.6.2) SRP is defined as being the bioavailable P fraction but no reference is given. There is

considerable controversy in how bioavailable are defined – perhaps more recent references should

be referred to here? In App P (Part 1 p 38), the sum of nitrate and ammonium (DIN) is used to

define bioavailable N – not TKN.

9.3.2

App E

3.6.113 186

In the discussion of unionized ammonia, a threshold value of 0.019 mg/L is noted. No reference for

this concentration is given, please provide a reference and rationale for use – guideline values are

dependent on ambient temperature and pH rather than a fixed concentration.9.3.2

Appendix E

Section

3 -

Genera

l

187

The emphasis in this section seems to be on metals and nutrients. TOC and DOC should have been

included at least in a preliminary survey or historical data discussed. They have relevance to aquatic

productivity, mercury methylation and drinking water potential as well as many other applications.

Data are included in Appendix J Part 1 p 42 and Appendix P Part 1 p39 and should be referred to

and commented on.

9.3.2

App B,

Geology Soil

and Terrain

Reports -

Part 4

188

Acid Rock Dranage and Metal Leachate Plan This appendix has minimal information related to

water quality other than reference to the geological survey work reported in the Geochemistry

subsection of Volume 2 Section 11.2 Geology, Terrain and Soils. Evaluation of risk is taken from

previous reports and no specifics as to monitoring or assessment during construction other than

shallow well monitoring and a plan to be put in place if a problem arises. There is a mention of

elevated selenium in some area but little comment as to the risk. Some basic specifics for dealing

with ARD and selenium in the event that it becomes a problem would seem appropriate. Consider

worse case situations so as to prepare for mitigation measures. Mitigation of ARD or Selenium

contamination is a concern and needs to be evaluated in more detail than was done.

9.3.2



EIS Review Comments



Appendix B

Part 417 189

The discussion of metals shows consistent pattern of association between high metals and TSS. Also

reservoirs tend to have lower TSS concentrations than streams which have higher energy flows.

One of the conclusions that might be drawn from this is that the creation of Site C might reduce the

potential toxicity of metals to aquatic life since the metals would be partially lost from the water

column. Discussion of TSS should be expanded to consider the consequences of TSS on water clarity

in the proposed Site C Reservoir. Water clarity will be an extremely important factor in many

aspects of Site C Reservoir (fisheries as well as chemistry and other aspects of biology).

9.3.2

Appendix B

Part 4

A 4.0

QA /

QC

P 12

189

The QA/QC data seem quite minimal in comparison to what is recommended in standard

references on the subject. The RIC protocols suggest that 10% of samples should be a part of

QA/QC. The evaluation of QA/QC samples does not follow the standard Ministry of Environment

methods. Please clarify what reference was followed in evaluating the QA/QC samples and provide

rationale for use.

9.3.2

Appendix H 190

Reservoir Water Temperature and Ice Regime - The work reported on in this topic area appeared

to be well done. The approach and methods were well explained and used models that seemed

realistic and the results seemed plausible. The only missing aspect would have been to run a similar

modelling scenario for dissolved oxygen. Other measurement and evaluations seem to indicate that

DO is not likely to be an issue but it would have been useful to run a modelling simulation to verify

that DO depletion in the deeper water at the base of the dam would not be a problem. DO has a

major effect on mercury methylation and many other chemical and biological processes, so it is an

important parameter in many ways. DO modelling should be done.

9.3.2

Appendix J 191

Aspects of water quality that affect potential mercury methylation are covered (Part 1 p 42) – but

are not included in the Water Quality Appendix E (sulfate and DOC/TOC) Please provide additional

information. Also, please include consideration of a worst case eventuality as well as the

thoroughly discussed likely case. 9.3.2



EIS Review Comments



Appendix P general 192

Part 3 of this Appendix is the most important and the most technically difficult of the sections

related to water quality and aquatic ecology. Predicting changes at different trophic levels and the

interactions between them and the influences of physical and chemical changes that take place in

the creation of a reservoir is difficult. The accuracy of the predictions depends on many factors but

one of the most important discussed here is the many assumptions that are made as a prerequisite

to running models and evaluating the results. Please review the assumptions made with regard to

the models in this section as some appear to be questionable and ensure that the correct

assumptions have been made. More detail on specific assumptions that are cause for concern are

outlined in other comments.

9.3.2

Appendix

Part 3 -

Exec

Summary

p iii 193

The use of the outputs from CE-QUAL-W2 for the predictions of phytoplankton and periphyton

biomasses used as input to EcoPath predictions of potential changes to higher trophic taxa (i.e.,

zooplankton, benthos, and fish) carries with it some risk as the accuracy of the CE-QUAL-W2 model

for biological production seems to carry some weakness. Part of this uncertainty is because CE-

QUAL-W2 was calibrated to data on existing conditions in Dinosaur Reservoir, which as noted above

is not an ideal model for the future Site C Reservoir and part because the strength of the model

appears to be in physical and chemical simulation (rather than biological). The dependency of the

model on the Dinosaur Reservoir data inputs and the assumption that the Site C Reservoir biology,

chemistry and physics will resemble Dinosaur Reservoir is a very poor. The results from W2 are

difficult to accept at the conceptual level. The results of the model indicate that phytoplankton

biomass densities were predicted to increase about 30 times relative to current biomass, in both

the early stage and long term. Average periphyton densities in the simulated reservoir were

expected to decrease to 5% of their current value. The former result (phytoplankton) seems

reasonable the latter (periphyton) does not.

Comment Continued in Next Cell

9.3.2



EIS Review Comments



Appendix

Part 3 - Exec

Summary

p iii 193

Comment Continued

The decrease is explained as being a result of the assertion that the littoral of the new Site C

reservoir would be only 10% - presumably of the whole reservoir surface area – however the

reservoir is much larger. On page iv, the loss of complete riverine habitat is given a 29.6 km2 and

the new littoral area is given as 9.42 km2 so a reduction to one third not 5%. (These

inconsistencies need to be corrected and consistent throughout the BC Hydro submission.)

Conceptually the amount of littoral in the Site C Reservoir (from the shoreline out to the 6 meter

depth) should represent a large area if the reservoir averages 1 km wide. The littoral might not

support the same biomass because of lower flow and water movement but that would be partly

compensated by the clearer water conditions in the reservoir providing potential biomass of

periphyton that should be comparable to the riverine levels of periphyon. It is unclear why the

model predicts such huge decrease in periphyton biomass. The BC Hydro Report requires clarity on

the model results. The input of this assumption of substantial periphyton biomass reduction into

EcoPath would change the outputs significantly. It is suggested that the modelling be redone with

different assumptions for data inputs.

Appendix P

Part 1

Fig 3.11

& 3.16194

The relative proportions of phytoplankton versus zooplankton standing crop in Dinosaur Reservoir

is interesting. Figure 3.11 shows wet weight biomass averaging about 1000 mg/m2 in 2010 (about

half that in 2011) but zooplankton biomass shown as averaging about 500 mg/m2 DRY weight in

2010. If the conversion for WW to DW cited is used, then the biomass of the zooplankton would be

about 3X that of the phytoplankton on average. It would be unusual to have an inverted biomass

structure in the plankton community. Although zooplankton productivity is calculated, no estimate

of phytoplankton productivity is provided - only WW biomass (Fig 3.11 ) and chlorophyll (Table

3.10). Please consider including or provide rationale why not.

9.3.2



EIS Review Comments



Appendix P

Part 1Fig 3.14 195

The presence of Didymo is significant as it has been identified as a problem species in several other

countries – especially Chile and New Zealand where it has caused considerable ecological

disruption. No reference to this potentially problem species is made. Please clarify if efforts have

been made to verify if Didymo is present and describe.

9.3.2

Appendix P

Part 1

10 (and

other

places)

196

Algal PB is a term used in the beginning of the report but later Periphyton PB is used – which is a bit

confusing (Periphyton Biomass?)

9.3.2

Appendix P

Part 169 197

In Table 3.24, zooplankton for Dinosaur Reservoir is calculated for an area of 9.58 km2 although the

footnote indicates that zooplankton in the littoral (2.56 km2) is negligible. The production should be

assessed over only the pelagic area? (9.58 minus 2.56), which should change the annual production.

The production should be assessed for the littoral (2.56) and pelagic (7.02) zones separately to

assess a more realistic annual production.

9.3.2

Appendix P

Part 1 -

Section 4

92 198

In Hypothesis 4 it is noted that “The reservoir was classified as oligotrophic or ultra-oligotrophic

based on comparison of trophic indicators to other systems of known trophic state and to

classifications in respected text (Section 3.4). On the basis of nutrients and biological production the

conclusion is supported but the Secchi data do not support a classification of oligotrphic . The

reasons for not using the Secchi data and why this metric was rejected should be noted. 9.3.2



EIS Review Comments



Appendix P

Part 1 -

Section 4

92 199

In Hypothesis 5 the discussion revolves around spatial patterns of periphyton down the river and

whether it is related to phosphorus concentration – specifically whether the increased loading of

bioavailable P when proceeding downstream causes increased periphyton growth. The conclusion

reached is that there is no increase in algal biomass that corresponds to the increased SRP load.

However, there are other factors that explain the lack of correspondence. The first possibility is that

algal production (and biomass) is limited by light and not by P. Light penetration / transmissivity in

the river apparently was not measured so could not be evaluated as a possible factor in biological

production. Please measure and evaluate this factor as the creation of a dam at Site C and the

presence of a larger body of water in the valley and longer water residence time is likely to result in

higher TSS settling rates and clearer water with more light penetration.

9.3.2

Appendix P

Part 1 -

Section 4

92 200

The rationale regarding defining the littoral zone for Dinosaur Reservoir in Hypothesis 1 has some

problems. There is no problem with the depth chosen (6m) but some of the logic is hard to

understand. One of the arguments for the 6 m boundary was that this was the depth to which light

penetrated allowing photosynthetic growth (“vertical extent of living algal biomass growing on

epilithic surfaces”). However the data presented in Figure 3.1 shows significant periphyton growth

to 12 or 13 meters and it is hard to see how 6 meters can be derived from this particular graph. A

second piece of evidence is the Secchi disc data which shows that these measurements (Table 3.11)

are 4.9 in 2010 and 2.3 in 2011 (a very high flow year). The general relationship between Secchi and

1% light is a factor of between 2 and 3 so in 2010 (the more typical year) the 1% light penetration

depth would be 9.8 to 14.7 m not the 6 meters chosen. While the 6 meters is reasonable, the

reasons used to rationalize the value is not. Please revise the rationale and clarify the points above.

9.3.2



EIS Review Comments



Appendix P

Part 2

Part 2,

1 of 4 201

The accuracy of predictive models depends on a number of things. One of the assumptions that the

application of CE-QUAL-W2 to the Peace and Site C Reservoir system seems to make is that the

width of the river is treated as a homogeneous cross section. This is in contrast to Part 1 where

much effort was made to define littoral and pelagic zones since the dominant ecological processes

in each are quite different. In the reservoir after filling, the shore zone out to a depth of 6 meters

would be a system dominated by periphyton as primary producers and benthic invertebrates as

primary consumers. In the dominant pelagic zone (most of the 980 m average width), the dominant

producer is phytoplankton with zooplankton as the next level of the food chain. Without

consideration of these two distinct ecological zones, it is unclear how the model can accurately

model the new reservoir and predict periphyton and phytoplankton quantities. It is recommended

that a more detail/clarification on this modelling procedure and it's accuracy be added to the

report.

9.3.2

Appendix P

Part 2

Modelling

figures

20 202

It is not clear what Figure 4.20 is attempting to portray - Please consider presenting this information

in a different way.

9.3.2

Appendix P

Part 2

Modelling

figures

27 203

In Figure 4.27 the low observed D0 values at Peace 1 (a value of <2 mg/L in 2008) and at Peace 2

that lie considerably outside the predicted concentration line need some explanation. Since they

also occur at the same time at Peace 4 and 5, there appears to be a sampling problem - If the data

are real, please provide an explanation for these low D0 values. If there is any doubt as to their

accuracy, they should be disregarded and not used. Please provide further explanation for the low

D0 value.

9.3.2

Appendix P

Part 2

Modelling

figures

31 204

In Figure 4.31, it appears that the direction limits for ammonium changed in mid 2010 and it seems

strange that the modeled concentration produced by W2 also track this analytical detection limit

change. This also seems obvious in looking at the modeled concentration of nitrate in Figure 4.33.

Please explain.9.3.2



EIS Review Comments



Appendix P

Part 2

Modelling

figures

46 205

In Figure 4.46 the simulated DO profiles especially for Peace 3 for mid August or mid September

would be far more useful than July 8 or October 30 which are the profiles shown since the August

and September periods would be the most sensitive and more likely to show if there were any

significant DO depletion in the deeper waters of the reservoir. Please consider revising. 9.3.2

Appendix P

Part 2

Modelling

figures

58 206

The predicted phytoplankton biomass appears to underestimate the observed values fairly

consistently and by a significant amount. This seems counterintuitive for phytoplankton and is also

likely for periphyton. The observed phytoplankton biomass (presumably before reservoir flooding)

should be much higher than after the reservoir has filled and the conditions for phytoplankton are

much more favorable. If this is different there should be more clarification of the data. Please

explain. As a general observation, parameters such as temperature seem to be predicted much

more accurately than biological parameters – which is understood to be the primary purpose of this

modelling.

9.3.2

Appendix P

Part 2

Modelling

figures

118 of

121 5.0

Summa

ry

207

Some of the conclusions reached using CE-QUAL-W2 seem reasonable but others seem less

plausible. One of the reasons for less confidence in the biological predictions may be the reliance of

using Dinosaur reservoir data as a predictor of how Site C Reservoir may function. Dino Reservoir is

very narrow and steep sides and not at all what the topography of Site C is like. Many of the other

fundamental properties (water exchange time, nutrient supply, substrate) differ fundamentally and

will affect how accurately data from one reservoir can be transferred to another. A number of

relevant parameters were modeled including TSS but some prediction of water clarity (which

should have a reasonable relationship to TSS) is not and this would be a critical factor in modelling

both phytoplankton and periphyton biomass and production in the proposed Site C Reservoir. It is

recommended that the modelling be done on the basis of a different comparative that may be

more consistent with the proposed Site C reservoirs.

9.3.2



EIS Review Comments



Appendix P

Part 3

Figures

6B.1-4208

Figures 6B.1 - 4: These figures show in visual form what was being attempted to describe in the

above comments. The circles are presumably proportional to the biomass of each individual

component and show the relative small size of the primary producers in comparison to the

secondary trophic level - and the relative importance of the detritus component in the food chain.

Whether or not it is realistic is likely a topic of some discussion. It is recommended that the figures

are clarified.

9.3.2

Appendix P

Part 3

Table

6A209

This table contains much of the basic information that was used in the EcoPath simulation and it is

interesting to look at the larger view of the applicability and if some of the quantitative estimates of

the trophic components – especially how primary and secondary levels of production quantities

look in what might be seen in a more conceptual view of the Site C Reservoir biota. With

phytoplankton biomass estimates at 2.25 t/km2 and the levels of secondary biomass of cladocera

(2.1) and copepods (3.8) indicate similar quantities of biomass in the water column for all three

groups (on an average basis) which unusual but not unrealistic. Whether or not this biomass of

phytoplankton would provide a sufficient food base for zooplankton would primarily depend on the

P/B ratios that are applied to each group. The choice of P/B ratios is important and the values used

differ in this report from some used in the literature. Similarly the comparison of the biomass of

benthic algae in the reservoir at a low 0.6 t/km2 and the benthic invertebrate biomass at 3.8, the

chosen P/B ratios are critical in assessing whether the modeled biomass values are reasonable. The

wild card value that was used was for detritus at a very high 50t/km2 – presumably will compensate

for the low periphyton biomass as a food source for benthic invertebrates. However the detritus

value is given as a “guesstimate” with no indication of what it was based on. It is recommended

that additional clarification is required regarding the biomass modelling and the P/B ratios.

9.3.2



EIS Review Comments



Appendix P

Part 3

Section 3

12 210

In this section some of the background for the W2 output values for phytoplankton and periphyton

to production quantities poses a possible source of error. The table indicated P/B ratios of 43 for

periphyton and 28 for phytoplankton. Typical "average" P/B ratios cited in textbook sources like

Wetzel (2001) are much higher (113 is the value cited for phytoplankton). The result would again be

an underestimation of primary production. Please address9.3.2

Appendix P

Part 3

Table

3.2

P. 15

211

The extrapolation of the W2 output values for phytoplankton and periphyton to production

quantities is another possible source of error. The table indicates P/B ratios of 43 for periphyton

and 28 for phytoplankton. Typical “average” P/B ratios cited in textbook sources like Wetzel (2001)

are much higher (113 is the value cited for phytoplankton). The result would be again be an

underestimation of primary production. Please address9.3.2

Appendix P

Part 3

Table

4.1,

P 18

212

The table shows are of littoral using a 10 m depth of light penetration - which may be a more

realistic estimate. However it is noted that all calculations use the 6m assumption. These

inconsistencies need to be addressed in the BC Hydro Data. 9.3.2

11.6.1 92 20 - 22 213

" An evaluation of project construction on groundwater (GW) quality indicated that there is a low

likelihood that GW chemistry would undergo change and affect GW use". No rationale has been

given for this statement given. Please make reference to the relevant sections that support this

statement.

9.3.3

11.6.10 101 3 - 5 214

Please ensure that, when developed, the "Contaminated Site and Groundwater Quality

Management Plans" include ongoing GW quality monitoring as needed and appropriate to identify,

characterize, monitor, and remediate any impacts associated with GW elevation rise. 9.3.3

11.6 - Groundwater Regime



EIS Review Comments



11.6.4.2

Genera

l

comme

nt

215

The condition of a well may affect the water quality, such as pathogens, especially shallower wells

in proximity to the reservoir shoreline where there is greater change in groundwater levels. The

conditions of the drinking water wells should have been assessed as part of the field program to

assess whether there were any sanitary issues with them.9.3.3

11.6.4.2 95, 961 - 36;

1 - 5216

When a reservoir fills and groundwater (GW) gradients are changed, the redox can have a

significant influence on the water quality (e.g., Fe, Mn). Experience in Revelstoke in the mid-1980’s

suggests when reservoir levels are high there, the well water quality deteriorates; when the

reservoir level drops, water quality improves. Establishing redox conditions initially will help

address likely causes of changes in well water quality during construction and operation of Site C. It

appears redox was not measured. BCH should measure redox conditions and assess potential

implication for well water quality during dam construction and operation.

9.3.3

11.6.4.3 11-96 6 - 21 217

Modelling work should be consistent with best practices documented in: Guidelines for

Groundwater Modelling to Assess Impacts of Proposed Natural Resource Development Activities9.3.3

11.6.4.4 96 31 - 34 218

It appears that contaminated sites have been identified in or near the flood zone. What is the

remediation strategy for the contaminated sites before the construction of the reservoir to make

sure that the risk of groundwater contamination is minimized? It should be noted that

groundwater contamination may affect the entire regional aquifer if it gets polluted at some part of

an aquifer.

9.3.3

11.6.5.1 97 9 219 Information on the springs can help identify potential aquifers to allow assessment of impacts on

them? Please clarify if the flow and chemistry of these springs was measured. 9.3.3



EIS Review Comments



11.6.5.2 97

General

comme

nt

220

The effect of groundwater level changes on slope pore pressures and risk of slope instability has not

been addressed in Section 11.6. Slope stability was briefly referred to in the EIS Guidelines for the

Groundwater Regime in Section 9.3.3 (2nd bullet). The affect of groundwater level changes on risk

of slope instability should be assessed, and if so should be briefly described here as well. 9.3.3

11.6.5.2 98 8 - 12 221What are the specific implications for those wells, springs, infrastructure and land use that could be

affected? 9.3.3

11.6.6 98 30 - 32 222

Please clarify what, if any, remedial measures will be implemented to minimize contamination of

water sources before filling of the reservoir. Mitigation measures should include initial and ongoing

GW quality monitoring (as needed) in inundated agricultural areas to assess and monitor impacts

associated with GW elevation rise. In particular, monitoring should address soluble pollutants

related to agricultural activities (e.g., nitrates).

9.3.3

Section

11.6.6223

Please clarify if project has the potential to impact the groundwater regime in surrounding

tributaries (eg. Halfway, Moberly)? Groundwater upwelling is an important environmental factor in

bull trout red site selection.

11.6.7 99 2 - 4 224

Groundwater quality could become influenced in situations where either a flooded septic field or a

contaminated site with impacted groundwater is located in close proximity to an operating water

well. For impacted domestic water wells, please consider including initial and periodic GW quality

monitoring (as needed) to assess and monitor (if needed) any associated effects between GW

elevation rise and GW quality as mitigation measures.

9.3.3

11.6.7 99 2 - 4 225

Six know/identified water wells are expected to undergo direct submersion. Please clarify if

alternative potable water sources have been identified for the current water users in the area after

decommissioning these wells. 9.3.3



EIS Review Comments



11.6.8 99 32 - 33 226

In addition to the loss of the agricultural land, formation of wetlands may also occur along the sides

of the reservoir where groundwater level rises to the surface, which leads to a significant eco

system change in the area. Please clarify if this scenario has been considered in the EIS.9.3.3

11.6.8 99 15 227

Please expand the study to identify known and potential aquifers and assess what percentage of

aquifer areas may be lost. 9.3.3

11.6.9 99 35 - 40 228

It has to be emphasised that, decommissioning of structures and remediation of contaminated sites

before the inundation is a very critical step to minimize the risk of contamination of regional

potential aquifers in the area. Polluting a regional aquifer will aggravate the already stressed water

resource condition in the region.

9.3.3

11.8.4.1 130 23-27 229

Please clarify why the minimum duration of wetted work was used in the calculation of sediment

loading. The precautionary principle would seem to push one towards using the maximum

duration.

11.8.5.1 138 28-36 230

Please clarify the following issues within this section.

1. Talks about grain size bias in the sampling and having to estimate the grain size curves. If that

was the case, why was it not re-sampled?

2. Why was there limited site access to the shoreline resulting in Lidar being uses instead.

3. Thickness of colluvial deposits were estimated based on LIDAR imagery – please clarify if any test

pits were done, and if not, why?

11.8.5.1 139 40-45 231

This paragraph describes the ‘acceleration’ of the sediment deposition model by applying a

multiplier of 10 to a 5 year run to simulate that of a 50 year run. While not knowing the nuances of

the model they were using, this sort of ‘jiggling’ does raises concerns if more detail is not provided.

11.8.6 145 10 232 Please define ‘Further downstream’. How far downstream?

11.8- Fluvial Geomorphology



EIS Review Comments



11.9 30 233

Baseline is here is defined as conditions prior to anthropogenic disturbances. The report does not

discuss whether baseline metal data is available prior to the development of the WAC Bennett and

Peace Canyon dams.

11.9 19 234

Baseline conditions are defined as after the installation of the WAC Bennett and Peace Canyon

dams. A baseline selected in the pre-regulation period would be more suitable when considering

aquatic organisms.

11.9 29 235

Mean peak concentration was used to on the assumption that this better approximates typical

human exposure (eg. eating fish). This does not indicate the range in Hg levels and does not

quantify the distribution of samples around this mean (eg the percent of the population with Hg

concentrations that may result in behavioural or reproductive impacts).

236There is no discussion of what effects the predicted Hg values could have on fish health and

behaviour for the species in the Peace

11.9- Methyl Mercury

Section 12 - Fish and Fish Habitat



EIS Review Comments



12.1 237

Focus is on a limited subset of fish species - The fish fauna in the Peace River system is diverse (39

spp.) and provincially distinctive and this is adequately not reflected in the EIS.

Concern: The depth of information on species assemblages and individual species varies in the EIS,

with detailed treatment available on a relatively small subset of species, primarily the more

charismatic ones.


(a) Clarify what empirical data exists on fish species and populations not emphasized in the EIS (see

Detailed Examples).

(b) Where empirical data exists on other fish species, summarize the status and future outcomes of

these species and populations in the LAA and RAA.



EIS Review Comments



12.1 238

Arbitrary division of fish fauna into large-fish and small-fish components - The EIS splits the fish

fauna into large and small fish for some assessments, however, such a division appears arbitrary, is

not well supported and may make assessments inaccurate.

Concern: The division of the fish fauna into “small” and “large” appears arbitrary and not provided

with references from biological study (pg12-25, line 29). Assumptions on seasonal and annual

movement/migrations life history functions of small species are questionable without supporting

references. For example, the statement that the ability of a “fish” to move extended distances

(upstream) is related to its maximum size may be true for large fish in the short-term (1 year);

however, many small fish move upstream as an essential life-history function (e.g., sculpins), it may

take several generations to complete the same distance a large fish does in one season, but it is no

less important to biodiversity and survival of the “small” fish species.


(a) Redo the assessment without the seemingly arbitrary division into large and small fish (unless

solid support for this approach can be provided from the literature).

(b) Provide literature sources to support assumptions on the ranges and temporal movements of

small fish species over periods of time (e.g., annual vs. longer periods).

(c) Clarify whether sufficient empirical data exists on small-fish species and populations for the

Project area. If this data exists, summarize and discuss the status and future outcomes of these

species and populations in the LAA and RAA.



EIS Review Comments



12.1 239

Arbitrary division of fish fauna into large-fish and small-fish components: More detailed

evaluation of focal species is a reasonable approach, but non-focal species receive too little

attention. Monitoring is needed to verify important assumptions in the analyses, particularly where

the information base is limited.

Concern : Since the decision not to focus on some species was due to the limited information base,

attention should be given in follow-up programs to improve information on those species and

monitor to evaluate whether assumptions used in the assessment of impacts are reasonable (and if

not then impacts must be addressed after the fact). For example, there appears to be a general

assumption that small fish don’t migrate and therefore won’t be affected by entrainment or

blocked passage.


(a) Provide a rationale (with references) for the general assumption that small fish don’t migrate

and therefore won’t be affected by entrainment or blocked passage.

(b) Monitoring should include fish species other than focal fish species in order to test assumptions

applied in the EIS to assess impacts.

12.1 240

Habitat suitability, preferences, and effects of altered flow regimes - The suite of habitat values

appears to be comprehensive but habitat suitability and preference information is incomplete.

Concern: A large body of information has been brought to bear on understanding fish populations

and potential impacts. Inclusion of this information would help clarify current fish species and

population distributions (see Question 2).


(a) Describe the present use of the Peace River and its tributaries by Arctic grayling and other

species by life stage



EIS Review Comments



12.1 241

Habitat suitability, preferences, and effects of altered flow regimes - The impacts of daily flow

fluctuations in the Peace River downstream of the proposed project are poorly addressed in the EIS.

This is a substantial omission from the assessment.

Concern: Daily flow variations associated with the dam would increase in magnitude as a result of

the project, and high flow periods would shift from night to day. These changes will likely result in

impacts over a large spatial scale (downstream to the provincial border) but the impacts and

residual effects on fish are not addressed in the assessment.


(a) Describe potential uncertainties related to predictions of the future quality of habitats

downstream of the Site C dam. Including the effects of flow variations and the consequences of

shifts away from typical daily flow variations for fish populations.

(b) Provide a synthesis of available information on depth-velocity/physical habitat to explain

existing fish distributions and likely future outcomes in response to the Project.



EIS Review Comments



12.1 242

Ranking of fish habitat and fishing values - Habitat-related and recreational fishery-related Valued

Components are poorly defined.

Concern:

The replacement of river habitat for high-throughput reservoir habitat is a key consideration for

valuation. Values for river versus reservoir habitat and fisheries are different. Overall harvest is the

value examined; however, angler preferences and other factors influence the valuation of existing

and future habitats and fishing opportunities.

Species changes between the existing river environment and the future reservoir may limit the

attractiveness of the future reservoir fauna to recreational anglers. Anglers may place higher value

in catching a bull trout than a kokanee. LGL (2009) (and roughly, table 24-7) indicates that the vast

majority of fishing effort is currently upstream of the Site C dam location. A survey of current users

may indicate a lower perceived value of reservoir habitat. If this is the case, the two types of fishery

are not weighted equally, which could imply a significant reduction in recreational fishing values

overall.


More thoroughly assess impacts to fish values in the future reservoir in regard to potential

recreational fishery. Talking to the resource users about their perceived valuation of these

components would add useful (and relevant) context to the EIS. To answer this properly, an angler

preference survey (or some similar method) would be useful.



EIS Review Comments



12.2 243

First Nations fishery values - It is not evident whether the EIS includes First Nations harvest levels

for food and ceremonial purposes as an indicator..

Concern: Fish Values for First Nations received little attention, and should be expanded upon.


(a) Provide information on the current status of FN use of fish in the LAA and RAA, as available;

and

(b) Assess how First Nations harvest of fish for food and ceremonial purposes might change as a

consequence of the Project.

12.3 244

Limitations to understanding current status of species and populations: Assessment data appear

to be predominantly qualitative or “index level” - There are shortcomings in quantitative

information on some components and attributes of the fish and fish habitat values. Also the level

of detail for habitat descriptions varies between main-channel Peace River and its tributaries, and

among the tributaries.

Concern: Basic biological information (baseline or background) was not presented for most species

in the LAA, tributaries to the LAA, and the RAA. Most assessments are made on the higher profile

“focal” or “charismatic” species.

Habitat is described as suitable for fish sporadically and with varying degrees of detail: For

example. There is no comment on suitability of habitat for fish in areas with known information

(e.g., Chowade or Murray), but fish habitat values are described in areas with less information (e.g.,

Cypress described as high and side channels in Moberly identified as important spawning and

rearing habitat for northern pike)

Continued in next box



EIS Review Comments



244

Previous Comment Continued Request that

the Proponent:

(a) Describe the limitations of the fish population assessment procedures used and the

consequences for the level of uncertainty about current population status, in order to provide a

more credible context for comparing the current fish fauna with the projected outcomes for the

Site reservoir, its tributaries, and the portion of the Peace River downstream of the dam.

(b) Explain how “general patterns of distribution and abundance” (incidental, scarce, restricted,

abundant) were quantified to develop numerical stock status. Include a definition of these terms as

used in the EIS. Is this based on data from Table 5.2.2 (p. 72)?

(c) Include a discussion of abundance versus distribution when observations appear somewhat

contradictory. For example, Arctic grayling were listed as scarce in the Peace River mainstem in BC

(limited to a few areas and not abundant), but are recorded as widely distributed along with bull

trout (found in 6 of 9 survey zones in mainstem Peace) section 5.2.2 (p. 76). See p. 72, 80, 104.

Continued in next box



EIS Review Comments



244

Previous Comment Continued Detailed

Example:

According to the Fish and Fish Habitat Technical Data Report and supporting consultant reports, the

fish inventory/stock assessment methods essentially involved localized sampling at spatial intervals

in both the Peace River LAA/RAA and tributaries to the Peace River in the LAA, most frequently in

marginal shallows. Gear used varied based on site conditions and could include various

combinations of large and small-boat electrofishers, backpack electrofishers, beach seines, and gill

nets. Sample sites included main-channel margins, side channels, and tributary junctions. Fishing

effort and habitat types were recorded, but data generated were limited by several factors

including emigration/immigration from the non-enclosed areas surveyed and the differential ability

to catch different species and life stages.

These surveys were accompanied by fish fence operations to document spring and fall use of

tributaries, rotary screw traps to obtain indices of downstream fish movements in the Peace River

and tributaries, bull trout spawner and red surveys in one drainage, movement studies of sport fish

by radio telemetry, and fish habitat descriptions throughout the LAA/Peace River RAA.



EIS Review Comments



12.3 245

Lack of description of methods for fish assessment - It was difficult to find details on

methodologies employed for fish population assessments. The inventory methods employed are

generally not well described in the main body of the report. Field assessment techniques are not

even mentioned broadly by name.

Concern: The type of data collection approaches and sampling methodologies used will generate

estimates for current fish species and populations that carry a level of uncertainty that is not fully

discussed in the current EIS. This uncertainty carries through to the Impact, Mitigation, and

Residual Effects components of the EIS.

A lack of information on methodologies makes it difficult to determine the level of rigor around the

status of fish resources and determine whether fish and fish habitat inventories and the

information they generated are credible. Based on what is known about the methods, there is the

potential that total abundances, biomass, and productivity of species in the Peace River and its

major tributaries within the LAA are currently underestimated. This will affect the evaluation of the

success of project’s mitigation actions including the reservoir “replacement” fish community, and

residual impacts. Uncertainties also need to be clearly defined.



EIS Review Comments



245

Previous Comment Continued


(a) Provide more details in the text of the EIS regarding methods of fish population assessment or

provide clear cross-references and links to relevant supporting documentation.

(b) Provide a more fulsome presentation and discussion of uncertainty to present a more credible

context supporting existing fish population and habitat assessments and projected future outcomes

after the Site C completion.

Detailed Example:

See specifics in detailed examples above. The studies are variously and vaguely termed as

“standardized fish investigations” or “structured and repeated fish collection methods”, but the

reader needs to look into the appended Fish and Fish Habitat Technical Data Report, supporting

documents, and sometimes deeper into the referenced literature by accessing web-based search

engines (usually consultants reports) to find out enough about methodologies to determine

whether fish and fish habitat inventories and the information they generated are credible.



EIS Review Comments



12.3 246

Issue: Incomplete sampling or analysis of fish habitat and population data - Fish

population/community sampling (and habitat sampling in some locations) was distributed unevenly

across the project area. For example, no fish community sampling was conducted over the dam

site. The species composition of the fish fauna in the LAA and RAA portions of the Peace River and

major tributaries to the LAA, and the relative abundance are described primarily in a qualitative

sense. Population status is not described quantitatively. Descriptions are based from sampling

programs and studies which generated qualitative data or semi-quantitative index data at best.


(a) Provide a rationale to explain variation in level of sampling in different areas within the LAA

and RAA, and for the analysis and presentation of a subset of the collected data. For example: (i)

Only 2011 data for fish abundance was presented. The EIS states that similar patterns were

recorded in 2010 and 2012. What was the justification for only presenting the data from one year

when 3 years of data are available? (ii) Tributary data on fish were collected in both 2008 and

2009. Why was only 2009 data presented? (iii) It appears that

no mesohabitat data were collected for the lower, middle mainstem, and upper East regions of the

Kiskatinaw River. Also, no macrohabitat information was presented for upper east and upper west

regions. Clarify whether data was collected for these areas and, if it exists, why it was not used in

the assessment.

(b) Clarify if habitat data were collected for lower and middle main-stem Beatton. Is there a

forecast of how will the lower reaches of the Beatton and other tributary streams may be affected

by flow changes?

(c) Re-analyze fish population and community information using all available data (including gaps

noted above).



EIS Review Comments



12.3 247

Incomplete sampling or analysis of fish habitat and population data - There is uncertainty

regarding the contribution of mainstem Peace River spawning to population recruitment and the

diversity of fish using side channel habitats.

Request that the Proponent: Provide additional information to substantiate the EIS claim of a

relative (or lack of) importance of Peace River spawning habitat (mainstem spawning to

recruitment of nearly zero; pg 12-27, line 21), and the relatively low level of diversity associated

with side-channel fish community composition (pg 12-28 line 29; see Details)

Additional Details: 12-28, 29: The statement that mainstem side-channels support only 5 fish

species is questionable. Side channel (and tributary) productivity and diversity often greatly

exceeds that of river mainstems. These areas also supported abundance and diverse benthic

macroinvertebrates communities, and therefore were essential for juvenile and larval fish such as

the Arctic Grayling. Perhaps the Peace River is different, but no references are provided.



EIS Review Comments



12.3 248

Use of relative abundance and total biomass to characterize current and future fish faunas - The

EIS would be improved with reliable quantitative estimates of population abundance, productivity

(e.g., biomass), and distribution by habitat and life stage. Limited or little quantitative fisheries

information was presented for most species. Stock assessment data are qualitative at best. True

abundance and biomass data are needed. These characteristics are therefore incompletely known

for the Peace River and its tributaries in the LAA. Habitat suitability information by life stage and

species would be helpful.

Concern: The quality of the data describing baseline conditions will affect the interpretation of

potential impacts to fish and fish habitat values, and the relative success achieved by the post-

project replacement fauna in the reservoir.

Additional Details: Use of the metric “long-term average standing stock biomass” seems a

simplistic and inadequately defined measure of the fish community. Also there is no biodiversity

measure, and as written implies the replacement of several fish species with another fish species is

not a significant residual effect if the comparisons are made only in terms of biomass.

Request the Proponent: Describe species and life stage abundance and distribution at mesohabitat,

reach and larger scale to the extent that sufficient stock assessment data are available. Such

information would clarify the use of the main channel of the Peace River by several species

including Arctic grayling. This would be preferable to the existing EIS approach of using broad

measures of faunal and focal species biomass for characterizing current status.



EIS Review Comments



12.3 249

Uncertainty about the spatial boundaries of discrete fish populations and the importance of

migrations - The relationships between populations in the LAA and its tributaries, and the RAA

portion of the Peace River and the LAA are uncertain; for example, the role and importance played

by seasonal migrations for spawning and other life history phases. These relations are also

described primarily from qualitative information (indices of seasonal migrations, spawners). The

separation of resident versus migratory components for different species such as bull trout in the

LAA remain problematic.

Uncertainty exists on (1) the relative abundances of migratory vs. resident populations of species

using the same drainages for spawning and rearing; e.g., Halfway River bull trout; and (2) the

contribution to spawning populations in the LAA and its tributaries made by migrants from the

Peace River originating downstream of the proposed Site C dam. These uncertainties affect the

nature and level of project impacts as well as mitigation strategies and effectiveness.

It is unlikely that detailed migration studies have been completed for the majority of species in the

area (information used from other biogeographic zones is probably not transferable).

Concern: There was limited description of the species, life-stage, timing, and quantity of fish

migrating by the proposed Site C dam site, especially for small fish, or at other possible dam sites.

Most of the techniques and information presented in Section 12 and the supporting technical data

report related to determination of presence/absence of fish species.




EIS Review Comments



249

Continued

Radio telemetry work to define fish migrations seems sufficient to get a general impression of

migration timings and distances, but inadequate to quantify the characteristics of the population

proportion migrating, range of migrations, migration frequency, etc., as the number of species and

sample sizes of tagged fish were small and limited to a size of fish that could carry tags. Tag

(battery) life was relatively short compared to the lifespan of the species. Results could also be

limited by river conditions and the very large geographic area. Also, capture locations were few,

relative to the number of populations and life-history types potentially present. Therefore, it

appears conclusions are qualitative with no measures of confidence (uncertainty) possible. Mark/

recapture work had similar limitations, and was limited to fewer species.


(a) Acknowledge gaps in the current understanding of life histories and spatial extent of

populations throughout the LAA/RAA.

(b) Describe the implications of these gaps in regard to the uncertainty about the status of current

populations and comparisons to future post-Site C fish fauna outcomes.

(c) Describe the approach to estimating resident and migrant components of different fish

populations, e.g., Pine River bull trout, including the level of confidence in these estimates.

(d) Review assumptions/ conclusions on longnose sucker movements being “local”.



EIS Review Comments



12.3 250

The definition of fish population and method used to define their geographic areas may be out-of-

date and incomplete. The “same point of time” portion can be broadly interpreted.

Contemporarily definitions of populations contain a component such as “a distinct group which has

little demographic or genetic exchange”. Use of a “geographic area” to define a fish population

may not be correct for highly migratory species such as those found in the Peace River. With Bull

Trout, for example, it may be more appropriate to use genetic clustering methods to define

populations. Assuming a geographic population structure may over estimate structure (see

Warnock et al. 2010). [Warnock, W.G., J.B. Rasmussen, and E.B. Taylor. 2010. Genetic clustering

methods reveal Bull Trout (Salvelinus confluentus) fine-scale population structure as a spatially

nested hierarchy. Conservation Genetics 11:1421–1433.]

12-29, 44: The Peace River is likely a migration area from more than “several”, or 8 of the 32-39

fish species in the watershed. The provided list of 8 excludes all the “small fish” such as redside

shiner and longnose dace, which probably depend on the mainstem as a migration corridor. Small

fish do migrate, both at the individual and population levels. The summaries of the fish studies in

the appendices indicate many of these small fish species were caught in trap nets, which suggests

they were moving over some distance. Daily migrations may be short for most individuals, but

seasonal and occasional (every few years) migrations may occur and be important for population

persistence.

Comment Continued in next cell

250

Comment Continued

Longnose sucker movement strategy is describes as “local”. This conclusion should be reviewed.

This species is long lived (20+ years), can grow to a large size (30-50 cm), are numerous in the

project area, and there is some evidence of local, complex, and possibly long migrations (see

McLeod et al. 1978, in McPhail 2007). They do spawn in streams, and they do migrate in other

areas (Bailey 1969; Montgomery et al. 1983), which suggests spawning migrations could be long,

involving main-stem Peace River and downstream end of tributaries. This is suggested in the EIS in

12-26, line 33.



EIS Review Comments



12.3 251

Uncertainties about life histories - The use of “general life history parameters” is probably not

appropriate for many of the fish populations in the Peace River (Page 12-9 line 14).

Concern: Location-specific information should be provided to supplement the more general

understanding of life history and habitat, particularly for focal species. There is little information

specific to the Project area for many of the fish species assessed but life history characteristics can

vary with location, for example, due to hydrology. Where local information is not available,

descriptions from other freshwater biogeographic zones may apply (e.g., on migration timing,

distances). Key publications describing these species in BC (e.g. McPhail 2007) often rely on studies

conducted in other parts of North America, or the world.

For example, little is known about the habitat used by different life stages of mountain whitefish in

central and northern BC and life-history characteristic of the longnose sucker are based on accounts

from elsewhere in N.A. However, these species are the most abundant in the project area (McPhail

2007) and are likely keystone species, similar to salmon in coastal rivers e.g., as drivers of

productivity and nutrient dynamics. Both mountain whitefish and longnose suckers are highly

migratory with at least 5 known migrations and associated habitat shifts:

• post spawn fall migrations to overwintering sites

• spring feeding migrations

• summer feeding migrations

• fall pre-spawning migrations

• spawning migration

Comment Continued in next Cell



EIS Review Comments



251

Above Comment Continued


Clarify sources of location-specific information on fish species used in the assessment. (See also

previous Comment re “Uncertainty about the spatial boundaries of discrete fish populations and

the importance of migrations”)

Additional Details

Page 12-16, line 1: Table 12.7: Pygmy Whitefish have fluvial populations in the interior of BC,

although little is known about their life history and ecology (see McPhail 2007, p. 381) ().

Reference: McPhail, J.D. 2007. The Freshwater Fishes of British Columbia. The University of Alberta

Press. Edmonton, Alberta.



EIS Review Comments



12.3 252

Issue: Definition of baseline conditions - Baseline conditions are defined as present conditions, but

the true baseline is the pre-impoundment pre-flow control era for the Peace River

Concerns:

12-9, 10: There may be trends in fish populations that are relevant to the overall assessment of

impacts and residual effects. It is likely that the Peace River is still adjusting to the original

perturbations caused by regulation (e.g. geomorphologically) and the fish community may be

undergoing a long-term adjustment. While it may be unreasonable to consider pre-impact as the

baseline, it is still a useful reference point.

12-46, 15: The use of current conditions as a baseline for temperature may be problematic.

Particular attention should be given to the historical condition, since that is the important context

for the native fish fauna and their preferences and tolerances. The EIS predicts that the proposed

Project will have limited effects on water temperature. However, when superimposed on prior

changes, the incremental impacts could be greater than projected. Therefore, current condition is

not the only baseline that needs to be considered.


(a) Include a description of pre-impoundment conditions to use as a reference point.

(b) Review trends in fish populations since the existing dams were created and report on trends

relevant to the assessment.

(c) Provide a review of the extent to which water temperature changes due specifically to this

Project are diminished due to the already regulated state of the river. What are the cumulative

effects of all impoundments (existing and proposed) on water temperatures and fish?



EIS Review Comments



12.3 253

Lack of aquatic nutrient data from the Peace River and tributaries - Orthophosphorus data was

only collected in 2007/08 and in 2010. No total phosphorus data was collected.

Concern: Orthophosphorus and total phosphorus would further inform a description of future

forebay epilimnion and aquatic productivity. This is likely a limitation to the productivity model

accuracy, as is the apparent homogenization of the limnetic area with an overly optimistic level of

productivity – which would result in an overestimation of predicted secondary productivity levels

and fish populations abundance/assemblage.


(a) Clarify if empirical data on orthophosphorus are available to refine forecasts of future

conditions; and

(b) If these data are not available, provide a more complete discussion of uncertainty associated

with these forecasts of forebay epilmnion and aquatic productivity.



EIS Review Comments



12.4 254

General categorization of effects and identification of interactions - Conceptually, the

categorization and identification of ecosystem components and processes affecting fish and fish

habitat both within the Local Assessment Area (LAA) and Regional Assessment Area (RAA) are

generally complete and well laid out as are the potential interactions and impact sources over all

phases of the project. However, there is concern that all identified impacts have not been fully

described.

The broad scale outcomes where the interactions were judged significant, are well described in

general. However, there is uncertainty in the full extent of outcomes for the LAA, its tributaries,

and the RAA for fish and supporting trophic levels (see below).

Concern: Significant effects were identified for several stocks of fish including Moberly River Arctic

grayling, Halfway River bull trout, and Peace River mountain whitefish. The possibility of losing

these stocks was acknowledged.

However, the description of the likelihood of these outcomes could have been improved. The

projected effects on other fish species varied in level of detail, and modelled effects on other

trophic levels raised concerns linked to models used, assumptions, and input data (see below).



EIS Review Comments



12.4 255

Describing any and all impacts associated with the Site C development as “potential” - The

damming of the Peace River, the consequent disruption of fish migrations, the elimination of river

habitat, the creation of reservoir habitats, the changes to the flow regimes associated with the

operation of the dam, and alterations to fundamental ecosystem processes are all clear and certain

impacts to aquatic habitats. This is not reflected in the text of the EIS.

Concern: The project will certainly alter and impact habitat. The use of the term “potentially” sets a

tone that does not particularly establish an atmosphere of openness. The text should indicate that

habitat will be affected, as this is the subject of the EIS content around mitigation. The term is

inconsistent with the report’s findings and could be interpreted as misleading (pg 12-1 line 4).

Request that the Proponent: be more forthcoming in the EIS about the obvious changes that will

occur to Peace River and its aquatic communities. This would establish a stance that strengthens

confidence and credibility support of confidence and credibility in the EIS. It is also the reality that

drives the project components concerned with mitigation, residual effects, and cumulative effects.



EIS Review Comments



12.4 256

Evaluating the significance of fish community changes - Comparisons of Peace River fish faunas

with Site C reservoir faunas were made primarily from the perspective of community biomass.

Concern: The method of evaluating significance is based on evaluation at the community biomass

level, rather than at the species level. The grouping of fish species can be misleading and it can

mask species specific effects. Increases in fish biomass are not equivalent to increases in

harvestable fish biomass. The species and proportions that are harvested depend on a number of

other factors such as, availability, catchability, regulatory regimes, angler preferences, etc.

Significant changes in relative and actual species composition should be considered as well, this is

not captured by using total biomass as an indicator.

It is unclear how a biomass-based significance criterion will capture the goals in the provincial

Conservation Framework that pertain to species diversity and conservation.

Using biomass as a criterion does not necessarily meet the goal of long-term recreational

opportunities. If a large portion of the biomass is non-game species, this will have adverse effects

on recreational opportunities.

Discussion of outcomes could have been presented more clearly. As presently written, some

reviewers were confused with the presentation of species group responses within which most of

the group response could have been accounted for by a subset of species.

Comment continued in next Cell



EIS Review Comments



256

Comment Continued from previous Cell


(a) Present the predicted biomass outcomes of species groups more clearly, including an

explanation of whether the biomass measure represents a relatively small number of large sized

individuals or the equivalent weight of larger numbers of small sized fish.

(b) Evaluate the projected changes in regional faunas at a more detailed level of resolution i.e., for

individual species, to the extent that sufficient reliable data are available. At the very least focal

species should be evaluated individually.

Example: There is a projected 45-80% decrease in burbot, lake trout, rainbow trout, walleye, and

northern pike, which assumed would be counteracted by a 1.8-1.9 fold increase in arctic grayling,

mountain whitefish, and bull trout (page 12-47, lines 9 – 17). This appears to be contradicted by the

sentence further down that bull trout and Arctic grayling are expected to decline.

Increases in the grayling/ mountain whitefish/bull trout group (Group 2) would reflect a decline in

Arctic grayling and bull trout, and an increase in mountain whitefish. However, this is represented

as an overall increase in Group 2 fish (i.e. an implied positive effect).

Note also, mountain whitefish aren’t nearly as desirable as a sport fish so the impact of this change

on fishing values may be negative.



EIS Review Comments



12.4 257

Reservoir littoral and limnetic habitat development - Overall, habitat conditions that would be

created in the reservoir, including limnetic productivity, remain quite uncertain as noted in the

following issues:

(i) The projected success of lakeshore littoral habitat development, the habitat value of large rip

rap, and the establishment of a productive reservoir fish fauna may be more uncertain than stated

by the proponent due to the assumptions used.

(ii) The text suggests that reservoir spawning and rearing habitats are created merely by the

flooding of land. This requires major assumptions. Just as there aren’t spawning and rearing

habitats everywhere there’s water, those habitats won’t be created everywhere in the flooded

zone. Many other characteristics, such as substrate, water velocities, cover, etc. will determine

where these habitats will be.

(iii) The extent of littoral habitats in the reservoir may be exaggerated, since the low productivity in

the upper 20 km of the reservoir does not seem to have been accounted for. This may mean that a

large proportion of the littoral habitat (i.e. < 6 m deep) occurs in a reach that is relatively

unproductive due to the continued effects of cold and variable outflows from the Peace Canyon.

(iv) It is not correct to state that aquatic vegetation has established itself in Dinosaur Reservoir, in

fact, a great deal of time and money has been spent to try and create habitats that support

submerged vegetation. Two of the main reasons why it has not worked are water level fluctuations

and heavy sedimentation rates. In this statement sedimentation is being characterized as

promoting vegetation growth, and its subsequent role as fish habitat.




EIS Review Comments



257

Comment Continued from Previous Cell

(v) Appendix P. GIS analysis of changes in habitat area addresses habitat loss due to inundation, but

does not talk about variation in different habitat types due to daily and seasonal variation in water

flow. Also, the EIS states that loss of fluvial habitat types (low area) is balanced against gain of

lacustrine habitat types (extremely high area) but does not provide a justification for this

conclusion.

Concern: Assessment of comparative impacts to specific fish habitats should be valued based on

something [example?] other than gain and loss of area.


(a) Provide a functional description of reservoir littoral fish habitat along with the attributes as

they relate to specific species and life-stages, in order to help evaluate future habitats,

(b) Expand the explanations/rationale on the balance of river habitat amounts/quality lost due to

inundation with the amounts and expected quality of littoral and limnetic habitats of the future

reservoir. Are fluvial habitat types (low area) of equal habitat value to lacustrine habitat types

(extremely high area)? Should they be valued based on something other than on a square-km basis?

Comment Continued in Next cell



EIS Review Comments



257


(c) Provide an analysis of the following:

(i) how much area is dried during low flow downstream of the Site C reservoir; and

(ii) how much area is dried up during low flow upstream of the dam?

(d) Provide more discussion on the degree of uncertainty of future littoral habitat quality and

quantity.

Additional Details:

12-34, lines 28 and 43: It is mentioned that several stages of construction will provide “additional

fish habitat” when water levels increase; however, a description of the habitat relative to the

species and life stages that would be present to use it is not offered.

12-35, 4-8: The limnetic area is defined as areas where water is < 6 m deep; however not all

shallow, limnetic habitat is created equal. Also the loss of terrestrial habitats was not considered.

The text also implies a net gain in habitat resulting from the creation of the reservoir; however, it is

really only a net gain in wetted area, not necessarily fish habitat, or more importantly productive

epilimnetic habitat. The loss side of the habitat conversion equation seems to omit the loss of

mainstem river habitat, but the gain side appears to include the limnetic area (from which the old

river habitat was a part). The extent, nutrient and thermal characteristics of the epilimnion is also

not provided. This area is fundamental to aquatic productivity including fisheries productivity.



EIS Review Comments



12.4 258

Habitat fragmentation and its potential consequences - The creation of site C dam and reservoir

may lead to the resultant habitats being split into 4 or more ‘zones’ (upper reservoir, main

reservoir, Site C to Pine River confluence, Pine River confluence to the provincial border).

Concern: Although post-project habitats are arguably contiguous (except for passage issues at the

dam), their different characteristics may lead to population fragmentation.


Include an assessment of potential for population fragmentation as a result of dam construction

and the creation of the reservoir.

Examples:

(i) Populations residing downstream of the Pine River confluence (i.e., cool water lotic fauna) will

be isolated and distinct from those in the reservoir (warmer lentic habitat). The area downstream

of the Peace Canyon dam may continue to show low productivity.

(ii) The reach immediately downstream of the proposed Site C dam will likely show decreased

productivity similar to the current state downstream of the Peace Canyon Dam (which include

bedrock conditions for 7 km, cold water in summer, low fish productivity, dominated by larger fish,

recruitment largely based on entrainment).



EIS Review Comments



12.4 259

Aquatic primary and secondary production and review of modeling - Levels of uncertainty

associated with assessments of impact on fish and fish habitat have been inadequately reported in

the EIS. The following are examples of uncertainties in the assessment:

• Projected “increases in aquatic productivity” are uncertain. In spite of the modelling summary

that suggests the reservoir will be more productive than the river, these projections appear to be

doubtful considering the literature compiled in Volume 2, Appendix P, Part 3. Fish species which

can respond to the changes in productivity will dominate in the future.

• Interactions between temperature and productivity generate uncertainty about future reservoir

productivity. While the loss of river habitat is clearly identified, this is suggested to be offset by

greater productivity in the newly created reservoir. Fairly high flushing rate of the reservoir may

limit such productivity. The upper 20 km of the reservoir will continue to be cold and unproductive

due to the continued influence of Peace Canyon outflows. As a result. This may also affect

expectations about the resultant littoral areas. Expected habitat quality of littoral areas may be

overly optimistic.

• Periphyton was poorly estimated by stepwise multiple regression (bad analysis to perform). Flow

variation was a stated variable in both regressions of periphyton and phytoplankton, but the

temporal scale of this variation not mentioned. Periphyton not well explained by using particle size

and flow. Models of benthos biomass and richness were used to predict conditions after Site C:

periphyton wasn’t predicted, due to poor predictive ability.

• Question arises whether data from 2 years are sufficient to model future conditions. Were there

large perturbations in the data to provide power for such predictions? Was the time-scale of flow

variation relevant for the daily vs. seasonal flow variation to be expected?




EIS Review Comments



259

Comment Continued

•Models for both benthos and periphyton and predictions do not account for the influence of

underlying productivity, which will not vary much over the two years of data. Since productivity

(particularly N and P) will change following construction, it is nearly impossible to say what benthic

and periphyton production rates will be, so it seems future predictions are speculative at best.

• Benthos richness and bio-volume were reasonably well explained – mostly by distance from the

dam (stream order arguments), flow variation and depth. Little discussion presented on how this

creates complex spatial patterns; i.e., immediately downstream of the Site C dam, there will be

extremely low benthos abundance, causing complex patterns in higher trophic levels (impacts on

capacity to support fish). This will have implications for the ecosystem, but also for the fisheries

that are supported by them (which are based in Fort St John, very close to the dam).

Uncertainty is acknowledged in the EIS; however, for habitat impacts of this magnitude require

greater attention to levels of certainty.


(a) Revisit modeling efforts for predicting future changes in primary and secondary production in

the reservoir and downstream of the Site C dam to respond to questions about analytical approach,

data characteristics, and related questions posed here which all have implications for the validity

and/or level of certainty around predicted outcomes.

Comment Continued on next Box



EIS Review Comments



259

Comment Continued

(b) Provide a response to the following questions about methods:

(i) How normal were the data following transformation? Normality tests are prone to errors when

sample sizes are low. Could a plot be shown to indicate that data are normalized?

(ii) Variables used in the regression include variation in flow, etc. On what time-scale is this

variation measured… weekly, monthly, seasonal or hourly? All time-scales are relevant and may

influence predictions.

Additional Details:

• 12-35, 22-25: As mentioned here, the initial increase in productivity will diminish over time until

an equilibrium is met. This equilibrium will likely have a lower level of productivity as is typical with

a reservoir. None of the literature reviewed in Appendix P, Part 3 had reservoir data sets that

showed an increase in primary productivity, following formation. Sedimentation and high flushing

rate appear to be dominant factors in suppressing production, and Site C’s reservoir will have the

additional factors of cold water and two upstream reservoirs to trap nutrients. IMHO, this cold, run

of the river reservoir will not produce significant phytoplankton nor periphyton, with low numbers

of cladoceran zooplankton. Information suggesting there will be sufficient stratification in the

reservoir to support epilimnetic productivity was not apparent.

• Calibration of phytoplankton and periphyton abundance showed a poor match to seasonal

variations observed in Dinosaur reservoir. This suggests that the predictive ability for production in

the newly formed reservoir is low.




EIS Review Comments



259

Comment Continued

• The reservoir is predicted to show thermal structure in the summer, however, calibrations based

on Dinosaur reservoir showed limitations in the ability to predict water temperatures during the

period that thermal stratification was forming (June and early July). This could have impacts when

coupled with a fairly short productive summer season. Additionally, the two models used to predict

water temperatures predicted temperatures that repeatedly differed by about 5°C. Since the

reservoir thermal structure would also affect factors such as nutrient retention, this contributes to

broader uncertainty regarding the resultant productivity in reservoir habitats.

• App P3, 5.1.1.1: Model development. Trends in benthic and periphyton biomass

analyzed by multiple regression (backwards stepping) where data were log10(x+1) transformed.

The more appropriate analysis would have been a GLM using a zero-inflated Poisson distribution.

There are many problems with using step-wise analyses like the one proposed which may influence

results. Similarly, the zeros in the data may have some mechanistic trends which may also influence

results (but were not accounted for).

• Overall, estimates for all trophic levels don’t account for daily variation in water flow, other than

experiments to see how species richness and biomass was affected by dewatering in Appendix P).

Not accounting for daily variation in water flow may lead to under-estimates or over-estimates of

biomass and mortality.



EIS Review Comments



12.4 260

Aquatic primary and secondary production and review of modeling - CE-QUAL Estimates of

Periphyton and Phytoplankton are that periphyton biomass will increase ~4% downstream of dam,

but this area has high flows during the day.

Concern: An examination of how dewatering affects biomass and richness is provided in Appendix

P, but this information does not appear to be incorporated into the main analysis. The EIS states

that the data used for the models apply only to areas that will be continuously wetted. This does

not take into account possible loss due to dewatering.


(a) Clarify if a 4% reduction in means that during the night, significant areas may be dewatered,

resulting in drying/death of periphyton.

(b) Clarify if the potential for dewatering and drying/death of periphyton is accounted for in the

assessment

(c) Include an examination of how dewatering affects biomass and richness as part of the main

analysis.



EIS Review Comments



12.4 261

Fish species and population responses – Reservoir - More details are sought regarding inputs and

uncertainties related to analyses of fish species and population responses in the reservoir:

• 12-30, 11: One key aspect potentially changed by the project is loss of life history types (or

biodiversity) from some fish species, but this outcome is not mentioned specifically. Perhaps it is

part of genetic diversity (12-31, 4).

• Within the reservoir, while fish will continue to be present the resultant fish community is

uncertain. For example, the establishment of a planktivorous species is probable (possibly only

maintained by entrainment); however, whether this species is lake whitefish or Kokanee does not

appear to be certain.

• In general, there is substantial uncertainty regarding the resultant community that will establish in

the reservoir, as well as the extent (magnitude and spatial extent) of downstream impacts. While

this is reflected at some points in the document, at other locations increased certainty is implied

which may present an overly positive outlook. Will Kokanee or lake whitefish be the dominant

planktivore in the reservoir? Will northern pikeminnow be the dominant predator? These

questions cannot be answered with certainty, but have important influences on how

desirable/acceptable fish community changes are.

• Reservoir productivity biases: While fish biomass may increase in the reservoir, this increase may

be primarily the result of entrained Kokanee. If so, this may mask actual negative effects on

reservoir productivity and its impact on intrinsic fish production.

• Reservoir operations: Although the reservoir is expected to maintain a fairly stable water

elevation, the water license will allow for some variation in water elevation. For example, in

summer this could have a strong effect on reservoir thermal structure and reservoir productivity. It

could also affect entrainment.



EIS Review Comments



261

Comment Continued

• Utility of Ecopath mass balance models to estimate changes in Peace River fish biomass and food

webs: Rationale not provided.

Harvest rates were assumed to be the same before and after Site C dam construction. Given that

there is a whole EIS section on harvest, reasonable estimates could have been made regarding

harvest rates for each species in each river section (upstream and downstream of the dam).

• They find biomass and harvest of planktivorous fish (whitefish and kokanee) will increase in the

reservoir following construction, and continue to increase, but this is entirely based on their

assumption of increasing biomass of these fish in Williston. There is substantial uncertainty around

that assumption and should be acknowledged. All other harvests go down, but this is partially

masked by increase in planktivorous fish

• Balancing the model:

• A good job done in rationalizing all changes to best guesses for biomass, etc. for each group which

were needed to balance the model.

• Ecopath models of future food webs were based on predicted phytoplankton and periphyton

biomasses from the CE-QUAL model, which was quite bad at estimating upstream production and

not based on changing nutrient conditions.

• Changes in whitefish and kokanee data were based on trends over the last several decades (4

points in total) and observations from other systems. This seems weak, but they did specifically

model different scenarios.

• It is unclear why walleye and northern pike are expected to increase. Spawning and nursery areas

for both of these species will likely decrease in a reservoir environment.



EIS Review Comments



261

Comment Continued

• It is unclear why it is concluded that Arctic grayling and bull trout would extend their distribution

downstream in the project area. Bull trout at least, are there now.

• Northern pikeminnow is not a sport fish species. If northern pikeminnow becomes the dominant

predator in the reservoir there will be significant impacts to the fish fauna and recreational

use/harvest.

Uncertainty is acknowledged in the EIS; however, changes to habitat and fish community of this

magnitude require greater attention to levels of certainty.


(a) Evaluate the effects of reservoir water level variations on thermal profile, reservoir productivity,

and entrainment.

(b) Discuss the potential contribution of entrained fish versus intrinsic Site C reservoir productivity.

(c) List the multiple assumptions embedded within the EIS and identify appropriate actions if

assumptions are invalid (e.g. based on monitoring or other information).

(d) Explicitly discuss the use and purpose of Ecopath model, and all key assumptions embedded

within it which control model outcomes, and which contribute to uncertainty.

(e) Provide more clarity on outcomes in the reservoir and its tributaries for species such as walleye,

northern pike, Arctic grayling, and bull trout.

(f) Here, and elsewhere, “show the work” behind analyses forecasting future outcomes, at least

briefly in summary form. A more open discussion of how outcomes were derived would increase

the level of confidence around modeled outcomes, or at least provide proper context and levels of

uncertainty around them.



EIS Review Comments



261

Comment Continued

Additional Details:

• Bull trout, as one example, have numerous life-history types and several have been lost from

populations in Alberta due to riverine developments. Many of the fish species in the project area

have several life-history types documented (see McPhail 2007).

• Kokanee entrainment may have strong effects on the fish community in the resultant reservoir.

However, continued entrainment from Williston Reservoir was simply assumed, and this

assumption was not evaluated; i.e., will entrainment rates be high enough to support a kokanee

population to be the dominant pelagic species?

• Estimates of kokanee growth and size would be helpful to understand the future population. If

established, this population might have individual too small to interest anglers.

• Overall harvest in the reservoir is assumed to increase, but excluding whitefish and kokanee,

harvests actually decrease. Kokanee populations are assumed to increase based on very little data

from Williston Lake showing possible population increases.


261

Comment Continued

6. The need for an Ecopath model of the system following construction is not explained except that

the guidelines require an estimate of the ecosystem. There may be minor changes to parameters

and state variables in order to ensure the model balances, but the utility of this is questionable. It

basically shows what you put in to the model, rather than providing any insights (apart from being

able to visually see the relationships; i.e., building a food web diagram). Some rationale is provided

in Table 6.2, but not explicitly stated in the text. Even the table lists benefits over passage models,

but don’t rationalize using Ecopath rather than just displaying the inputs used (which is largely all

that Ecopath was used for).



EIS Review Comments



12.4 262

Fish species and population responses – Tributaries - More details are sought related to the inputs

and uncertainties related to analyses of fish species and population responses in tributaries:

1. The future outcomes for some of the single species models can be questioned based on certain

input values and model assumptions.

2. There seems to be very little consideration on the impacts to fish and fish habitat in the flooded

areas of the LAA tributaries above the dam site. There is the potential to have significant impacts in

these areas depending on the current use of these areas for tributary species (e.g., Could the

flooded area in the Halfway impact Arctic grayling overwintering habitat?).

3. Consideration should be given to potential impacts on post-project tributary populations on the

potential for the reservoir to be a “population sink” due to predation of species originating in the

tributaries (e.g., Arctic grayling).

4. Uncertainty about the future of ecologically important areas such as tributary junctions in the

LAA.

Concern: More detailed explanation and discussion of issues related to inputs and the derivation of

outcomes would increase the level of confidence around modeled outcomes, or at least provide

proper context and levels of uncertainty around them. Information on predation risks to tributary

populations would provide beneficial additional context to the uncertainties for species such as

Arctic grayling.



EIS Review Comments



262

Comment Continued


(a) “Show the work” behind analyses forecasting future species outcomes, at least in summary

form. This includes:

(i) an explanation of model input data pertaining to life histories that appear to be well outside of

natural ranges; and

(ii) a more open discussion of how outcomes were derived.

(b) Provide information on possible life-history-related impacts on post-Project tributary

populations, such as Arctic grayling, due to predation by reservoir species.

Additional Details:

• Predicted population productivity for bull trout is driven partly from presumed 83% bull trout egg-

to-fry survival rates (based on a single study with eggs contained within perforated steel cylinders),

and density independent growth and survival of juveniles.

• 2 12-95, 7: The statement that tributary, or fluvial, Grayling populations can provide recruits to

the reservoir (Peace mainstem) to maintain populations misses the likely outcome that the Peace

mainstem will become a sink for tributary populations as these recruits will likely never return from

the mainstem (predation northern pike minnow, and possibly by burbot, northern pike, walleye,

etc).

• 3It is an assumption that the current and important staging areas for bull trout in the LAA such as

at the mouth of the Halfway River (recognized by the establishment of a no-fishing zone for a radius

of 5 km.), will persist in the reservoir environment.



EIS Review Comments



12.4 262

Fish species and population responses – Downstream of Site C - Biological outcomes are still quite

uncertain. The key issue with regard to assessment of downstream habitats in the EIS is that flow

fluctuations on fish were not addressed. Habitat inundation effects were only considered upstream

of the Pine at one location. Attention to both impact categories is therefore deficient.

The spatial variability in benthic production is mentioned only in the summary and how between

the Site C dam and the Pine River there are virtually no opportunities for invertebrate production.

The implication is that this area will be largely devoid of invertebrates, and therefore, consumer fish

species.

No fish community sampling was performed at the Site C dam location.

Transition between the coldwater and coolwater species assemblages creates a unique fish

community. It is thought that reservoir development will move this transition zone downstream,

however impediment to fish passage could significantly alter the makeup of the cold water species

assemblage which will impact the community in the downstream transition zone.

The relative importance of the Pine River in the post-dam scenario will greatly increase in its role of

flow attenuation and access to fish habitat away from the Peace River mainstem. This should be

highlighted because the degree to which fish species will be able to utilize the Pine assumes no

significant changes in the Pine River in the post-dam period.

Continued in next cell



EIS Review Comments



262

Comment Continued

Concern: Downstream habitat impacts have not been sufficiently addressed. Impacts both

upstream and downstream of the Pine River confluence have received limited attention. Also the

possibility of habitats downstream of the dam becoming less productive (similar to current habitat

downstream of Peace Canyon Dam) has not been sufficiently addressed. The limited attention to

downstream impacts is a substantial omission.

Uncertainty is acknowledged in the EIS; however, habitat impacts of this magnitude require greater

attention to levels of certainty.


Use available information on fish communities at the location of the proposed dam and

downstream to provide an expanded discussion of post-Project changes to the environment and

fish community at these locations.

12.4 263

Issue: Fish mortality at the Site C dam - Potential for bias resulting in underestimation of fish

mortality.

Concern: A potential bias may exist that affects observations of GBD in fish exposed to total

dissolved gas (TDG) in rivers and reservoirs: dead fish don’t float (pg 12-58, line 20): Mortality is

often underestimated in fish kills as the majority of dead fish may not be found because they sink to

deep waters out of sight and are washed downstream, and struggling fish can be quickly caught by

predators.


Provide information on sources of error associated with estimates of mortality related to the dam

and its operations as part of discussions related to potential future losses of fish at the Site C dam.

Comment Conitnued in Next Cell



EIS Review Comments



263

Comment Continued

Additional Details:

See McCubbing et al. (2005), which documents that only 1% of fish killed in a chemical spill were

collected and enumerated despite widespread efforts.]

Also: McCubbing, D.J.F., C.C. Melville, G. Wilson and M. Foy. 2006. Assessment of the CN sodium

hydroxide spill August 5th, 2005, on the fish populations of the Cheakamus River. Report prepared

for the BC Ministry of Environment, Surrey Regional Office. Final Draft. 123 p.

Note: During at fish kill at Ruskin Dam (Stave River) caused by a TDG event in 2007, anglers

reported seeing dead sculpins, char, and steelhead two days before the event was reported to

officials and biologists responded. The same anglers reported taking home one struggling steelhead

(hatchery fish) they could reach from the shore. This may not have been in the BC hydro report on

the incident, because it was considered anecdotal information. The post-event investigation

discovered the TDG event probably occurred for 2-3 days before it was discovered.



EIS Review Comments



12.4 264

Issue: Impacts to sustainability of fish populations due to entrainment - The report estimates the

rate of entrainment to be low (< 10%) of for all species except for bull trout, kokanee, lake

whitefish, and lake trout (pg 12-60, line 17).

Concern: This statement, reframed, is stating that the rate of entrainment is predicted to exceed

10% for bull trout, kokanee, lake whitefish, and lake trout. A 10% entrainment rate may be

unsustainable for many species. Entrainment is equivalent to mortality if the fish can’t return. For

species which are long lived such levels of entrainment may severely constrain upstream

populations


Describe the long-term implications of predicted entrainment rates on fish species. In particular,

discuss the implications of predicted rates on long-lived species. Include references from the

literature.



EIS Review Comments



12.4 265

Water quality impacts on fish habitat - There are gaps in the assessment of water quality (Vol 2

Section 11) with respect to impact on fish and fish habitat.

Concerns:

(i) Groundwater upwelling is an important environmental factor in bull trout red site selection and

should be considered in the assessment of impacts on bull trout (Sec 11.6.6 pg 11-100).

(ii) Mean peak concentration of Hg was used as an indicator on the assumption that this better

approximates typical human exposure (e.g., eating fish) (Sec 11.9.7 pg 11-167 line 29). This metric

does not indicate the range in Hg levels and does not quantify the distribution of samples around

this mean. There is no discussion of what effects the predicted Hg values could have on the health,

reproduction and behavior of fish species in the Peace River.


Respond to the following questions and concerns related to the impacts of changes in water quality

on fish and fish habitat:

(i) Evaluate the potential impacts and effects to bull trout related to changes in the groundwater

regime. Will the project potentially impact the groundwater regime in surrounding tributaries (eg.

Halfway, Moberly)? What are the implications for bull trout?

(ii) Report on the range and distribution of predicted Hg concentrations associated with the mean

peak concentrations reported in Section 11.9.7.

Describe the effects that predicted Hg values could have on fish health and behavior in the Peace

River. What is the % population (by species) with concentrations that may result in behavioral or

reproductive impacts?



EIS Review Comments



12.5 266

Issue: A substantial proportion of the discussion around mitigation measures for fish and fish

habitat refers to mitigation in the future as dictated by project outcomes and “when feasible,

where practical, when economically feasible or as possible”. This approach makes it difficult to

evaluate mitigation due to the lack of clarity around these conditions.

Concern:

The suggested level of mitigation for the completed project appears inadequate. (see below

comments for further details)

12.5 267

Issue: Monitoring programs are proposed to evaluate assumed outcomes post-Project but not pre-

Project.

Concern: While post-project effectiveness monitoring is welcomed, the challenge with such an

approach is it defers risk of non-compliance until after the Project is built (i.e., after a non-reversible

decision has been made) and also puts unclear limitations on addressing any residual effects (i.e.,

linked to economical and technical feasibility).


(a) Undertake detailed planning and implementation of mitigation and monitoring prior to Project

construction.



EIS Review Comments



12.5 268

Issue: There appears to be an overall approach in the EIS which assumes that the negative effects

(e.g., loss of river fish habitats) are offset by proposed gains (e.g., reservoir productivity).

Concern: The suitability of such an approach is low because it does not represent a like-for-like

replacement. Uncertainty in the achievement of proposed positive effects also limits the suitability

of such an approach.


(b) Provide a detailed rationale, supported by literature sources, to support the EIS assumption

that the negative effects (e.g., loss of river fish habitats) will be offset by proposed gains (e.g.,

reservoir productivity).

12.5 269

Issue: Concern that fish habitat and/ or environmental compensation as a result of the project

might detrimentally affect essential operation and maintenance requirements along the highway

corridor.


(a) Clarify that essential operation and maintenance requirements along the highway corridor will

not be detrimentally affected by the addition of fish habitat and/or environmental compensation as

a result of the project.

(b) Consider off-site compensation and aggregating, where possible, where required so that the

resulting compensation is more biologically productive and can be further removed from the

transportation corridor.



EIS Review Comments



12.5 270

Issue: Concern about future responsibilities associated with post-construction compensation

monitoring on MoT lands and RoWs as well as any repairs and modifications to that compensation

to ensure functionality over the long-term.


(c) Clarify that any long-term post-construction compensation monitoring requirements resulting

from the project that impact, or are located on MoT lands or RoWs, will be the responsibility of BC

Hydro, as will any future repairs/modifications to that compensation which may be required by

environmental agencies to ensure functionality.

(d) Clarify that fish-bearing stream crossings affected by the realignment of Highway 29 that are

found to be barriers to fish passage, shall have fish passage restored. This includes new stream

crossing installations and all installations shall ensure fish passage is maintained under flow

conditions when fish would be migrating for all fish species and life stages present.



EIS Review Comments



12.5 271

Operations phase – Reservoir - Broadly, the development of a reservoir fish fauna is the

mitigation measure proposed for the loss of river conditions in the LAA. The predicted success of

this is partly founded on the proponent’s previous experiences. A level of uncertainty exists in the

Site C LAA given the potential effects of high through-flows (22-day residence time) on primary and

secondary production supporting fish populations in the future reservoir.

The uncertainty of future habitat structure and fish community composition in the reservoir affects

habitat mitigation options and prevents the evaluation of suitable levels/types of mitigation

measures.

No specific mitigation is proposed in the event of the loss of the migratory Arctic grayling

population in the Moberly River, or migratory bull trout in the Halfway River. The proponent

proposes that mitigation/compensation options await the outcomes of post-project effectiveness

monitoring.

Concern:

The uncertainty in the composition and productivity of the fish fauna limits the identification of

mitigation options at this time. For example, if reservoir kokanee cannot successfully access

suitable spawning sites in the LAA tributaries, kokanee recruitment and populations may have to

depend entirely on entrainment from upstream.

Although the proponent expects the development of littoral habitats in the reservoir to be

successful, post-project effectiveness monitoring will be needed to confirm the level of success.

Continued in Next Cell



EIS Review Comments



271

Comment Continued

While this approach may be acceptable under the circumstances, the transfer of risk to regulatory

agencies must be matched by the ability to compensate/mitigate if assumptions are untrue and

outcomes are not achieved. This makes it critical to define terms such as ‘economically and

technically feasible’ as potential constraints on mitigation and compensation measures.


(a) Consider monitoring the success of proposed habitat enhancement structures in littoral areas

and the status of fish populations in the reservoir and tributary to it, including the Halfway River

bull trout and Moberly River Arctic grayling populations

(b) Prepare a mitigation/compensation strategy in the event of negative results.

(c) Consider developing borrow pit recreational opportunities to offset recreational and harvest

impact losses.

(d) Expand on options to further improve reservoir habitats

Additional Details:

12-66, 35: While river habitat cannot be replaced, there may be options to improve either the

reservoir habitats or downstream river habitats. Such options appear to have been given relatively

limited attention.

P67L4 and 5 Without further details about the extent of contouring and fish enhancement works it

is difficult to evaluate the net effect of these measures.

Mitigation for lost recreational opportunities is possible for borrow pits that are not located within

the littoral zone. As part of the mitigation for recreational and harvest impacts, funding could be

provided to stock or aerate these borrow pits.



EIS Review Comments



12.5 272

Operations phase – Fish passage at Dam -

Opportunities were missed in the design of mitigational fish passages.

(i) It is understood that a substantial effort was undertaken to select the optimal type of dam for

the Site C development in terms of cost, efficiency, and so forth; however, the largest mitigation

opportunity for fish populations in the LAA and RAA was missed in the Site C Dam proposal. Fish

passage options proposed are retrofitted to the dam design. A more fish friendly approach would

have been to design optimal fish passage facilities, then design a dam around it. Different dam

orientations may have improved fish capture efficiency by creating optimal collection points. Fish

approaching a dam from the downstream area often collect at the most upstream point of the dam,

and fish approaching from upstream often collect at the most downstream point of the dam. The

proposed dam crossing the river perpendicular to the streambank, and the powerhouse passing

flows perpendicular to the river flow is probably the most difficult orientation for the retrofit of fish

passage facilities.

(ii) The other largest mitigation opportunity missed was the chosen location of the Site C dam. By

locating the dam only 2 km upstream of the Moberly River, the loss of habitat in the river,

migration obstructions, and introduction of new reservoir fish species (e.g., northern pike) into the

Moberly would have been largely avoided, for a small change in head and storage volume.



EIS Review Comments



272

Comment Continued

Concern: The potential for success for the proposed mitigation for migration blockage at the Site C

dam with the trap-and-haul proposal for bull trout and other migrants is uncertain, and may be low.

Fish passage mitigation assumes a successful trap-and-haul program as well as persistence of

favourable environmental cues that will stimulate bull trout to maintain pre-dam migration

patterns.

The proposal to implement a periodic capture and translocation program for the small-fish fauna

“contingent of the results of research on the genetic exchange requirements of upstream and

downstream populations” appears dubious. Who is committed to doing this research, and when?


(a) Prepare a mitigation strategy in the event of negative results.

(b) Commit to support studies of “genetic exchange requirements” for members of the small-fish

fauna.

(c) Evaluate the assumption that movements are unimportant to small-sized fish species.

(d) Provide a review of the potential effectiveness of trap-and-haul methods in the context of the

proposed Project. Suggest that the review assume the method is ineffective until proven

otherwise.

(e) Provide the Fish Passage Management Plan for review.



EIS Review Comments



272

Comment Continued

Additional Details:

• 12-71, 5: An additional consideration for mitigating fish entrainment is positioning the intakes

deeper in the water column. This should entrain fewer fish which are often surface oriented.

• 12-65,L9: Several reviewers disagree that movement is not an issue for small fish. This is an

assumption that should be evaluated further. Small fish in general require greater attention.

• 12-72, 12: Studies of the genetic exchange requirements for small-fish species would have been

useful to have within the EIS. However, failing that they are important to include within the

ongoing monitoring work.

• The incomplete knowledge on the current role and importance of migrants in sustaining fish

species distributed on both sides of the Site C dam location may confound the trap-and-haul

strategy. Because an individual of a species (e.g., bull trout) shows up at the base of the dam does

not necessarily imply that the individual was a migrant intent on reaching the mainstem of the

Peace in the LAA and its tributaries. Moving this individual upstream may be a effort and cost

wasted.

12-71,30: We have little experience with trap-and-haul in BC. It is employed on the Columbia River

with salmon. Further review of its potential effectiveness in this case may be required. One

approach within the review may be to assume that it is ineffective, until proven otherwise.



EIS Review Comments



12.5 273

Operations phase – Peace River downstream of Site C dam - Near-shore habitat/side channel

enhancements downstream of the Site C dam have the potential for success, but post-project

effectiveness monitoring will be required for confirmation.

Concern: The success of near-shore habitat/side channel enhancements may be counteracted by

the low levels of benthic productivity anticipated downstream of the dam and trophic level impacts

on the fish community.


(a) Prepare a mitigation strategy in the event of negative results. Considerations should include:

(i) How will shear zones and point bars be constructed to be effective under variable flow

levels/conditions. What will make them good fish habitat? (pg 12-66, line 18; pg 27-28).

(ii) Stated bounds for compensation options which are currently undefined but conditional on what

is “technically and economically feasible” (pg 12-67, line 17).

Additional Details:

Further mitigation should be included (i.e., for impacts downstream of the Pine River confluence).



EIS Review Comments



12.6 274

Residual Effects on individual fish populations - The following populations were recognized in the

EIS as being vulnerable to significant impacts and populations that would be potentially lost.

However, reviewers question the estimates regarding the likelihood of loss.

• Moberly River Arctic grayling

• Halfway River bull trout

• Mountain Whitefish in the LAA

Concern: There is a concern that the EIS underestimates the likelihood of loss of some fish

populations. For example, reviewers disagree that the probability of losing the migratory Halfway

River bull trout is Low (page 95 line 23). This seems like an overly positive assessment. This species

may face >10% mortality due to entrainment, which could have substantial effects over the longer

term. Also all entrainment represents a loss to the upstream population (without upstream

passage for which effectiveness has been proven). The effectiveness of trap-and-haul is unproven,

so their migration to areas upstream of the dam could be lost or reduced substantially.


Consider preparing a contingency mitigation plan early in the process post-approval to proactively

address the potential loss of these fish stocks.



EIS Review Comments



12.6 275

Effects on fish populations downstream of the Pine River - Residual but unaddressed habitat

impacts from the Pine River to the BC border and beyond. Reviewers are unconvinced that habitat

impacts would be limited to areas upstream of the Pine River. These effects may also depend on

season and the relative flow in the Pine and Peace rivers.

Concern: Reviewers agree with the statement (12-48, 33-36) that the extent of the change on all

fish populations downstream of the Pine River would be based primarily on the degree to which

Pine River and other tributary inputs (i.e., Beatton River, Kiskatinaw River, Clear River, and Pouce

Coupe River) would attenuate the flow and thermal and ice regime as a result of the operations of

the Project. However, the uncertainty regarding the resultant downstream aquatic fauna appears

to have received a low level of attention in the EIS.

In a number of cases, the mitigation of impacts appears to be largely focused on areas upstream of

the Pine River confluence. Such a geographically restricted area may not be justified. Impacts will

likely extend further downstream than the Pine confluence and there is a need for greater

assessment /mitigation attention for those areas.

An elevated level of attention to habitat downstream of the Site C dam is recommended




EIS Review Comments



275

Comment Continued


(a) Revisit estimates of the likelihood of loss of

(i) Moberly River Arctic grayling,

(ii) Halfway River bull trout and (iii) Mountain Whitefish throughout the LAA. Consider trends in

these populations in their regional context (including the effect of existing dams) and uncertainties

related to data and analyses and proposed fish mitigation measures (as described in previous

comments).

(b) Consider preparing a contingency mitigation plan early in the process post-approval to

proactively address the potential loss of these fish stocks.

Additional Details:

12-58, 31: Stranding in some localized areas downstream of Site C could be frequent and therefore

of concern. 2D habitat modeling shows that impacts would occur downstream to near the border

(and possibly beyond). However, impacts are only addressed downstream to the Pine River

confluence. Mitigation is possible to avoid mortality. What isn’t addressed however, is the lost

productivity due to the flow fluctuations.

12-42, 40: This project represents an increase in the daily flow variation for habitats downstream

of Site C. This is a negative impact. The report appears to take the position that impacts

downstream of the Pine are so limited that they do not need to be addressed or compensated for.

Further review of supporting documentation indicates this is not accurate.



EIS Review Comments



12.6 276

Estimate of species effects of multiple developments - The assessment lacks contextual

information on existing developments in the RAA. As an example, the development of the entire

Peace River drainage upstream of the Peace Canyon Dam has had a major impact on populations of

Arctic grayling in the region but this not included as a consideration.

Also, the description of Previous Developments (s 11.1.2.2 Aquatic Resources) provides a broad

overview of impacts on fish communities without discussing individual species.

Concern: The addition of the Site C development has the potential to lose migrant Arctic graying in

the Moberly River. This represents a regional cumulative effect of multiple developments. This

concern might be applied to other fish species as well.


(a) Clarify how aquatic ecosystem alterations linked to historic hydro-electric developments and

associated impacts on fish species were included in the baseline and how / if this was this factored

into assessing residual effects on fish species in the context of regional-level impacts to fish species

and populations such as Peace River Arctic grayling. A number of impact categories should be

examined such as long-term water temperature alterations, a shift from predominantly benthic to

pelagic-based food webs, and barriers to upstream movement of fish.

(b) Provide a more detailed description of impacts to individual fish species as a result of previous

developments in Section 11.1.2.2.

12 1 4277

P1L4 should indicate that habitat will be affected, use of potentially contradicts the report’s findings

and is misleading.

12 4 1

278

P4L1 It would be useful to verify whether items excluded from this table based on a score <2 are

reasonable to exclude. The brief explanation of items scored <2 suggests most are likely reasonable

to exclude, but verification would be useful.

12 16 Table

12.7279

P16Table 12.7 It isn’t clear how to interpret blanks (e.g. w.r.t. recruitment source)



EIS Review Comments



12 18 Table

12.8

280

P18 Table 12.8 Table is a useful summary, however, there is a lot of detail left out, particularly with

regard to movements. For example:

Bull trout – Movements from the Halfway to Pine and the mainstem have been detected, but

aren’t reflected here. Given entrainment and lack of upstream passage, fish engaging in this

movement pattern will likely be lost from areas u/s of the dam. Resident and migratory groups in

the Halfway are stated as distinct, but should clarify what this is based on.

Lake whitefish – this pattern is very interesting and suggests the localized spatial structure suggest

possible genetic. This should be verified/refuted. If there is any amount of distinction between

tributaries associated groups this may be lost when the reservoir is formed (but maintained d/s).

Mountain whitefish – similar to lake whitefish, but less potential for distinction.

Yellow perch – will likely not be present upstream of the dam. While we may not consider this a

focal species, potential impacts such as this should still be mentioned. The identification of focal

species doesn’t mean that all others should be ignored when impacts can be reasonably predicted.

Suckers – they appear widespread. Future work might be considered to evaluation assumptions of

a) population heterogeneity b) impacts in the reservoir area in particular.

Northern Pike – not a focal species, but one that we need more information on. Further

information needs for this species could be considered in a monitoring plan

12 30Table

12.10281

P30 Table 12.10 I think further attention should be given to all these reports, and each should be

thoroughly reviewed by at least one person.

12 39 9 282P39L9 This sentence is confusing. Does it mean that there will be a general increase, but walleye

are expected to decline?



EIS Review Comments



12 46 6 283P46L6 The basis for this statement is unclear to me. Not likely critical, but could be clarified.

12 62 1 284P62L1 further review of Gulliver (2012) would be useful, but has not been done due to time

constraints.

12 67 19 - 20 285

P67L19-20. This sentence is misleading. With regard to seasonal pattern it is correct, but it is

misleading with regard to daily pattern since changes will occur. Also impacts will extend beyond

the Pine, and as such the limitation of the report focus to areas upstream of the Pine confluence is

not justified. Both the spatial extent and the severity of this impact are misrepresented.

12 71 4 286P71L4 The term "practical" should be defined in some manner.

12 82 16 287Is RAA missing from the Geographical Extent criteria?

12 all 288Pages are indicated from 1 to 105 and lines for the start of text relevant to the comment (e.g.

format is P1L1 for line 1 on page 1)

12 all 289

General – the reports format is generally good, but not great. In particular the limited use of sub-

headings and left justifying nearly all text makes it hard to discriminate breaks between sections,

lists etc.

12.8 96 14 290Wrong table reference, should read 12.26.

12.4.2.1 39 12-Oct 291Confusing and contradicting statement. Are walleye expected to increase or decrease?

12.6.2 12-86 17 292

Using biomass as a criterion does not necessarily meet the goal of long-term recreational

opportunities. If a large portion of the biomass is non-game species, this will have adverse effects

on recreational opportunities. This should be reflected in the EIS



EIS Review Comments



App P s2.2 293

Williston and Dinosaur Reservoirs

The section discussing the relative abundance of different species in the two reservoirs is difficult to

follow. The text bounces between talking about absolute abundance and relative changes. Please

discuss how absolute abundances changed over time.

App P s2.2 294

Williston and Dinosaur Reservoirs

The EIS seems to say bull trout and kokanee are most important in Williston, and lake trout and

kokanee are most important in Dinosaur, but then states that findings are similar and they base Site

C results on this – confusing

App P3 295

a) This report should be cited as follows:

ESSA, Limnotek, and Golder 2012. Future Aquatic Conditions in the Peace River. Site C Clean Energy

Project, BC Hydro. Environmental Impact Assessment. Volume 2 Appendix P Aquatic Productivity

Reports, Part 3 Future Aquatic Conditions in the Peace River. Prepared for BC Hydro. October 10,

2012. 131 p. + 6 app.

7, 8 1; 44 296

It is stated in the Guideline document (pg23) that “Data collection methods, models and studies

shall be documented so that the analyses are transparent and reproducible.” However, regarding

“Data Collection Methods,” there appear to be no specifics in the main document that would allow

“reproducible” data collection for Fish and Fish Habitat.

Ix, 63,

2011 - 2 297

“Abbreviations and Acronyms”

The acronyms here do appear to be from Provincial Guidelines for Fish Inventory species codes,

however, two of the acronyms are incorrect with consistency to the provincial guidelines. EIS

Document has: “WP - Yellow perch; YP – Walleye”. These should be: YP - Yellow perch; WP –

Walleye. Mistake is on pages ix, 63, 201

Section 13 - Vegetation and Ecological Communities

Ecological Communities



EIS Review Comments



13 298

Selection and Description of VCs - Ecological Communities

Issue: VCs include at-risk ecological communities, sensitive ecosystems and rare ecological

features, including CF Goal 2 Priority 1 and 2 ecosystems. This represents a fairly comprehensive list

of those ecosystems that may be impacted.

The exception to this is the definition of ‘old growth’ as a sensitive ecosystem. This landscape is

characterized by frequent natural disturbance which limits old growth. As a result, it would be more

reasonable to assess the distribution of structural stages across ecosystems in comparison to the

Range of Natural Variation rather than simply look at ‘old growth’.

Concern: If "old growth" distribution is assessed by itself, the potential impacts to VC's maybe

underestimated due to the frequency of natural disturbance.

Details: Table 3 of Tech Rep. #59 (Delong 2011; see Reference) indicates range of distribution of

age classes which, when linked to ‘successional’ stages, provides a basis of natural (historical)

distribution of all seral stages related to First Nations interests. A comparison of these categories

to the distribution of structural stages over the Project area would provide a more robust measure

of effects and direction for mitigation.

Reference: DeLong, 2011 Tech Report #59.

http://www.for.gov.bc.ca/hfd/pubs/Docs/Tr/Tr059.htm

Request that the Proponent: Provide an

assessment of the existing distribution of structural stages across ecosystems in comparison to the

Range of Natural Variation rather than simply looking at ‘old growth’. Recommend using the

natural distribution of seral stages described in Delong 2011.



EIS Review Comments



13 299

Selection of VCs - Ecological Communities

Issue: Not all of the Candidate Valued Components have been selected for the Valued

Components Assessment and a rationale for the selection of VCs is not provided. Some unique

ecosystems (noted in EIS Guidelines item) have not been defined or described with respect to range

extensions of rare ecological communities. For example, an alkaline community type (Puccinellia

nuttalliana – Hordeum jubatum) identified at Watson Slough is not reported on in the list of

Ecological Communities at Risk. This ecosystem is red-listed in BC and if new inventory locates the

ecosystem in a different area, it is still an ecological community at risk that should be reported and

assessed. Concern: Omitting to include

rare or sensitive ecological communities in the assessment may result in an underestimate of

impacts.

Request to the Proponent:

(a) Identify and describe all rare and sensitive ecological communities in the LAA and RAA based on

surveys and a review of the literature. (b)

Provide a rationale for the VCs selected and not selected to be included the assessment.

(c) Include the alkaline community type Puccinellia nuttalliana – Hordeum jubatum as a VC in the

assessment.



EIS Review Comments



13 300

Description of VCs - Ecological Communities

Issue: The distribution of sampling effort for surveys of sensitive ecological communities and rare

plants number is not described in detail. Also Appendix R: Preface: p. I of XII: Scope: baseline data:

focus of additional work was restricted to additional rare plant survey only. What was rationale for

exclusion of other species and of rare ecosystems?

Concern: It appears that fewer surveys were conducted on the south side of the Peace River. If

that is the case, sensitive ecological communities and rare plants in that area may not be

adequately described.


(a) Provide a map showing the distribution of sample locations and discuss the design and rigour of

their sampling program. Include clarification of how the types of plant communities sampled along

the transmission line constitute a random sample (S13.3 lines 1-2).

(b) Provide a rationale for some locations receiving less survey effort and discuss the implications

of gaps in coverage (e.g., on the south side of the Peace River), including the identification of rare

plant communities and potential effects of the access roads and transmission line.

(c) Provide a rationale for restricting additional surveys to rare plants and not including rare

ecosystems.



EIS Review Comments



13 301


Issue: it is noted in Appendix R Section 1.1.1.1 that some of the ecosystems found by ecosystem

mappers in the Peace Valley did not correspond well to the descriptions found in the regional

guide. As described, some of the more common ecosystems, as suggested by the field guide, were

actually uncommon on the steep side slopes of the valley and that some of rare units, as noted by

the field guide, but were very common in the valley bottom. Likewise, Appendix R: Table 1.1.1

reports new and non-correlated map units that were not considered as potentially being

ecosystems.

Concern: These ecosystems are similar to discoveries of new plant or animal species during the

course of a baseline inventory. They should be considered as “unique ecosystems” from the study

area, until additional inventory proves otherwise. These findings suggest that the ecological

communities of the Peace River Valley are somewhat unique within the BWBSmw and the

surrounding landscape. More information and data regarding residual effects on rare ecosystems is

warranted in the landscape context. Continued in next box



EIS Review Comments



301

Continued


(a) Clarify the following points:

(i) Were the issues and solutions adopted discussed with provincial experts to ensure consistency

both within the region and across the Province? (ii)

Are the descriptions provided for ecological communities at risk generic for British Columbia, or

specific to the Peace Valley? Did any of the ecological communities at risk, other than those only

known to occur in the Peace River valley, possess characteristics unique to the area?

(iii) What does the term ‘unique ecosystems’ mean in terms of an indicator for the

Vegetation/Ecological Community VC? Is this related to these new and non-correlated map units?

(iv) Were considerations of regionally uniqueness incorporated into the assessment of impacts and

residual effects? If not, what are the implications of not including these as unique ecosystems in

the assessment?

(b) Describe the extent of these communities in their regional and provincial context to determining

impacts and effects prior to development.

(c) Consider treating new and non-correlated map units as ecosystems unique and potentially new

to science for the purposes of planning, management, avoidance, mitigation and compensation

until inventory proves otherwise.



EIS Review Comments



13 302


Issue: The discussion of the relationship of site series and ecological communities is somewhat

simplified. Where site series are formally correlated to plant associations that are equivalent to the

ecological community, early successional status is generally the only reason to not identify the site

series as equivalent to the ecological community unless field sampling proves that the map unit is

incorrect.

Concern: Site series are only identifiable when linked to a Biogeoclimatic Unit (zone/subzone or

zone/subzone/variant). Site series numbers alone are meaningless in terms of relaying information

about a specific site series or the ecological community type it represents. Grouping site series

numbers without the Biogeoclimatic unit cannot be a way of determining area of occupancy of

ecosystem types. If this was done it is a big methodological error that will need to be corrected.

Additional Details: Biogeoclimatic (BGC) zones represent the combined area of related regional

climates (e.g. subzones). BGC units do not themselves represent species habitat. Regional climates

(subzones) are sometimes distinguished by further climatic variation as variants of the subzone and

each subzone or subzone/variant combination includes a zonal ecosystem that represents the

regional climate where the vegetation community is not influenced by local topo-edaphic

conditions, terrain, or soil types. All ecosystems identified as site series within each subzone or

subzone/variant must be identified with both the BGC unit and the site series number.

Request that the Proponent: Clarify whether site series numbers without Biogeoclimatic Units in

identifying representation of ecosystem types. If necessary, re-run the analyses correctly linking

site series numbers to the relevant Biogeoclimatic Units.



EIS Review Comments



13 303

Description of VCs - Wetlands

Issue: All wetlands have been grouped for assessment into a category of “sedge wetlands”. This

grouping is so broad as to not provide adequate description of whether these wetlands occur on

peat land or mineral soils which would alter the appropriate management or mitigation response.

Concern: There are very distinct wetland types in the LAA. Inappropriate lumping of wetlands

could result in impacts on the different wetland communities being missed. Without

characterization and quantification it is also not possible to know whether mitigation measures are

appropriate. For example, each wetland type performs a different ecological function (as habitat

but also water filtration, flood control, CO2 sinks, etc) and without separation into wetland types,

particular ecological functions might be put at risk.




EIS Review Comments



303

Comment Continued

Additional Details: The following is a description by Provincial Research Ecologist Will MacKenzie of

wetlands in the Project area based on a visit in the spring of 2012:

"The interesting thing about [the Project area] is the suite of types is more reminiscent of the

Chilcotin rather than the rest of the boreal (warmer). Watson slough is a Wm03 (Awned sedge) but

also Woolly Sedge (Wm12) and Bulrush (Wm06). These types then occur higher up in the valley.

Also something like the Baltic rush (Wm07) and Field sedge (Ga03) in some areas (mostly above the

impact area on the slopes. Marsh types

would be relatively easier than other wetlands to recreate in other locations. Some Tamarack -

Water sedge ecosystems (Wb06) occur in the valley bottoms. Probably lots of these in the general

region certainly very common in the boreal in general, these would be difficult to reconstruct. Some

of these ecosystems have been impacted by beaver flooding, which is not an uncommon natural

occurrence. The resulting ecosystems are a hodgepodge of willow swamp and marsh types."


(a) Identify wetlands in the Project area according to the provincial wetland classification scheme

and map the quantity, extent and distribution for each.

(b) Assess impacts, develop mitigation measures , estimate effects for each wetland class (by plant

association) individually.

13 304


Issue: The report seems to be using ecosystems and habitat interchangeably.

Concern: Using the terms ecosystem and habitat interchangeably has potential to miss or

misrepresent habitat for the purpose of assessment

Request that the Proponent: Clarify the definition of these terms and ensure that each is used in

the appropriate context.



EIS Review Comments



13 305


Issue: The BC Conservation Framework (BCCF) is not current with the CDC list of species and

ecological communities at this time and the list of BCCF rankings and the BCCF recommended

Actions may not address all species of conservation concern.

Concern: The BCCF provides Actions for recovering species and ecosystems at risk. A number of

ecosystems identified in the Peace River valley are "new" so don't have actions for recovery.

Request that the Proponent: Consider BCCF rankings and recommended Actions in the context of

current CDC listings and "new" (as-yet unlisted) ecosystems identified in the Project area. Also

applies to mitigation measures (see below).



EIS Review Comments



13 306


Issue: The methodology for baseline mapping (Broad Habitat Mapping) of ecosystems in the RAA

(and part of LAA) contains a number of technical inconsistencies with provincial mapping standards

and accuracy assessment guidelines. Data from one scale was re-interpreted at a finer scale (1:50K

biophysical data was used to populate 1:20K VRI polygons) and a spatial shift applied resulting in

polygons with potentially incorrect attributes. A statistically valid accuracy assessment was not

completed and very few habitat types were actually sampled. A comparison of quality and

reliability of the baseline mapping to standard map products is not provided with the EIS.

The current status and distribution of terrestrial ecosystems were described adequately in the area

in which Terrestrial Ecosystem Mapping (TEM) was completed.

Concern: Baseline mapping is one of the fundamental data layers for the assessment. The quality

of this map layer influences subsequent interpretations such as the accuracy of habitat maps for

wildlife and the area calculations of all of the ecological communities and area by structural stage.

There may be inadequate information on the distribution and condition of terrestrial ecosystems in

the RAA to reasonably identify significance of loss associated with development. Specific concerns

include: (i) Since the

methods are non-standard and untested it is particularly important that the documentation

includes a reasonable comparison to more standard methods vis-à-vis quality and reliability.



EIS Review Comments



306

Comment Continued

(ii) The “pre-processing of the biophysical habitat information”, as described on page 18 (App R S

1.1.2) 8, is essentially altering the original intent of the biophysical data. The attributes of each

biophysical polygon were photo interpreted by an ecologist, so to “slightly shift the lines to better

match the VRI polygons” potentially results in polygons with incorrect attributes; and

(iii) There may be issues with the methods used for Accuracy Assessment (see comment below).


(a) Clarify in detail the methodology used to create the baseline ecosystem mapping. Methods

need to be presented as transparent and repeatable. Include a description of:(i) mapping

methods; (ii) accuracy assessment methods and values; (iii) an explanation of the spatial shift (How

significant was this? How did it affect the product?); and (iv) a summary of the differences between

the use of the biophysical air-photo-interpreted and VRI lines, with an explanation of how the

differences in linework were mitigated.

(b) Describe how the thematic and spatial accuracy of the Broad Habitat Mapping (BHM) is the

same or different than TEM re thematic and spatial accuracy.

(c) Clarify the vintage of air photos on which Broad Habitat Mapping was based (mid 80s to early

90s) as well as the dates of current airphotos. Were they current to 2012?

(d) Clarify whether “pre-processing of the biophysical habitat information” was completed prior to

converting the biophysical data to a raster format; and

(e) Consider submitting the full complement of mapping data to provincial government staff for

review. Access to this data, would provide clarity with respect to the methods used and allow for a

much more comprehensive review.



EIS Review Comments



13 307


Questions re Broad Habitat Mapping:

1. Please clarify the following statement from Vol. 2, Appendix R, Part 1, pp20 “The 07-SH and $07-

SH:ac units had the poorest accuracy at 35% and the 05-SO unit had relatively poor accuracy at

43%. There was a common error related to differentiating the 04-BL and the 08-BT; these units are

located adjacent to each other on the edatopic grid and this error may have contributed to the high

number of acceptable classifications for non-seral forested units in Table 1.1.6” Does this mean

that of only the 07 and $07 plots the proportion correct or acceptable only tallied 35% and 43%

respectively?

2. A rational for why the 04 and 08 were more difficult to differentiate is presented here but there

is no rational for the low accuracy of the 07 and $07 units. Is there any rational for this and if so,

what is it? Tree species composition from VRI is sited next as a confounding factor for seral unit

accuracy. The use of structural stage from VRI can be challenging for certain applications.




EIS Review Comments



307

Continued

3. In the same paragraph from Vol. 2, Appendix R, Part 1, pp20 accuracy is referred to as both

70.4% and 69%. Table 1.1.6 shows from where 70.4% is derived (" “The overall broad habitat map

accuracy calculated from the 2010 field plots was 70.4%") but there is no reference to 69% in the

text. Most mapping accuracy projects focus on forested site series as the non-forested units are

generally easier to differentiate. The accuracy of broad habitat mapping forested

units—69%—exceeds the minimum requirement of 65% for mapping projects and wildlife habitat

modeling (Meidinger 2000). Which value is it?

4. It is noted that 2673 polygons were visited in the TEM LAA (equal to 37% visitation) but only 283

polygons were checked for bioterrain? Why were so few polygons assessed from a bioterrain

perspective? Was a terrain specialist involved in most of the ecosystem plot data collection? If not,

both the bioterrain and ecosystem mapping should be critically reviewed, as should the plot data.



EIS Review Comments



13 308


Issue: There are a number of questions and concerns related to the Accuracy Assessment (AA) of

the Broad Habitat Mapping: (i)

The AA appears to be sampled in a targeted, non-random fashion resulting in biased results. It is

noted in Vol 2 App R Section 1.1.2 that certain ecosystem units were not sampled and others were

targeted. (ii) The map

accuracy values noted in this report are statistically invalid. It also assumed that the AA outlined in

the report was completed by the mapper? This is non-standard. A statistically valid accuracy

assessment (as outlined in the Accuracy Assessment Protocol, Meidinger 2000) is supposed to be

conducted by an independent third-party and use randomly selected polygons from the entire map

area. The data generated from the AA is supposed to be kept independent from the map data.

(iii) The accuracy assessment only reported out on the first leading decile instead of all deciles.

Structural stage information should be summarized across all three deciles rather than only the first

decile. Certain structural stages associated with sensitive ecosystems may not be the most

prevalent on the landscape and thus maybe under represented if assessed using a first decile

approach.


308

Comment Continued


(a) Provide a rationale for why the accuracy assessment for the biophysical mapping only reports on

the first leading decile instead of the entire value. How might reporting to the first leading decile

affect the overall analysis?

(b) There is mention of quality assurance completed by third party ecology and bioterrain

specialists (Vol 2 App R S 1.1.1.1 Pg 15). Who did this QA? How much of the mapping was reviewed

and at what stage? What were the findings? Is there a QA report?

(c) Was the sampling method for the AA consistent with standard protocols? Was the sampling non-

random? If so, please describe how sampling sites were selected and the implications of a non-

random sampling method on the assessment of accuracy.



EIS Review Comments



13 309


Issue: The current status, distribution and significance of terrestrial ecosystems were not described

adequately in areas covered by the Broad Habitat Mapping (BHM). These mapping products do not

provide sufficiently reliable mapping to locate occurrences of ecological communities, specific

wetlands, etc. and can only be used as a broad roll-up of areal extent, e.g. timber harvesting

allocation. The BHM would also not be particularly suited for identifying areas of compensation

without additional field inventory.

The current status and distribution of terrestrial ecosystems were described adequately in the area

in which Terrestrial Ecosystem Mapping (TEM) was completed.

Concern: CDC does not map occurrences from Predictive Ecosystem Mapping (PEM) products as

the reliability and sampling have proven to be insufficient for specific location information. CDC

also has not used PEM products to determine area of occupancy of small patch rare ecological

communities for status ranking factor of rarity. However, TEM products are used but are always

reviewed for confidence level and sometimes resampled. For areas outside of the LAA (and some

of the recently added LAA which is BHM, not TEM, accuracy of quantifying area lost is subject to

considerable error of omission and commission within an EIA project




EIS Review Comments



309

Continued


(a) Clarify the limitations and uncertainties associated with the Broad Habitat Mapping when

reporting on estimates of areas of terrestrial ecosystems impacted by Project development.

(b) Explain how differences in the quality and accuracy of the two ecosystem map layers (BHM and

TEM) were reconciled in reporting areas of ecological communities.

(c) How might differences between BHM and TEM affect the subsequent interpretations re habitat

value as well as area of representation of ecological communities?

(c) Consider field verifying sites such small patch rare ecological communities for size and location.



EIS Review Comments



13 310

Assessment of Impacts - Ecological communities

Issue: The EIS characterizes the post-dam hydrology but does not provide an assessment of effects

to ecological communities resulting from changes to the hydrologic regime and water table post-

inundation.

Concern: There may be significant impacts to plant communities that are currently located on a

mesic site but that become located on a sub-hydric site post-inundation. The EIS notes the real

impact to zonal plant communities are result of flooding but the overall impact may be even higher

once changes to hydrology adjacent to the inundated area are taken into account (see Details). For

example, there are likely to be far-reaching effects on plant communities sited on old fluvial fans.

Also, wetlands may be particularly impacted by a change in hydrologic regime post-inundation. For

example, new wetlands may form along the sides of the reservoir where groundwater level rises to

the surface, which would result in a significant ecosystem change in the area.

Additional Details: The following is a description by Provincial Research Ecologist Will MacKenzie of

cottonwood stands in the Project area based on a visit in the spring of 2012:

"The cottonwood stands along the mainstem [of the Peace River] are largely in a state of decline

due to the changing flood regime (they never have surface flooding anymore). The understory is

converting from the normal mid bench understory to an upland suite of species. Some flood release

management might be able to create new cottonwood stands or refurbish older stands (maybe, this

would take a huge release - last year's "highest in 20 years" flood levels did not lead to surface

flooding of the existing stands)."




EIS Review Comments



310

Continued


a) Clarify the potential impact of changed hydrology post-inundation on plant communities within

a 5% slope (gently to non-sloping sites) that are now coincident with the new water table. Include a

comparison of the spatial extent of existing plant communities and future projected communities

when one includes both inundation and changed hydrology.

(b) Assess impacts to wetlands that may are likely to result from changes in the hydrology of areas

on the fringe of the reservoir post-inundation and in areas affected by the post-dam water table.

(c) Clarify whether there is a strategy to deal with the newly emerging wetlands along the banks of

the reservoir.



EIS Review Comments



13 311

Assessment of Impacts - Old forests

Issue: The EIS describes plans to remove 'merchantable' trees in the riparian, leaving

unmerchantable trees as a mitigation measure (Table 13.15 on pg 13-13). The impacts of the

removal of large, old trees from the riparian buffer was not assessed.

Concern: Blue-listed old and mature riparian and floodplain forests will be reduced in provincial

representation as a result of this Project and the EIS estimates an overall loss/degradation of nearly

> 40% of the riparian habitat. The planned removal of large old trees in riparian areas will

contribute to further reductions in representation of riparian and floodplain forests. There are also

other impacts likely from the removal of riparian vegetation. For example, the removal of any

vegetation in the riparian buffer zone will increase the risk of erosion in these sensitive areas. Also,

removing the merchantable trees reduces potential for recruitment of future old growth riparian

ecosystems.

Request that the Proponent: (a)

Clarify to what area the proposed removal of merchantable trees applies. Is the intent to clear

vegetation immediately before filling the reservoir or will it be retained throughout operations?

(b) Provide an assessment of the implications to rare and sensitive ecological communities of the

removal of merchantable timber from riparian areas.

(c) If riparian vegetation is to be retained throughout operations, consider retaining merchantable

trees, especially large poplar and aspen, in the 15 m riparian buffer to aid in the regeneration of the

riparian forest that has high value to wildlife.



EIS Review Comments



13 312


Issue: The EIS does not provide a full landscape context in which to assess impacts to ecological

communities. The Project Active Zone occurs in a unique valley-bottom environment. Impacts

should not just be assessed in direct impact zone; Impacts need to be reported in the context of

what is available in the larger area.

Concern: The overall significance of effects may be underestimated if impacts to ecological

communities are assessed without consideration of ecosystem abundance and condition in the

RAA. For example, the percentages noted for rare communities lost in the BWBSmw are

meaningless if only stating relative to what is present in the LAA. What if these areas represent the

only occurrence of these communities in the BWBSmw? Or, what if these communities exist

elsewhere in a protected area or in an area slated for development as well? Likewise, it is not

possible to identify whether the seven tufa seeps that are to be destroyed, or negatively impacted,

are the only seven tufa seeps in the entire RAA, or if they commonly occur throughout the region.




EIS Review Comments



312

Comment Continued from Previous cell


(a) Provide an analysis of representation of ecosystem units in a regional context. Of the 60

different ecosystem units found in the LAA, how well represented are each of these units within a

given Biogeoclimatic (BGC) unit or region? In particular, how common are the valley bottom forest

and riparian wetland types (those with “the largest proportional loss”) within the given BGC unit?

Within the Region? Within the province?

(b) Include an assessment of rare ecological communities lost in the BWBSmw relative to the

region and province. How much riparian forest exists in the BWBSmw? What structural stages are

present and what is the areal extent of each? How does this compare to the range of natural

variation within these riparian forests? How many occurrences of rare plants are present? What is

the area of these occurrences? How common are the types of wetlands found in the BWBSmw? In

the region? To what extent are all of these values captured in the protected area versus the area to

be developed?



EIS Review Comments



13 313


Issue: The EIS states that there will be sizeable losses of old and mature riparian and floodplain

ecosystems in the LAA, however these ecosystems will persist downstream of the reservoir" (Pg 13-

39 lines 9 - 13). It would be reasonable to expect that the riparian and floodplain ecosystems

downstream of the planned reservoir will be significantly negatively impacted by altered flow

regime.

Concern: These ecosystems are maintained by their natural flood regime, it is likely that they will

be lost, or significantly degraded, rather than act as remnants of high quality intact forest.


Assess the probable loss of rare and sensitive ecosystems due to impacts downstream of the

proposed dam. Please include (i) a quantification of the type or amount of riparian ecological

communities (e.g. Fm02) that may be lost or significantly degraded by the downstream flow

regulations; and (ii) include the existing impacts of the Peace Canyon Dam and the W.A.C Bennett

dam on equivalent ecosystems as part of the regional context.



EIS Review Comments



13 314


Issue: The EIS lacks a comprehensive assessment of impacts due to loss of ecological function.

There is a section assigned to discussing impacts on Ecological Function, however this section

appears to only focus on the species at risk that may be associated with these ecosystems, rather

than the more comprehensive topic of ecosystem function as a whole.

Concern: Analysis of the impacts of the predicted levels of ecosystem loss on the function of

ecosystems is critical to determining impacts of this Project.

Request that the Proponent: Provide an assessment of impacts due to loss of ecological function

that include a thorough summary of the impacts of ecosystem loss on ecosystem functioning

beyond the impacts on individual specie and assesses impacts on hydrology; impacts on wetland

function and longevity; and impacts on stand structure and resilience.



EIS Review Comments



13 315

Assessment of Impacts - Ecological Communities

Issue: The EIS states (Vol 2 Pg 13-27 Table 13.15): “If there is limited or no existing data to help

facilitate avoidance measures, then supplemental pre-construction surveys will be conducted.”

There should not be any gaps in the data if the inventories have been completed as suggested by

this report.

Concern: Assessment of impacts and effects may be underestimated if there are gaps in the

inventory of ecological communities.


(a) Clarify the level of confidence provided by existing mapping of ecological communities and

whether additional surveys are likely to be needed prior to construction.

(b) Explain how gaps in data might affect the estimates in the EIS of area of ecosystems and

number of plant occurrences directly impacted.

13 316

Assessment of Impacts - Ecological Communities

Issue: The EIS states (Vol 2 Pg 13-32 Table 13.15): “Prior to work commencing, surveys will be

conducted to identify invasive species populations”

Concern: An inventory of the extent of invasive species should be a factor in the assessment of

ecological communities and rare plant species status.


(a) Clarify whether an inventory of invasive species has been completed to date and this data

included in the baseline assessment of the status of ecological communities and rare plant species.

(b) If this was not included, please explain the implications of not factoring in the existing extent of

invasive species in the assessment of the status of ecological communities and rare plant species.



EIS Review Comments



13 317


Issue: In Section Vol. 2, S13.3 Effects Assessment, it is stated:" Vegetation and ecological

communities and rare plant populations in the LAA adjacent to any Project components may still be

changed through edge effects associated with fragmentation, spread of invasive species, or changes

in hydrology, but the exact spatial extent of any change is difficult to quantify. A qualitative

assessment of changes in the condition of a community and rare plants due to these stresses –

including long-term maintenance of the transmission line right-of-way – is considered". In looking at

Vol. 2 Appendix R, part 2, 2.11, Terrestrial Ecosystems (pp 84-85), fragmentation and edge effect

are discussed but only in context of increased edge due to added roading (Table 2.11.8).

Concern: Information on edge effects should be presented in the EIS to provide a more

comprehensive sense of true impact.

Request that the Proponent: Clarify if there are GIS data for total edge effect within the PAZ that

includes all project components as stated in S13.3. If this data exist, please present it in the EIS.



EIS Review Comments



13 318

Mitigation Measures - Ecological Communities

Issue: The proposed mitigation does not specifically address the issue of climate change and

associated impacts on vegetation or ecological communities. The impacts could be both positive

and negative and will vary by individual species and ecosystem.

Concern: In several instances, the EIS describes mitigation effectiveness as “Effective – these are

standard measures that have been applied successfully in the past”. However, there is a high

degree of uncertainty about whether past engineering practices will be effective with respect to

climate change impacts. Likewise, the effectiveness of management / restoration practices for

vegetation and ecological communities may be reduced in the future under climate change.

Climate change impacts are likely to alter hydro-geomorphological processes over the proposed

100 yr life span of the dam.

Request that the Proponent: Consider incorporating climate change adaptation techniques in early

project stages to increase resilience over the long-term. For example: The mitigation measure to

“Retain vegetation on steep unstable slopes that would be highly susceptible to landslides if the

vegetation as removed” (Vol 5 Pg 38-6). Given the climate scenarios and projects for changes in

precipitation and slope instability, it might be prudent to incorporate additional conservative

measures on slope angle as an adaptation technique when determining which areas need to be

revegetated.



EIS Review Comments



13 319


Issue: Details concerning mitigation and monitoring are not sufficient to determine accuracy of

assessment of residual effects and determinations of significance. The EIS refers to environmental

management plans for details of mitigation, but the plans do not contain details or make clear links

between impacts and mitigation requirements. There are essentially no specific actions in the table

of mitigation measures to address the condition or loss of Ecological Communities at risk or

Sensitive ecosystems. What is proposed for mitigation is unlikely to be entirely effective, as

acknowledged in the assessment.

Concern: Specific consideration needs to be given to address the loss or reduced condition of at-risk

or sensitive ecological communities. A net loss of terrestrial ecosystems is a net loss of habitat to a

variety of wildlife species and a potential increase in the level of conservation concern of both

plants and animal species within the area of impact. Mitigation measures that are unlikely to be

effective should not be used to reduce estimates of residual effect. Considerations:

(i) Very few mitigation measures are proposed for terrestrial ecosystems as most are directly lost

due to flooding of the reservoir or construction of the dam. The one exception to this is the Wilder

Creek mitigation plan which could provide some mitigation. However, Wilder Creek will only

provide mitigation of a very small proportion of the habitat that is being lost. For example,

approximately 12 hectares of wetland habitat will be created to replace the approximately 675 ha

of wetland that will be lost to this project.



EIS Review Comments



319

Comment Continued

(ii) Translocation is not possible for ecological communities (plant species, yes, plant communities

no) and is not feasible to include as a mitigation measure.

(iii) BC Conservation Framework (CF) Actions are indicated for plant species but there is no

equivalent compensation recommendation for ecological communities e.g., several of the listed

ecological communities recommend monitoring action.


(a) Clarify intentions to compensate for direct loss of terrestrial ecosystems due to inundation or

other aspects of development. Will there be an attempt to compensate so that there is no net loss

of ecosystems where possible e.g., by restoration activities or conservation of other occurrences of

same/similar ecological communities or sensitive ecosystems.

(b) Provide scientific evidence of the effectiveness of translocation of ecological communities in

other locations. If this does not exist, please remove translocation as a mitigation measure.

(c) Include Conservation Framework (CF) Actions for ecological communities in mitigation and

monitoring plans and list in the details of technical reporting in Appendix R.

(d) Table 13.15 states that “Disturbed sites will be planted quickly with ground cover, shrubs or

trees that are regionally appropriate...”. Please clarify what is meant by “quickly”. Also

recommend clarifying in the text that "all vegetation will be replaced with native vegetation and

localized seed stock".

(e) Engage provincial government staff when developing detailed mitigation plans.



EIS Review Comments



13 320


Considerations re mitigation and monitoring:

(i) Timing and avoidance measures need to be developed as a condition of permitting.

(ii) Relevant management plans (e.g., Soil Management, Site Restoration and Re-Vegetation Plan;

Vegetation and Invasive Plant Management Plan, Operational Vegetation Management Plan) should

be completed in consultation with interested agencies, First Nations, and the public.

(iii) Consider identifying environmental protection zones for ecological communities at risk or non-

wetland sensitive ecosystems. (iv)

Retain tree roots (including merchantable timber) within riparian buffers to forestall erosion.

(v) Mitigation measures forImpacts on sensitive sites should take into account how

common/uncommon these communities are both inside and outside the LAA/RAA.




EIS Review Comments



320

Comment Continued from previous cell

(vi) Consider using the baseline information as a tool for monitoring the status of

(1) rare plant occurrences and ecological communities left intact or partially intact

(2) habitat changes over time

(3) ecological community species composition, e.g. spread of invasives or spp shifts due to changes

in site conditions (wetter sites). Recommend setting up permanent sample plots with climate

stations to monitor change from pre-development to post-completion.

(vii) Recommend that further consideration be given to avoiding Project activities, or using

intensive mitigation measures, in the following areas:

• Portage Mountain – This proposed quarry area provides habitat for Siberian polypody and

hibernating bats. The rare plant is not known to occur elsewhere in the LAA, while bat hibernacula

are important habitat features and their preservation a priority.

• Watson’s Slough – This wetland supports numerous rare plants, and a range of wildlife, including

the listed western toad and Yellow Rail. BC Recommend the consideration of alternative avoidance

and mitigation measures

13 321


Issue: There is little to no detail on follow-up plans around commitments on monitoring (methods,

field testable objectives, timing, frequency, duration) or contingency/adaptive management per

requirements of 23.5 in the EIS Guidelines.

Concern: A robust monitoring plan is needed to monitor the effectiveness of mitigation measures

over time. Government staff require access to data to effectively design and evaluate monitoring

outcomes.

Request that the Proponent: Engage in a data-sharing protocol with the Province that would allow

the provincial government to manage the data and have it accessible for use in monitoring the

effectiveness of mitigation measures.



EIS Review Comments



13 322

Mitigation Measures - Wetlands

Issue: The creation of new wetlands is mentioned throughout the EIS to address compensation for

a number of taxa, but there is no detail on what types of wetlands are going to be created (e.g,.

marshes, bogs, fens) and what species these will be created for. The EIS only refers to fish-free or

fish present wetlands.

Concern: Some characteristics of wetlands can take decades to centuries to replicate and there is

no detail in how this will be expidited or how it will be attempted.

Request that the Proponent: If the Project is approved, work with provincial government staff to

develop a detailed mitigation plan for wetlands that considers the types of wetlands and habitats

impacted and opportunities to create new wetlands of different types. Include consideration of

different wetland functions (species habitat, water filtration, flood control, CO2 sinks, etc.).



EIS Review Comments



13 323


Issue: Tufa seeps have been identified as a rare and senstive ecosystem unique to the Project area.

Tufa seeps provide highly specific habitat that support a number of rare and possibly endemic

species. The are an ecosystem of high conservation concern with respect to this Project. Most of

these communities will be lost in the Project footprint.The two remaining are in vulnerable

locations (e.g., along the proposed transmission line). Also a rare marl fen at Watson Slough will be

lost.

Concern: Conservation of tufa seep and other rare ecosystems requires a detailed inventory to

locate other occurrences of these ecosystems at least in all of the Ecosections that overlap the RAA.

They are too small to be picked up by TEM or PEM mapping.


Develop a management plan prior to construction to avoid and, where avoidance is not possible,

mitigate impacts to tufa seeps.

(b) Clarify whether an attempt has been made to find other tufa seeps in the RAA and environs or

will the Project impact all of the known tufa seep habitat.

(c) Clarify all Project-related activities that have potential to impact the tufa seep on the proposed

transmission line and describe measures to avoid impacts to this ecosystem. Request that the tufa

seep on the transmission line be avoided entirely and its hydrology maintained.



EIS Review Comments



13 324


Issue: The EIS states that “Reclamation and restoration activities for post-construction would alter

community structure” (page and line).

Concern: There is no information in the EIS document or other documents regarding actual

restoration for particular rare plant communities. This sounds like only reclamation.

Request that the Proponent: Clarify whether it intends to restore or reclaim rare plant

communities.



EIS Review Comments



13 325


Issue: In Vol 2 Appendix C, Section 1.2, At-risk and Sensitive Ecological Communities, it is stated

that OGMA’s are designated as Sensitive Ecological Communities. It is also noted that 4 Landscape

Units (LU’s) within the LAA encompass 1275 ha of legal OGMA’s. Under the Forest and Range

Practices Act these OGMA’s are stipulated in the Forest Stewardship Plans of forest licensees with

Major Licences to Cut and form the basis for their meeting old growth biodiversity targets set out

under the Provincial Old Growth Biodiversity Order. However, the values for the proportion of

OGMA area in the PAZ that would expect to be lost due to operations and construction do not

appear to be present and nor does any discussion on how the land status relationship between BC

Hydro, Ministry of Forests Lands and Natural Resource Operations and forest licensees is being

dealt with.

Concern: There appears to be no mention in the EIS of actual impact to OGMA’s nor how loss of

OGMA’s will be compensated for.


(a) Clarify whether the impact to designated OGMAs has been assessed as part of the EIS and

whether there are plans to compensate for loss of OGMAs.

(b) If there are mitigation strategies to address loss of OGMA area from the crown landbase, please

make this information available for reviewers and the public.



EIS Review Comments



13 326


Issue: As the majority of wood utilization/disposal is anticipated to occur early in the project,

within the reservoir activity zone, how will natural re-vegetation be dealt with?

Concern: Re-vegetation could be a year-round/seasonal attractant to wildlife prior to reservoir

infilling.


(a) Clarify intent with respect to natural re-vegetation prior to reservoir infilling?

(b) Consider revegetating to minimize attractants to wildlife.



EIS Review Comments



13 327

Estimate of Residual Effects - Ecological Communities

Issue: Not all of the residual effects to ecological communities are summarized 18-24. Further,

there has been no association between what the loss of these terrestrial ecosystems means in the

greater context of healthy environmental conditions.

For example, loss of 44% of the 09/Fm02 ecosystem will result in loss of one of the most

structurally complex ecosystems on this landscape. We can anticipate significant impacts on

wildlife species as a result of this (e.g. fisher, marten, bats, and other cavity nesting species).

Furthermore the loss of 675 ha of wetland has not been associated with impacts on ecological

function (i.e. maintenance of water quality).

Concern: The ‘high level’ nature in which the residual impacts to terrestrial ecosystem are

presented makes it impractical to evaluate the accuracy of the statements provided. Also, some of

the assumptions are questionable. For example, it is unlikely that many of the terrestrial ecosystem

impacts will be reversible over time, when a large proportion of the impacts are under the Project

Activity Zone. Likewise, given the nature of these impacts, it is difficult to image many of these

terrestrial ecosystems having high resilience.


(a) Report on residual effects by individual ecological communities, including separate reporting of

effects on Tufa seeps, different wetlands and other at-risk ecological communities. Question the

assumption of reversibility. Tufa seeps should be identified and summarized separately not

combined with wetlands and rare plants.

(b) Re-evaluate the assumptions used in assessing residual effects such as the reversibility of

impacts on ecological communities, based on existing literature and monitoring outcomes from

other similar developments.



EIS Review Comments



13 328

Estimate of Residual Effects - Ecological Communities

Issue: The effects assessment, as outlined in this section, appears to be focussed solely on the loss,

fragmentation and disturbance within the LAA. It does not make any reference to these effects

relative to the current and/or historical representation of these ecological communities within the

valley, BGC unit, Ecosection, region, etc. The assessment would be improved with a quantification

of similar habitat/terrestrial ecosystems that were lost below the Dinosaur and Williston reservoirs.

Most of these projects would have also collected baseline data, so it should be known whether or

not they impacted spp and ecosystems similar to those impacted by the Project.

Concern: If an ecosystem is likely to be destroyed or severely impacted there is a need to identify

the impacts on the ecosystem in the context of the area that has already been destroyed through

previous development. The cumulative loss of these ecosystems can be substantial. For example,

44% of the 09/Fm02 ecosystem type from the LAA is expected to be lost during Site C, whereas we

might already have lost up to 50% of that original habitat under the previous two reservoirs, and

can expect further losses downstream of Site C reservoir. The data to do this analysis is available

through the ecosystem modelling project that was completed for the Williston reservoir (modelling

pre-inundation habitats) in 2006.

Comment continued in next cell



EIS Review Comments



328



(a) Report on residual effects to individual rare or unique ecosystems(re.g., tufa seeps, old forest

and alluvial floodplains), in the context of historic distribution.

(b) Provide additional baseline information regarding pre-dam distribution and extent of

ecosystems.

(c) Provide a more detailed description of impacts to ecological communities as a result of previous

developments in Section 11.1.2.2

Rare Plants



EIS Review Comments



13 329

Selection of VCs - Rare plants

Issue: The Proponent has mostly assessed the appropriate suite of values. Results are provided for

vascular, moss and lichen plant species and some species new to science not yet described.

However, a number of rare plant species were identified during surveys of the proposed Project

area in 2008 that are not included in the EIS. A number of these species are proposed for listing

with CDC but are not yet listed.

(i) Packera plattensis and Scolochloa festucacea were found in the LAA (CDC received in Jan 2012);.

(ii) Previously-undescribed species of vascular plants listed in 2008: Carex sp. nov (cf atherodes

and tenera), Cystopteris sp. nov., Epilobium sp. nov., Muhlenbergia sp. nov., and Viola renifolia var.

nov.

(iii) Sphagnum contortum is a Blue-listed species;

(iv) Two macrolichens, Fulgensia subbracteata and Xanthoparmelia camtchadalis that are found

nowhere else in BC and would thus be ranked as Red-listed by the CDC (in progress);

(v) 9 microlichens, e.g., Acarospora terricola, which are not listed by BCMOE (CDC only tracks

macrolichens at this time) but worthy of noting because they are likely candidates for BC lists and

even national COSEWIC lists (i.e., Buellia elegans). It is only a lack of capacity at the CDC prevents

them from listing them provincially; and

(vi) Two undescribed species of mosses.

Epilobium leptocarpum was found in 2008 but is in the process of being yellow-listed so need not

be added.


(a) Include all of the species mentioned above as rare plants in the assessment (with the exception

of Epilobium leptocarpum).

(b) Clarify the steps taken to date to identify and process these species. For example, have

specimens been deposited in a recognized herbarium (e.g., at UBC) and if so, how many specimens

of each were deposited?



EIS Review Comments



13 330


Issue: Little bluestem is probably not the most at risk example to focus on for the assessment (it is

also known from southeastern BC). The specimens for Chyrsosplenium iowense have recently been

reviewed and there are only 3 good collections (Tupper Ck, Beatton R, and the LAA). Along with

Artemisa herriotii (Western Mugwort) these are probably the most impacted by this project with a

loss of 1/3 of known sites.

Concern: The determination of significance does not mention effects to two of the potentially most

impacted rare plant species.


Incorporate Chyrsosplenium iowense and Artemisa herriotii into the species account and

determination of significance (contact [email protected]).

Details: Western mugwort will probably be the most impacted BC-listed entity (likely be uplisted if

the Project proceeds). The EIS states that “it should be noted that the taxonomy of western

mugwort is uncertain” (Appendix R pg 346). Curtis Bjork pointed out the misnaming of our material

as A. longifolia and the correct name as A. herriotii in 2011. The challenge is that some of the

standard global references do not always cover the regional nuances (for example, an author may

not have reviewed all the material well enough). The Natureserve Global names don’t always match

the CDC names but there is flexibility within the Natureserve system to allow for this until the

standard can be updated. Scoggan is the reference that best fits.



EIS Review Comments



13 331


Issue: Table 13.12: Geum triflorum var. triflorum is not CDC-listed but in 2008, Curtis Bjork

suggested a specimen review which has since been done at UBC and the Royal BC Museum in

Victoria. Since this variety is only known to occur in the Peace River Valley, the loss of occurrences

to construction will likely significantly affect its conservation status rank (CDC rank). CDC will list

this entity in April this year as only few collections are known in BC.

Concern: Limiting the assessment to species that are currently listed by CDC may result in loss of

vulnerable species that have yet to be listed.


Proactively evaluate the potential impact on Geum triflorum var. triflorum given that it is endemic

and its loss will likely significantly affect its conservation (CDC) status rank.

13 332

Description of VCs - Rare plants

Issue: The rare plants that were assessed have been described fairly well (current status,

distribution and significance). There is no definition provided of an occurrence.

Concern: How a plant occurrence is defined has a bearing on its status. CDC defines an occurrence

by a standard 1 km separation distance.

Request that the Proponent: Clarify the definition of a rare plant occurrence used in the

assessment.



EIS Review Comments



13 333


Issue: The Conservation Framework Action Priorities and Groups (bins) are being actively

updated/reviewed and as a result, some of the bins in the EIS are not current. The total number of

CDC vascular plants is not 39 (because some were not listed that were in 2008 list and some should

now be removed because of upcoming CDC downlisting.)

Concern:

The CDC listings of rare plants in the EIS may not be current.


Update description of rare plants based on current listings and taxonomic bins. If ranks are

adjusted to the April 2013 list, ensure that other rank changes are also incorporated. (There should

only be a few that are relevant, plus a few name changes.)

13 334


Issue: The taxonomic bin for Utricularia ochroleuca is not appropriate. There is at least one good

specimen for this species in BC (Liard River hotsprings), but most others are likely misidentified (A.

Ceska, pers. comm. 2013). This species does not need any taxonomic work, but it does need

specimen review and inventory. The species account for Meadow Arnica (Appendix R Section G.2)

notes that "the authoritative Flora of North America did not accept subspecies incana as a

legitimate taxon ... and other botanists working on the Site C project have questioned its validity..."

Concern:

The specimens for the present study may be misidentified and should be sent to an expert for

confirmation.


Send samples of Utricularia ochroleuca and Arnica chamissonis ssp. Incana to an outside expert to

confirm their identity.



EIS Review Comments



13 335

Assessment of impacts - Rare plants.

Issue: Rare plants are lumped together for the purpose of assessment.

Concern: Rare plants require species by species management. Lumping rare plants potentially

masks impacts and results in missed opportunities for species-specific mitigation measures.

Request to the Proponent: Provide separate species by species assessments and mitigation

measures for rare plants.



EIS Review Comments



13 336

Assessment of impacts - Rare plants.

Issue: Impacts on rare plants are understated in the summaries of effects. Volume 2 Sec 13.3.1.2

(pages 13-19) states, “The large majority - 122 – of 142 BCMOE-listed vascular plant occurrences

[that will be impacted] are expected to be lost during construction,” but the Executive Summary

(Page 46) notes that “...occurrences of rare plants would be lost including two red-listed rare plant

species, Drummond’s thistle and little bluestem.” This would be more accurately summarized by

noting that 6 (7?) are red-listed including Drummond’s thistle and little bluestem - rather than

mentioning just two. The summary of loss provided in the residual effects section of Vol 2

Appendix R Part 1 (page 108), at least 35% of occurrences will be lost (85 occurrences in the dam,

reservoir, and quarry sites).

Concern: The way the information is presented, it is difficult to know what the actual effects are

and how they have been interpreted. The magnitude of impacts are underplayed in the Executive

Summary.


(a) Provide a clear link from the assessment of effects to rare plants in Appendix R to the results

reported in the main document.

(b) Clarify whether all Red- and Blue-listed species were considered individually in the assessment

of effects.

(c) Provide an explanation of how the loss of plant occurrences in the dam, reservoir and quarry

sites might impact individual rare plant species at a local and provincial scale.



EIS Review Comments



13 337

Mitigation measures - Rare plants

Issue: The EIS provides few details about mitigation measures for rare plants.

Concern: 122 occurrences of BCMOE-listed plant species are predicted to be impacted during the

construction phase of the Project and another 20 during operations (S13.3.1.2). Efforts should be

made prior to construction to avoid or mitigate anticipated impacts. A robust restoration plan is

needed for vegetation communities and rare plant occurrences.

Request that the Proponent: Develop and implement a Rare Plant Management and Mitigation

Strategy (see Details). It is recommended that planning for restoration of plant communities begin

as soon as possible in anticipation of possible Project approval. This would have the added benefit

of demonstrating a commitment to restoration and monitoring prior to construction.




EIS Review Comments



337

Continued

Details:

(i) Provide a strategy for how each occurrence of rare plant will be dealt with throughout the

Project. Planning should be on a species-by-species basis.

(ii) Consider setting up a nursery in the area, funded by the Project, to support reclamation and

restoration, with a special emphasis on propagation of rare plants.

(iii) Agronomic species are not acceptable for re-seeding.

(iv) Bank seeds and specimens of rare species in recognized institutions and provide sufficient

funds for their curation. Provide support to grow back-up specimens and preserve genetic material

(e.g. long-term cryo-storage of seeds such as through the Millennium Seed Program at Kew Gardens

in Richmond, UK).

(v) Maintain a spatial database of known rare plant occurrences and/ or provide data to the BC

Conservation Data Centre.

(vi) Monitoring post-construction for survival and health of rare plant occurrences should continue

past the 10 years recommended in the EIS.

(vii) Consider funding basic research into the distribution or taxonomy of rare plant species that are

affected by the Project and providing financial support for publication of data on rare plant species

in the Project area.



EIS Review Comments



13 338


Issue: Translocation is proposed as a mitigation measure and described in the EIS as "the removal

of live rare plant individuals or propagules ...from the Project activity zone, and their subsequent re-

establishment at another location" (Sec 13.3.2 og 13-23 line 20).

Concern: The “other locations” for plants or their propogules will need to be compatible habitat to

the plants' location of origin, both in community structure and function or the translocation will fail.


Consider the following during restoration planning and in preparation for translocation of rare

plants.

(i) Provide a detailed outline of the restoration plan for all vegetation communities and rare plant

occurrences including a list of plant species and the habitat attributes for each.

(ii) Ensure that any translocation of plant species follows appropriate guidelines, which includes

ensuring that the new location has the same habitat attributes, community structure and function

as the original location. Follow the document “Guidelines for Translocation of Plant Species at Risk

in BC” (see Reference).

(iii) For each rare plant and each rare plant occurrence, describe the type of habitat it uses and the

location of potential alternative habitats to support a translocation.

(iv) Provide specifics on the steps that will be followed including: the timing, the habitat and the

type of follow-up monitoring that will be done.

Continued - next cell



EIS Review Comments



13 338

Continued

(v) Rare plants should be propagated and also have their genetic material preserved prior to such

translocations (see comment above).

(vi) Locally sourced seeds and propagules will need to be collected ahead of destruction so that

rare and regionally-appropriate species can be grown in a nursery to provide materials for

restoration or used for re-seeding.

(viii) The following definition of a restored ecosystem can provide guidance: “An ecosystem has

recovered - and is restored - when it contains sufficient biotic and abiotic resources to continue its

development without further assistance or subsidy. It will sustain itself structurally and functionally.

It will demonstrate resilience to normal ranges of environmental stress and disturbance. It will

interact with contiguous ecosystems in terms of biotic and abiotic flows and cultural interactions.”

(Society for Ecological Restoration Primer definitions: http://www.ser.org/docs/default-document-

library/english.pdf)

Reference: Maslovat, C. 2009. Guidelines for Translocation of Species at Risk in British Columbia.

B.C. Minist. of Environ. Victoria, BC.

http://a100.gov.bc.ca/pub/eirs/finishDownloadDocument.do?subdocumentId=8321.



EIS Review Comments



13 339


Issue: There is an emphasis in the EIS on pesticide and herbicide use for the treatment of invasive

species. There are other methods for control of invasive species that are not chemical-based (e.g.

integrated pest management; mechanical treatment, biocontrol) that are not investigated.

Concerns: (i) Chemical treatments can cause long-term envronmental impacts, including toxicity

and bioaccumulation. (ii) The use of herbicides to limit tree growth (e.g, along transmission lines)

may destroy or damage rare plants.


(a) Develop an Invasive Species Management Plan that considers a range of treatments options,

including early detection, preventation and mechanical or other non-chemical methods, for long-

term application. It is recommended that herbicides only be used as a last resort to control invasive

plant species.

(b) Describe how impacts to rare plants will be avoided during management of weeds and tree

growth.

(c) Include plans to protect ecosystems, plant habitats, plant communities and vegetation post-

construction and during operational activities into the future. Monitoring should continue beyond

the 10 years recommended in the EIS but after 10 years could be at 2 to 5 year intervals. Such

empirical data is important for determining trends in populations and for determining success of

objectives in restoration and reclamation projects.

(d) Consider partnering with and funding the Northeast Invasive Plant Committee to become

involved with monitoring for invasive species within the Project footprint and adjacent areas (i.e.

transportation routes).



EIS Review Comments



13 340


Issue: Five species were identified during surveys that are potentially new to B.C.

Concern: There is little discussion in the EIS of specific methods to preserve these five species or

their habitats and no recognition of the need to collect propagules or otherwise safeguard their

continued existence. There is also no mention of plans to look for them elsewhere to see if their

destruction due to this development would be causing an extinction.


(a) Clarify any steps that are in place or planned to steward these five previously unidentified plant

species as part of any Rare Plant Management and Mitigation Strategy (see Details) . The EIS notes

that “Research to determine the taxonomic authenticity of these 5 potential species is

ongoing...”(App R Part 1 Sec 1.3.2.2 Pg 68). Since taxonomic research could take several years,

what is the commitment by the Proponent to protect the sites in the meantime and/or take

propagules for safe-keeping?

(b) Describe measures that have been taken to steward these plants since they were first

identified in 2008.

Details:

The following actions are recommended for previously unidentified plant species:

(i) Send seeds to a long-term repository; (ii) Propogate the plant material; and (iii) Ensure that

information is provided to the appropriate repositories of information on rare plants such as the BC

Conservation Data Centre.



EIS Review Comments



13 341


Issue: Table 38.1: Under Proposed Mitigation column at the end of Section 13: “Undertake a study

that attempts to clarify the taxonomy of Ochroleucus bladderwort” but there are no other specific

mitigation measures identified for this species.

Concern: It would be proactive to ensure that the location of Ochroleucus bladderwort along the

existing transmission line is not affected. Since this species occurs in aquatic habitats, this includes

not affecting the surrounding hydrology.


Avoid impacting the wetland that contains Ochroleucus bladderwort as part of mitigation planning.

This should be an outcome of planning the transmission line to avoid or minimize impacts to

wetlands and hydrology.

13 342


Issue: The cliffs at Portage Mountain support a rare vascular plant (Siberian polypody), which was

not found elsewhere in the LAA. Portage Mountain also supports a bat hibernaculum.

Concern: The distinct and important habitat values at Portage Mountain suggest that this location

is of high conservation value.


(a) Describe measures to avoid or mitigate impacts to the rare plant occurrences at Portage

Mountain.

(b) Clarify whether the high ecological values at the site were considered in an evaluation of

alternative quarry locations.



EIS Review Comments



13 343


Issue: It is stated that BC Hydro will undertake further surveys in the RAA to identify additional

occurrences of 18 rare plants directly affected by the Project.

Request that the Proponent: Describe plans for follow-up in the event that additional or novel

occurrences of rare plant species are identified. This includes mitigation and monitoring measures

and other steps to provide steward these occurrences.

Details:

(i) Surveys to identify target plants in the study area must be done at the appropriate time of year

by a qualified botanist. The rare plant occurrences need to also have important information like

habitat included, not just UTM’s (i.e., spatial data).

(ii) A qualified botanist should on site when wetlands are to be transversed by the Project to

ensure that the spatial data is interpreted correctly and rare plant/community occurrences are

successfully avoided.

13 344

Residual Effects - Rare plants

Issue: The autecology of individual species needs to be taken into account in the assessment of

residual effects.

Concern: Individual plant species have different tolerances to impacts that are not individually

summarized in the assessment.

Request that the Proponent: Assess Residual Effects on rare plants on a species by species basis in

consideration of their varying tolerances to impacts.



EIS Review Comments



13 345


Issue: The reporting of estimates of Residual Effects on rare plants is difficult to follow. The

rationales provided for the estimates do not always appear to be consistent with the impacts.

Examples:

(i) The Magnitude of effects is characterized as High for construction but Low for operations,

reported as "the additional loss during operations would not exceed the 10% threshold." This

suggests that the post-construction impacts can somehow be quantified when it is not well

understood how plants will be affected by operations.

(ii) It is not clear why Confidence is Low for rare plants (for construction and operations). Is this

confidence in the assessment of impacts or confidence in the effectiveness of mitigation measures?

Specific disturbance responses to excessive flooding are well-known. Plant species generally

tolerate flooding or they do not.

(iii) The reporting of Resilience as High for operations is questionable. The response of plants to

typical periodic flood events cannot be compared with the magnitude of the dam effects.


(a) Explain how the magnitude of additional impacts to rare plants during operations was

calculated?

(b) Consider bumping Confidence from Low to Moderate. There is a high level of confidence in loss

of rare plant occurrences associated with the dam, reservoir and quarry locations although some

other impacts are less certain.

(c) Consider characterizing the Resilience as something other than High since the response of

plants to natural flooding events cannot be compared to changes from the dam.



EIS Review Comments



13 346


Issue: The concluding statement regarding residual effects of the Project on Vegetation and

Ecological Communities (Vol 5 s 40.11 pg 40-5 lines 31 - 36) seems to suggest that the effects of

the Project are inconsequential since pre-existing projects and activities have a significant effect

themselves.

Concern: It would be more informative to describe the incremental effect of the Project given

these pre-existing impacts rather than stating that "..., the effects on those VCs resulting from other

projects and activities that have been or will be carried out are considered significant, even without

the Project." (lines 34 and 35).

Request that the Proponent: Describe the scope, area covered and percentage of vegetation and

rare plant species affected by these “other projects and activities...” and discuss in relation to the

incremental effects of the proposed Project.

App R Table

1.3.3

14a

347

Provide a title for the table to explain what the numbers in the columns mean – occurrences?

Observations? Individual plants? CDC occurrences are specifically defined and should not be

confused with observations.

App R 22348

Typo BC ranks the taxon S2 – it is S2S4

App R 23

349

It might be worth mentioning the issue with entity reported in 2008 here: Carex sp nov cf tenera

(intermediate to Carex crawfordii ).

35.2 33350

These sections only include wildlife as defined in the old terms, i.e. does not include plants.

App R Part

1, S 1.1.2

2351

This section appears to be incorrectly headed; should it be 1.1.1.2?

App R Part

1, S 1.3.2.1

6352

Reference source not found in the third paragraph on pg 66.



EIS Review Comments



App R Part

1, S 3.1

11353

There are three general categories of mitigation, rather than four as stated in the first sentence of

this section.

13 18-19 2a

354

“Reclamation and restoration activities for post-construction would alter community structure”.

This sounds like only reclamation. The EIS uses the terms reclamation/restoration interchangeably.

The word "reclamation" is typically used in mining activities. "Restoration" is the process of

assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed.

13 4 8 355

Section 13: INCONSISTENCY WITH REFERENCE :

DeLong reports on the Fire cycle in the BWBWmw1 in the Boreal Plains as ~ 100 yr cycle, and in the

Boreal Foothills, areas of BWBSmw, ESSFmw2 and SBSwk1 have varying fire cycles by mountain and

valley areas, e.g. 120 years and 150 years respectively (see Tech Report p. 9 and discussion).

DeLong 2011 is also referenced in Appendix R: Veg/EcolComm 1.1 Ecosystem Mapping p. 4 which

notes only the ~100 year cycle for the Project, and not the 120 or 150 yr cycle in some areas.

TECHNICAL MERIT: Quantitative method? In either case, it is not clear how exactly the EIA will

quantify the “loss of Old Growth” with respect to natural range of variability, or if the cumulative

effects of past harvesting is incorporated into the assessment, or only the effects of the Project

Activities.

13.1.4 4 9 356

The term habitat is being used interchangeably with ecosystem all through the EIS documents (e.g. -

Important habitats found within the project area including shoreline habitats, banks, wetlands and

floodplain); The term habitat should only be used when inferring its relationship to specific species.

13 6 15 357

Appendix R: 1.1.2 describes the Habitat Mapping Approach, 1.1.2, where there is a lack of

differentiation between vegetation ecology and species habitat: “Sensitive communities’ are not

equivalent to ‘Habitat’. Habitat can be a feature of the ecosystem, not the entire ecosystem.

Section 13 - General Comments



EIS Review Comments



13.1.4 7 6 358

In the March 2012 document “Environmental Assessment of the Site Clean Energy Project

Comment Table for Draft EIS Guidelines” it is suggested by the BC Conservation Data Centre (CDC)

the all occurrences of the term “plant communities” be changed to “ecological communities”. This

does not appear to have been done in Vol 2 Section 13

13.1.5.2 8 23-26 359

In the March 12 document “Environmental Assessment of the Site Clean Energy Project Comment

Table for Draft EIS Guidelines” more detail was requested around temporal boundaries. That

provided in Vol 2, Section 13.1.5.2 is still vague and there is no reference to any further information

in Appendices.

13.1.5.2 12 1 360

Regarding section 11.2.3.1 Rare and Sensitive Plant Communities:

The EIS will describe ecological communities at risk, which are identified as those ecological

communities currently designated on the provincial Red and Blue lists, communities that are ranked

1 or 2 for Goal 2 of the Conservation Framework , and sensitive communities that are communities

that are less resilient to disturbance such as wetlands ; it was noted in the first review of these

guidelines that this statement is not accurate. While all wetlands are sensitive to hydrological

regime changes, some wetland types (e.g. occurring on primarily mineral soils) are more resilient

than others so the statement above is in accurate. Suggested change to text on pp55: Remove the

words “such as wetlands”

13.2.1.2 15 12+ 361

In the effects assessments section values for impacts to ecosystems and plants are presented by

area in tables 13.8-13.12. The process to derive these values is “area of vegetation/ecological

community loss, assessed by overlaying the project 5 activity zone on the ecosystem maps and

conducting a GIS-based analysis of the area 6 lost due to project activities”. Although the

appropriate information is present in the tables, because information presented here is the

fundamental indicator of magnitude of impact, this information should be presented as proportions

(%) of the i) the ecosystem area and ii) the total PAZ. Preferably also in graph form where it is easy

for the public to visualize the relative impacts/losses.



EIS Review Comments



13.3.1 16 15 362

In Volume 2 Appendix C Part 1- Land Status, Tenure and Project Requirements Maps. The following

is stated “The figures in this appendix are maps described in Chapter 11.3 Land Status, Tenure and

Project Requirements. These maps provide the following information:” Ten Figures are referenced

(as maps) at the beginning including “Figure 3 Forestry Tenures: Third party forestry tenures within

the Project activity zone. (1:300,000)” However, there are only 4 maps there and none of them are

related to Forestry Tenures – Where can they be found?

13.4.1 22 39 363

Incorrect reference to the agricultural land base, rather than vegetation and ecological

communities.

13.5 22 1+ 364

Cumulative Effects – for this section it would be useful to see data from the spatial maps of current

and projected CE’s summarized by baseline rare plant and ecosystem mapping for the RAA, LAA

and PAZ

13 1 - 19 17 365

CLARIFY TITLE OF TABLES: Does this list include the site series for all Biogeoclimatic units occurring

in the LAA (BWBSmw, SBSvk2, ESSFmv2) or only the site series for BWBSmw ? This situation occurs

frequently throughout the report where the reader has to go back to the text to interpret what the

table data is about and in some cases even the text is obscure as in the example given here. If

required as in some publications, these Table Titles would not be able to stand alone for data

presentation and comprehension.

13 21-24 13 366

STATEMENT “Rare communities include red- and blue-listed communities ranked 1 or 2 for Goal 2

(to prevent species and ecosystems from becoming at risk) of the Conservation Framework.” This

sentence seems to be implying that to be considered for the effects assessment, the selected rare

communities must be both red- or blue-listed, AND must be ranked 1 or 2 for Goal 2. Suggest

rewording to clarify intent here (e.g. see 13-11, line 12-14)

13 47 12 367

The size of the size of the proposed Peace River Boudreau Lake Protected Area is identified

incorrectly and inconsistently here and in other locations (section 14.6.2.3) please ensure that the

correct area for the proposed protected area is used consistently throughout the document - See

Vol. 3, Table 25.14



EIS Review Comments



App R Part

1, S 2.1.18 368

The references in the first part of this section are incorrect; reference is to “0”, but should be

Appendix D.

13 Appendix

R - 1.1.2369

Appendix R: p.12 Discussion of seral stages. This section is somewhat simplified in that the criteria

used are only two indicators of successional processes; other factors include severity, frequency

and time since disturbance, etc. 35:35

Section 14 - Wildlife Resources

Butterflies & Dragonflies



EIS Review Comments



14 370

Selection and Description of VCs - Invertebrates

Issue: The Invertebrate section only looks in detail at butterflies and dragonflies. Other

invertebrate groups are not discussed or assessed.

Concern: There are many other invertebrate groups that have potential to be impacted by the

Project. The two invertebrate groups with baseline studies (butterflies and dragonflies) are not

suitable surrogates for all invertebrate groups. Not considering other taxa means that impacts to

species in these groups will not be recognized, opportunities for mitigation missed and overall

effects on invertebrates will be underestimated.


(a) Discuss and assess invertebrate groups other than butterflies and dragonflies. The major groups

of invertebrates could include Orthoptera, Ground beetles, lady beetles, longhorn beetles, tiger

beetles, click beetles, and other beetle groups (there are at least 100 beetle families in BC), true

bugs, pollinators (e.g. bumble bees, wasps, and flies), spiders and other arachnids, gastropods,

moths and other larger invertebrates. There is not one invertebrate group that is more important

than another invertebrate group, so listing these groups does not mean they should be the only

ones included.

(b) Consider implementing the following approach to provide a robust assessment of impacts and

residual effects on invertebrates and invertebrate assemblages:

i) Complete inventories of all invertebrate groups within the flood zone and transmission corridor,

as well as outside these zones (see Details). Analyze data from the impacted and non-impacted

zones for correlations.



EIS Review Comments



14 370

Continued

ii) Complete habitat mapping, using vegetation mapping or TEM polygons, for all areas sampled,

and identifying representative assemblages of invertebrates in each polygon type. Rare habitat

types, or habitats that are unique, are likely to have a distinct assemblage of invertebrate fauna

compared to more common vegetation types.

iii) Assess the overall impact to invertebrates by quantifying the area of habitats impacted by the

Project and comparing this to the total area of those habitats in study area and region. This

approach will also allow an identification of polygons of highest priority for avoidance or mitigation

measures.

iv) Monitoring regimes and mitigation will need to be proposed for these additional groups and

potentially individual species.

v) Specimens should be prepared, curated and deposited at the Royal British Columbia Museum

(Victoria). All bycatch should be kept (e.g., non target species groups) and placed in a collection

container and deposited at the Royal British Columbia Museum for future research opportunities.

Additional Details:

Inventory methodology, at the very least, should include light trapping, pitfall traps, pan traps,

cover boards, hand collection, beating and aspiration of specimens, as well as net collecting and

aquatic surveys. Inventory should span the entire growing season. This should be repeated for a

minimum of two years. At the minimum, GPS track, search effort and survey time (using GPS),

vegetation information and trap type need to be consistently documented.

Reference Martin, J.E.H. 1978. The insects and Arachnids of Canada Part 1: Collecting, preparing

and preserving insects, mites and spiders. Biosystematics Research Institute, Ottawa, Ontario.

Research Branch Canada Department of Agriculture. Publication 1643.



EIS Review Comments



14 371

Selection of VCs - Invertebrates

Issue: Baseline studies have not been undertaken for invasive invertebrates.

Concern: Invasive species can be more effectively managed if it is known what invasive species are

present at baseline. What are the expected introduced invertebrates present (e.g., earthworms,

gastropods, ants, wasps, etc)?

Request that the Proponent: Establish a baseline of invasive invertebrates to inform future invasive

species management.



EIS Review Comments



14 372

Description of VCs - Invertebrates

Issue: The assessment would benefit from additional baseline information about butterflies,

dragonflies and other invertebrate groups in the Project area. For example, the Peace region has

numerous invertebrate species that are westernmost range extentions, as well undescribed (to

science) species. There are museum records, inventory studies, and past projects from which

information can be drawn although these are not numerous. There are a few records in BC

museums. There have been a few biodiversity surveys in the Alberta Peace region, but without

inventory within the BC area, correlations cannot be drawn.

Concern: The baseline information on invertebrates is incompleted without a comprehensive

review of available information and data on invertebrate groups in the region.


(a) Host plant surveys would be beneficial for butterflies.

(b) Clarify whether there are species of butterflies or dragonflies in the region that have yet to be

described.

(c) Include additional descriptions on invertebrate groups, including dragonflies and butterflies,

including information from the literature, from survey data lodged with the Royal BC museum and

through discussions with taxonomists and other invertebrate experts with knowledge of the region.




EIS Review Comments



372

Continued:

Additional Details:

Consider contacting Canadian taxonomists to ask their professional opinion on whether there are

unique species in the Peace Region, what possible species could be present and whether there may

be undescribed species/subspecies within the region. Agriculture Canada has a number of Canadian

taxonomists available to help with this information. Initially contacting the Royal BC Museum for a

list of taxonomists and although this reference is old, there are some contacts for experts

http://www.for.gov.bc.ca/hfd/pubs/docs/wp/wp09.pdf.

Reference: Crispin Guppy pers. comm., regarding new subspecies of butterflies.

14 373


Issue: There are descriptions for only 11 of the 14 red or blue listed butterfly species. Uncertain if

3 species (Alberta arctic, coral and striped hairstreak) were not included intentionally or if this was

just missed. Maps are included for these additional 3 species. (App R S2.1 pg 15 - 17)

Request that the Proponent: Clarify

whether Alberta Arctic, Coral and Striped Hairstreak were intentionally not included or were they

just missed? If they were intentionally not included, please provide a rationale for their omission.

If they were just missed, please add a description about these species to the text.



EIS Review Comments



14 374


Issue: The EIS is missing details about survey methods for butterflies and dragonflies.

Concern: It is not possible to assess the character and quality of data used without information on

survey methods.


(a) Provide documentation of GPS track, search effort and survey time (using GPS), vegetation

information and trap type.

(b) Provide more details regarding sampling design and effort. Clarify that RISC standards were

followed and whether there were deviations from those standards.

(c) Provide criteria used to select the 50 sites sampled. Was there any stratification done to ensure

all wetland/aquatic types were included in sampling (e.g,. sphagnum bogs and small creeks)?

(d) Clarify whether the sampling effort was sufficient to inform relative habitat suitability for each

TEM unit.



EIS Review Comments



14 375


Issue: More information is needed about how habitat suitability maps for butterflies and

dragonflies were developed and the inferences that were made based upon those maps.

Concern: It is not possible to fully understand or evaluate habitat suitability maps and their

application if the inputs and assumptions are not provided.


(a) Clarify whether survey time was included in the calculation of density. Survey time can have a

big influence on density measures.

(b) Provide definitions for high, moderate and low-rated habitat for butterflies and dragonflies.

(c) Describe the assumptions and criteria behind habitat ratings. For example, some TEM polygons

that were sampled and had no species detected and were ranked low while others with no species

detected were ranked N. What is the rationale for this ranking? Are some habitat types ranked as

being more important to specific species than others?

(d) Describe how the habitat suitability maps were developed. For example, is the mapping based

on (i) recorded use vs. lack of use; (ii) mapping of known habitat associations followed by ground-

truthing and refining; (iii) mapping based on existing ecosystem type maps without not ground-

truthing; or (iv) some other method?

(e) Clarify if the suitable habitat as shown on the suitability maps for butterflies is a combination of

high and moderate habitat ratings.



EIS Review Comments



14 376


Issue: It appears that relative habitat suitability for each taxon was determined using the recorded

use or lack of use.

Concern: Lack of use over the 2 years of surveys does not mean the species is not found there.

Request that the Proponent: Factor in

expert opinion about potential habitats to adjust the ranking of habitat suitability so that habitats

are not overlooked due to lack of use over two years of survey (e.g., C. Guppy)

14 377


Issue: Habitat suitability maps have not been provided for the individual species of dragonflies,

including the other listed dragonflies that are found in the northeast of the province. Different

species have different habitat requirements. There has been little surveying done and other species

could found in the area as well, if looked for.

Concern: Not including all species will result in gaps in habitat suitability mapping and will

potentially mask impacts on individual species and underestimate overall effects. (This applies to

dragonflies and butterflies).

Request that the Proponent: Complete

mapping for individual dragonflies species, using what information and data is available.



EIS Review Comments



14 378


Issue: The EIS states that habitat suitability indices could not be completed for species captured in

low numbers despite information available on habitat/vegetation associations.

Concern: Habitat suitability indices were not completed for some species but the literature outlines

clear habitat/vegetation associations. For example, the Bronze Copper has known habitat

associations and field studies to support a preference for wetter herbaceous sites. Also, there

might be other methods of rating habitats that were not considered.


(a) Explain why habitat suitability indices could not be completed for species captured in low

numbers (e.g. Bronze Copper) when there are clear habitat/vegetation associations in the

literature.

(b) If habitat suitability ratings were not possible why were other methods not pursued (e.g.

habitat suitability index or 2 class HSR)?

(c) If habitat suitability mapping of the Bronze Copper butterfly is not to be completed, please

consider targeting this species for further inventory. Given that several other Red- or Blue-listed

butterflies appear to be geographically and morphologically distinct (new unnamed sub-species),

this may be useful and important to determine whether the Bronze Copper is the same as or

morphologically distinct from the rest of the Bronze Copper species in BC.



EIS Review Comments



14 379

Assessment of impacts - Invertebrates

Issue: Butterflies and dragonflies are inappropriately grouped and assessed together (EIS Table

4.3.1). The assessment also groups all species within each of these two taxa.

Concern: Butterflies and dragonflies are completely different organisms with completely different

life histories and vulnerabilities to development. Within each taxa, individual species use different

habitats. For example, it is incorrect to use the the term “wetland” to describe suitable breeding

habitat for all of the dragonfly and damselflies (pg 14-13, line 27 - 28). The “wetlands” identified

are habitat to a number of species, but not all. Some habitat types are missing (e.g., creek,

riverine and bog (sphagnum)).

14 379

Continued

Request that the Proponent: Assess

and report on impacts to butterflies and dragonflies separately:

(a) The EIS quantifies the amount of aquatic habitat to be lost during flooding. Please list separately

the amount of habitat lost for each species of butterfly and dragonfly. Include a consideration of

host plants that will be lost due to inundation.

(b) Clarify whether the assessment assumes that the three target species of dragonfly all utilize

every aquatic habitat equally. What are the implications of being wrong in this assumption?

(c) Table 14-6 (pg 14-27 and 14-28) is missing creek, riverine and bog (sphagnum) habitats. The

addition of these habitats will change the “Available Habitat” and “% lost”. Please reassess impacts

with these habitat types included.

(d) Provide a rationale for using wetlands as a surrogate for potential suitable dragonfly and

damselfly breeding habitat. The use of TEM to complete Habitat Suitability Ratings for the three

dragonfly/damselfly species listed in the Peace Forest District would enable assessment of more

accurate effects and mitigation. There are an additional three species listed in the northeast of BC

but few surveys have been completed and it is not known if those species occur in the study area.



EIS Review Comments



14 380


Issue: The EIS contains little information on the assessment of impacts of disturbance and

displacement on butterflies, dragonflies or to other invertebrate groups.

Concern: Without more information on the assessment of impacts due to disturbance and

displacement it is not possible to evaluate whether the impacts to VCs have been adequately

captured.


(a) Provide more detail about methods and findings regarding the assessment of disturbance and

displacement on butterflies (and host plants) and dragonflies.

(b) Provide information from the literature on potential impacts to other invertebrate groups due

to disturbance and displacement.



EIS Review Comments



14 381


Issue: Only a small number of activities that could cause disturbance or displacement to butterflies

and dragonflies are assessed. For example, in Section 4.3 disturbance and displacement is only

discussed with reference to temporary flooding due to natural causes or power generation. Also,

the effects of construction and operations are considered together when they are likely to have

different effects.

Concern: Impacts on butterflies and dragonflies may be underestimated if the range of sources of

disturbance and displacement are not considered.


(a) Provide a rationale for only considering temporary flooding as a cause of disturbance or

displacement. Discuss all potential sources of disturbance or displacement as a result of Project-

related activities and how each of these activities could be a source of disturbance or displacement

to butterflies and dragonflies. Report separately for each taxon and, to the extent possible, by

species.

(b) Clarify why natural causes of temporary flooding are included (there is way to control natural

flooding).

(c) Assess the effects of construction and operations on disturbance and displacement separately.

For example, the temporary flooding due to construction may be a displacement or disturbance

while the operational flooding will be a displacement. Other activities during construction, such as

clearing could be either, but more likely a disturbance.

(d) Discuss disturbance and displacement effects by species since there will be species that will be

irrevocably disturbed by construction versus others that are likely to return. For operations, there

is certainty where areas will be inundated, which will be positively correlated with displacement.



EIS Review Comments



14 382

Mitigation Measures - Invertebrates

Issue: Little detail is provided about proposed mitigation measures and there is no mention of

monitoring plans. Restoration and mitigation measures are not adequately described. In many

cases, there won’t be the ability to mitigate for flooding impacts. An explicit link is not

demonstrated between mitigation and project effects.

Concern: There is not enough conceptual detail about mitigation measures to evaluate the

effectiveness of the proposed measures and the estimates of residual effects. As currently

described, the proposed mitigation measures for butterflies and dragonflies are not likely to be

effective, particularly for more habitat-specific species. Follow-up plans/monitoring should be

included for all species where mitigation measures have been proposed (e.g. dragonflies and

wetland creation) (see Details).

Request that the Proponent: Consider the following when developing detailed mitigation plans.

Proposed mitigation measures should be supported, where available, by references that

demonstrate the effectiveness of the measures in other locations.

(i) Mitigation for butterflies and dragonflies is very tied to habitat.

(ii) Much of the mitigation proposed in the EIS is related to wetland and aquatic habitats that are

more appropriate for dragonflies. Habitats for butterflies also need to be considered. Mitigation

measures specific to butterflies should consider all life stages, host plants and habitat.



EIS Review Comments



14 382

Continued

(iii) “New wetland habitat areas will be created as partial compensation...” (Vol 2 S3.1 Pg 62). Plans

to create new wetlands should include a description of where the wetlands will be created and the

criteria to be used in decided how this should happen. It is important to create a variety of

wetlands to mimic the mosaic of different habitat types.

(iv) “Design a portion of the wetlands created to compensate for habitat loss to remain fish

free....”(Vol 5 S 39). New wetland habitat should consider a variety of wetland types rather than

simply fish free or fish present - not all dragonflies use the same type of wetland. Also, there are

many invertebrates other than dragonfly larvae that should be considered when developing

compensatory mitigation and monitoring.

(v) The proposal to “Avoid clearing during the breeding season; implement survey protocol if

avoidance is not feasible” is too general (Vol 2 S14.5.3 Pf 14-88 Table 14.22). There is not a single

breeding season for the dragonflies and butterflies (and other wildlife). This should be broken down

to at least the species groups or by the action to be avoided during the breeding season of that

group / group of groups.

(vi) Provide references to peer-reviewed literature regarding the effectiveness of proposed

mitigation measures.



EIS Review Comments



14 383

Mitigation Measures – Invertebrates

Please consider the following when developing a monitoring plan:

(i) Monitoring of a broader range of invertebrate species than butterflies and dragonflies is

encouraged.

(ii) Habitat considered suitable should be monitored within and outside of impacted areas to

confirm that habitat remaining post-construction and inundation actually represents habitats that

will be lost or altered. This applies to butterflies, dragonflies and the other invertebrate groups. For

example, surveys should be completed, as a minimum, for each of the ecosystem types flooded.

(iii) Ongoing monitoring surveys of all invertebrate groups should be done for at least 20 years to

determine if mitigation measures are working and species are re-establishing. This will also help

with understanding the spread of alien invasive species.

(iv) Actions to be tested should be converted to field-testable monitoring objectives.

(v) The monitoring design should include a statistical evaluation of the adequacy of existing

baseline data. This will provide a benchmark against which to test for project effects and any

additional pre-construction or pre-operational monitoring needed to establish a firmer project

baseline.

(vi) The Follow-up Program should include a schedule indicating the frequency and duration of

effects monitoring.

(vii) The Follow-up Program should also include any contingency procedures/plans or other

adaptive management provisions as a means of addressing unforeseen effects or for correcting

exceedances as required to comply or to conform to benchmarks, regulatory standards or

guidelines.



EIS Review Comments



14 384

Mitigation Measures - Invertebrates

Issue: Field survey results indicate that the Prairie Bluet (the one Blue-listed damselfly) was only

found at Watson’s Slough, which will be inundated per proposed plans.

Concern: Work is needed to characterize the habitat of Prairie Bluet prior to inundation.


(a) Clarify if there been any work done to determine why this species is found at this location e.g.,

is it due specific habitat associations, water chemistry, hydrology or all of the above (or other

reasons)?

(b) Watson’s Slough appears to have a distinct ecology in the area. What information is available

to inform replication of the wetland characteristics associated with this slough and Prairie Bluet

habitat?



EIS Review Comments



14 385

Estimate of Residual Effects - Invertebrates

Issue: The reporting of Residual Effects does not separate butterflies and dragonflies. The residual

effects that are reported appear to be more specific to dragonflies. The EIS states that a

considerable amount of suitable habitat within the LAA will persist and support viable populations

but this statement cannot be made with certainty for all species.

Concern: Lepidoptera and Odonata differ in their vulnerability to Residual Effects. Lumping of

butterflies and dragonflies can mask effects on individual species. Species that more closely

associated with riparian, floodplain or aquatic habitats are particularly vulnerable.

Since Habitat Suitability Models were completed for 10 of 14 listed butterfly species, risks/threats

should be broken down by species or at least grouped into upland/lowland-riparian. This would

assist in informing mitigation and monitoring. Once habitat models are completed for the dragonfly

species these should be reported by species as well.


Report estimates of residual effects separately for butterflies and dragonflies, by species where

possible.

(b) Demonstrate, through supporting references, that these estimates are based on a thorough

review of current literature and other available information, in general and specific to the region.

(c) Provide a separate assessment of mortality risks for butterflies, including a reference for the last

sentence – “mortality through vehicle collision...” (Vol 2 App R S 2.3 Pg 60). For example, butterflies

like to puddle in salty puddles, which may be on gravel roads thus increasing mortality. Has there

been research on this issue?



EIS Review Comments



14 386


Issues: The assessment of impacts and residual effects on butteflies and dragonflies is assumed to

reflect potential impacts to all invertebrates.

Concern: Two invertebrate species groups can not be used as indicators impacts to all invertebrate

groups. What are the impacts of hydrological changes due to a large reservoir on fly diversity and

abundance? Will flooding enable the increase of potential habitat for harmful/health risk flies? If

agriculture is to be intensified on remaining (non flooded) agricultural lands, are impacts expected

from pest invertebrate groups? Will increased evapotranspiration have an impact on pollinators?

How will aquatic invertebrates be impacted? What about sandy-gravelly banks for tiger beetles?

There is currently enough information in the literature and expertise to estimate the effects of the

proposed Project on other invertebrate groups.

Request that the Proponent: Provide a

thorough literature review to describe expected outcomes for other invertebrate groups, using

peer reviewed literature, professional opinion (taxonomic experts, ecologists and researchers with

experience in similar ecosystems) and results from studies on other dams. If no supporting

information is available, then this should be stated.



EIS Review Comments



14 387


Issue: The EIS says (referring to wetland habitat): “The total amount of potential breeding habitat

loss during construction and operations is 796 ha.” (pg 14-27). Pg 14-45 line 9 says ‘almost 500 of

potentially suitable aquatic habitat would be lost” when specifying inundation.

Concern: There is a discrepancy in the reporting of impacts on aquatic habitats.


(a) Clarify the difference in areas of potential breeding habitat to be lost;

(b) Clarify whether the increased water pressure and flooding will impact the remaining water

courses outside of the flood zone. What information is available on how this will impact aquatic

invertebrates, including dragonflies?

14 388


Issue: There are references to removal “merchantable trees” in Vol 5 Section 39.

Concern: As these trees are likely large and healthy they provide habitat for numerous species,

including several species of invertebrate.

Request that the Proponent: Assess the effects of removing merchantable trees on invertebrate

species in general.



EIS Review Comments



14 389


Issue: Few details are provided about the determination of the significance of residual effects on

butterflies and dragonflies. The EIS makes observations about the possible outcomes qualitatively

but without substantiation in most cases.

Example 1: The habitats required for the dragonflies are given as “wetlands” without consideration

for the varying types required.

Example 2: Each butterfly species in Appendix R is listed and the amount of low, moderate and high

quality habitat that is in the flood zone but there is no discussion of what the loss of habitat types

means to these species in a regional and provincial (and national) context. Are some of these

butterflies westernmost extensions of their Canadian range?

Concern: Impacts to butterflies and dragonflies need to be considered on a species by species basis

in their regional and provincial context. An determination of significance of effects is not simply a

matter of loss of habitat area.


(a) Explain the criteria and rationale used in the determination of significance to butterflies and

dragonflies.

(b) Provide an assessment of the effects of loss of habitat types on individual species in their

regional, provincial and national context.

(c) The magnitude of effects will vary with each of the species and the habitats that they use. These

need to be characterized by order and by species.

14 all 3

390

It would be preferable if dragonflies and butterflies were broken out into two sub-sections. The

text flows back and forth from one to the other making it confusing to follow. It also results in

inaccuracies as the conclusions and recomendations are different for the two groups.

14 Table

14.15

6391

Dragonflies/damselflies are not listed under “project effect” as a key indicator.



EIS Review Comments



14.2.1 17-18 1392

List the red and blue dragonflies and butterflies. This is done for the other taxonomic groups and is

a missing for these two groups.

14.3.11 2 - 5 5

393

These lines could refer to both dragonflies and butterflies; if the latter requires a herbaceous

wetland. The author uses generic “invertebrates” which is completely inappropriate for this report

or this statement. Other invertebrates (i.e. the majority) do not appear to be being considered in

this report. Stick to the two orders that are being assessed and make comments specific to each of

these two very different orders. If the author was choosing to make reference to all of the

invertebrates this section will require expansion.

14.3.11 2-14

and 1-2

on

page

4

394

These paragraphs belong with the discussion on dragonflies and damselflies; NOT under butterflies;

particularly the 2nd paragraph

14.3.2.1 23-24 7395

Obtuse sentence. Consider “Disturbance would be expected only for adult life stages, as immediate

effects on the majority of egg or larval stages will be mortality.”

14.4.1 Table

14.15

10

396

Project Effect is missing dragonflies in both rows. Dragonflies are wetland and wetland associated

key indicators, and are mentioned in the next column, so should be there.

14.5.1.3.1 5 16

397

This sentence is made of independent clauses: the characterization of low to moderate is not “thus”

based on the reasons provided. Why is there a percent change predicted? Please provide the

numbers and reasoning.

App R Part 2 2

398

Field survey results – indicates that Tables 1.1.2 and 1.1.3 include locations of dragonfly surveys by

year, but the tables do not include locations. Please clarify if the intent was that these tables

include location information.

App R Part 2 10399

1.2.3.4 references to maps for Assiniboine skipper are incorrect, should be 1.3.14 and 1.3.16

App R, Part

2 (2.1)

14

400

Are effects to Odonata and Lepidoptera habitats to be extrapolated to all invertebrates? First

sentence on this page should be limited to the two Orders included in the review.



EIS Review Comments



App R s3.2

401

Suggested wording: All butterflies (egg, larval and pupal stages) and dragonflies (larval life stages)

will experience mortality within the flood zone. Adults will have the ability to disperse, although the

habitat these species need to survive will be destroyed so the chance of population continuity is

diminished and adults will likely not be as successful at progeny.

14 App R 402

Baseline Data – reptiles

For reptiles, baseline studies were done on the two species of garter snake found in the area, the

only reptiles in the area and so that matches their commitment.

14 App R 403

Selection of VCs – amphibians

EIS Guideline: 14.2.2 Amphibians and Reptiles states:

"The amphibian and reptile baseline information will provide an understanding of the existing

habitat and species within the LAA as proposed by the Proponent. All species observations will be

summarized, but the focus will be placed upon the western toad (Bufo boreas) as it is a species of

concern under SARA." This

is appropriate. However, see comments below regarding species considered during the calculation

of residual effects and mitigation measures.

Amphibians & Reptiles



EIS Review Comments



14 App R 404

Description of VCs - amphibians

Issue: The EIS does an adequate job of describing breeding habitat for amphibians but provides no

assessment of terrestrial connectivity or foraging/overwintering habitat. Columbia Frogs, Wood

Frogs and especially Western Toad spend extensive time in different seasonal habitats and an

assessment of seasonal habitat connectivity is necessary.

Concern: Sustainable amphibians populations require both terrestrial and aquatic habitat with safe

connectivity between the two seasonal habitat. A description of only breeding habitat may skew

the estimation of impacts, design of mitigation and the assessment of residual impacts (see

comment below).

Request that the Proponent: Describe (i) foraging/ over-wintering habitat for amphibians; and (ii)

connectivity between breeding and non-breeding habitats



EIS Review Comments



14 App R 405

Assessment of Impacts - amphibians

Issue: There is a change mid-way in the EIS in how the VCs are evaluated – from being “all

(amphibian) species with a focus on Western Toads” to Western Toads being the only species

evaluated in the impact, mitigation and calculation of residual effects. Five amphibian species are

found in the project area (Boreal Chorus Frogs, Columbia Spotted Frogs, Western Toads, Wood

Frogs and Long-toed Salamanders). Two of these species Columbia Spotted Frog and Wood Frog

are ranked Priority 2 on the BC Conservation Framework.

Concern: Potential habitats for the full range of species will not be protected with mitigation

measures (such as sediment fencing etc.) if locations for mitigation are based only on surveys for

Western Toads. It is important that protection and mitigation measures be invoked for all

amphibian species and not just Western Toads.


(a) Use data collected on all amphibian species in an overall assessment of impacts; or be clear in

the document that only Western Toads were used as an indicator for assessing impacts on all

amphibian species and that all amphibian species in the project area are expected to suffer

similar impacts from the project, will benefit from similar mitigation measures, and that the

project will have similar residual effect on all species.

(b) Commit to undertaking measures to mitigate impacts to all amphibian species where found

(not just Western Toad).



EIS Review Comments



14 App R 406

Assessment of impacts - Reptiles

Issue: For reptiles, the VCs included both reptile species in this area with a focus on hibernation

habitat. This is appropriate however one of the species, the Western Garter Snake, can be very

aquatic and forages extensively in shallow wetlands and riparian areas. The flooding of the reservoir

will result in significant loss of foraging area for this snake, which was not accounted for in the

estimation of impacts.

Concern: The full suite of impacts to snakes has not been assessed, potentially resulting in an

underestimation of overall impact.

Request that the Proponent: Assess the impact of loss of foraging area for the Western Garter

Snake and include in the estimation of impacts to this species.

14 App R 407

Assessment of impacts -amphibians and reptiles

Issue: The percentage impact is calculated based on the loss of only one seasonal habitat –

breeding habitat for amphibians and hibernation habitat for snakes - rather than considering all

seasonal habitats and connectivity between them. For example the EIS estimates a loss of 38% of

Western Toad habitat but did not consider the loss of upland riparian habitats and hibernation

habitats that are also important to toad survival.

Concern: Population level impacts are potentially underestimated because the animals need all

seasonal habitats and connectivity between these seasonal habitats.



EIS Review Comments



14 App R 408


From the EIS: 14.3.1.2 Amphibians and Reptiles : "For garter snakes, 15% of suitable hibernation

habitat will be lost due to the Project, the majority of which is a result of the filling of the reservoir

(Table 14.8)."

Issue: Impact is evaluated as percentage loss of habitat, but the impact on the population and how

it correlates with habitat loss is not addressed. This correlation will depend on the timing of the

project activities as this could affect the success of the mitigation measures (e.g., timing the

flooding of the reservoir at a time when snakes are not hibernating will reduce population level

impacts) (see comment below). Also, the Peace River valley is at the northern extent of the range of

garter snakes, and Project could have regional scale effects. Also, the filling of the reservoir may

change the microclimate in the hibernation habitat close to the margins of the "Site C" lake and

may cause the snakes to abandon these sites.

Concern: Basing the assessment of impact on habitat loss without considering how this translates

to a population level impact may underestimate overall effects on amphibians and reptiles.

Request that the Proponent: Estimate the effect of habitat loss and other changes on amphibians

and reptiles at a population level. This should include consideration of the Project being at the

northern extent of the range of garter snakes.



EIS Review Comments



14 App R 409


Issue: The flooding of the reservoir is proposed to happen in the winter. The assessment of

impacts does not consider the impact of timing of the flood on hibernating amphibians and reptiles.

For example, if snakes in the hibernacula are flooded when they are in deep hibernation, the impact

on the population will be large and may affect population recovery in the long-term. If the flooding

is during the active season and the snakes are able to find alternate hibernation habitat, then the

impact on the population may be less severe. A similar argument would apply to amphibians.

Concern: The assessment of impacts is incomplete without discussion of the effect of timing of

flooding on amphibians and reptiles.

Request that the Proponent: Include a discussion of the implications of timing of flooding of the

reservoir on impacts to amphibians and reptiles at a population level.

14 App R 410

Assessment of impacts - amphibians and reptiles

Issue: The Proponent claims that the effects of operations on habitat alteration and fragmentation

are considered reversible upon cessation of erosion (Vol 2 S 14.5.1.1 Pg 14-70). However,

o Erosion may be a continuous process over the entire life of the Project

o Even if erosion does cease at the impact line, habitat loss is permanent; it is gone in the same way

that habitat in the reservoir is gone, and therefore effects are irreversible.

o Will wildlife use the post-erosion habitat; i.e., will it return to baseline conditions, and did wildlife

use the habitat at baseline?

Request that the Proponent: consider the potential implications of habitat loss due to short-term

or ongoing erosion in their design of mitigation and monitoring plans



EIS Review Comments



14 App R 411

Mitigation measures - amphibians and reptiles

Issue: The EIS is lacking in essential details to be able to decide if the proposed mitigation is either

reasonable or effective. For example, proposed mitigation measures for amphibians include the

erection of exclusion fencing, timing of activities, construction of wetlands, and tunnels for toad

passage under roads. All these sound fine but how effective they are going to be cannot be

assessed without the details. For example, the creation of wetlands has the potential to mitigate

effects on amphibians, but further detail on type of wetland (i.e., wetlands suitable for waterfowl

may not be not suitable for amphibians), location, number, and size is required before effectiveness

can be gauged.

Concerns:

It is difficult to evaluate the effectiveness of proposed mitigation measures without some details as

to what is planned.


(a) Provide references where available regarding the effectiveness of proposed mitigation

measures.

(b) Consider the recommendations for effective measures (see Details) when developing a detailed

mitigation plan.



EIS Review Comments



14 App R 412

Mitigation measures - amphibians and reptiles

Consider the following during detailed mitigation planning:

(a) The timing of the mitigation measure is important. For example:

(i) if exclusion fencing is set up before the frogs migrate into a pond to breed, then mitigation is far

more effective than if exclusion fencing is erected after the amphibians have bred in a pond and a

salvage operation becomes necessary.

(ii) If compensation wetlands are built before the impacts start and amphibians start using these

wetlands and salvaged animals are translocated to these “new” wetlands before impact to “old”

wetlands, then the mitigation is more effective than if old wetlands are destroyed and then

compensation wetlands are built elsewhere and much later (after the population has crashed).

(b) For untested mitigation measures (and even established mitigation measures), there needs to

be a monitoring program and effectiveness assessment built in. If these measures are completely or

partially ineffective then the residual effects estimation needs to be adjusted and additional or

alternative mitigation measures put in place.

(c) Some of the mitigation measures need a commitment to ongoing maintenance. For example,

drift fences leading to “toad tunnels” or snake dens. There is no indication of who will be

responsible for this ongoing maintenance and implementation of mitigation measures

(d) The data indicate heavy western toad use of the areas around the Jackfish Road extension.

Recommend transects be conducted along the proposed access road to identify potential areas for

underpasses and fencing.



EIS Review Comments



14 App R 413

Mitigation measures - amphibs and reptiles Issue: Some of

the proposed mitigation measures are experimental i.e., they have not been proven to mitigate

impacts elsewhere (at least no citations are provided). Examples:

(1) artificial snake dens are reported to have been installed in other BC Hydro facilities but no data

is provided as to their effectiveness. If that data is not available, there is a high degree of

uncertainty associated with their use and research and monitoring will be required to determine

their effectiveness.

(2) the use of underpasses to maintain dispersal movements across roads has been shown to have

mixed success and depends heavily on correct placement, structure and size.

Concern: If mitigation measures are not tested for effectiveness prior to construction and habitat

loss there will not be an opportunity to adapt mitigation to increase likelihood of survival.


(a) Initiate mitigation planning and implementation prior to construction to remove animals from

the area of impact and into alternative habitats and to test the effectiveness of mitigation

measures.

(b) Monitor and provide data on effectiveness of mitigation measures:

(i) for use by target species; and

(ii) in terms of potential population level conservation e.g., use of a snake den by one or two snakes

is not a sufficient demonstration of effectiveness.



EIS Review Comments



14 App R 414

Estimates of residual effects - Amphibians

Issue: Almost 40% of the western toad breeding habitat in the LAA is expected to be lost with the

project. This is a large proportion of habitat to be lost for a listed-species. Additionally, Western

Toads have high site fidelity to their breeding habitat (Matsuda et al, 2006). This impact is

accurately described as a high magnitude of effect on habitat alteration. Given the federal and

provincial status of Western Toad, the large amount of habitat affected, and uncertainty around

success and extent of mitigation, it is unclear why effects on habitat alteration and fragmentation

were not found to be significant.

Concern: The conclusions of the assessment of residual effects do not appear to be consistent with

the Proponent's criteria for determination of significant adverse effects to Wildlife Resources.

Request that the Proponent: Provide a rationale for concluding that effects of habitat alteration

and fragmentation were determined to be not significant for Western Toad, which is a listed

species.

References: Matsuda, B.M., D.M. Green and P.T. Gregory. 2006. Amphibians and Reptiles of British

Columbia. Royal BC Museum Handbook.

14 App R 415

Estimates of residual effects - amphibians and reptiles

The EIS provides qualitative rankings of residual effects but no rationale that links back to the data

and literature sources. Construction, in particular, is expected to have permanent negative impacts

on amphibians and reptiles, although there may be continuing impact during the operations phase

due to road mortality depending on the effectiveness of proposed mitigation measures.

Request that the Proponent: Provide a rationale for concluding that residual effects on amphibians

and reptiles are not significant.



EIS Review Comments



14.3.1 14-25 40 416

Some species tables in this section present habitat lost as a percentage of that available in the LAA,

while others do not. Please adjust so that percentage is included in all the tables, as this is useful for

determining magnitude.

14.3.1.6.1 14-36 417

Lines 14-16 refer to foraging opportunities being available over the water of the reservoir;

however, the reference cited in lines 23-25 appears to contradict this statement. Please clarify.

14.3.1.6.1 14-43 30-31 418

Please provide a reference for the statement “….including blasting within 300 m of bat hibernacula

during the winter, can cause premature arousal of hibernating bats”.

14.5.1.1 14-70 25 - 28 419

Effects of operations on habitat alteration and fragmentation are considered reversible upon

cessation of erosion. It is recommended that BC Hydro consider several points:

o Erosion may be a continuous process over the entire life of the Project

o Even if erosion does cease at the impact line, habitat loss is permanent; it is gone in the same way

that habitat in the reservoir is gone, and therefore effects are irreversible.

o Will wildlife use the post-erosion habitat; i.e., will it return to baseline conditions, and did wildlife

use the habitat at baseline?

Migratory Birds



EIS Review Comments



14 420

Selection of VCs - Migratory Birds

Issue: The scope of the assessment of Migratory Birds has been limited to a handful of species at

risk, despite the guidance given in the EIS Guidelines (below). These analysis needs to be expanded

to include a large suite of species, rather than just those at risk.

The EIS Guidelines (12.2.3.3) state

“The migratory bird baseline information will provide an understanding of the existing habitat,

species, relative abundance*, distribution and temporal use within the LAA as proposed by the

Proponent for the following categories of migratory birds:

• Songbirds;

• Waterfowl and shorebirds;

• Marsh birds (Yellow Rail, American Bittern, Le Conte’s Sparrow, Nelson’s Sharp-tailed Sparrow);

• Woodpeckers;

• Common Nighthawk; and

• Others as appropriate. “

Concern: While the Province is especially interested in the species-at-risk within this group, the

number of VCs needs to be expanded to include a fuller suite of migratory birds. There are a

number of reasons for this:

(i) There is a high potential for large numbers of breeding bird to be impacted as a result of the

Project;

(ii) It’s possible that the loss of riparian lowland forests and associated wetlands may drive other

currently non-listed species dependent on these habitats in this area to becoming listed.

(iii) There is enough data from baseline surveys to support assessments of impacts on individual

species.



EIS Review Comments



14 420

Continued


(a) Provide a rationale for how indicator species were selected. Were all habitat types in the LAA

represented by the listed birds selected?

(b) Include all species of Migratory Bird that are protected under the Migratory Birds Convention

Act.

(c) Add Sandhill Crane to the Marsh birds.

14 421

Selection of VCs - Migratory Birds

Issue: Table 1.1.1 Barn Swallow is Blue-listed (since 2009) and COSEWIC listed (since 2011) but is

not included in the list of species to be considered in the EIS. The EIS currently uses Bank Swallow as

an indicator species for all Swallows.

Concern: Barn Swallow needs to be added to the list of species and dealt with throughout the

document. It is incorrect to use Bank Swallow as an indicator for all Swallows (pg 14-71 line 7).

This species might be one of the Swallows most impacted by the Project, but their nest habits

(holes in banks) are quite different from Barn and Cliff Swallows (mud cups/gourds on structures)

and Tree/Violet-green Swallows (cavities in trees). The residual effects for each group will

therefore differ. The impacts may be minimal over the long term for bank nesters and the dam may

provide increased nesting opportunities for structure nesters, but for tree cavity nesters, much of

their breeding habitat will be lost forever.


(a) Add Barn Swallow to the list of species to be assessed.

(b) Expand the assessment of impacts to Swallows to report separately on bank nesters, tree cavity

nesters and structure nesters.



EIS Review Comments



14 422

Description of VCs - Migratory Birds

Issue: Information presented on relative abundance of Migratory Birds is incomplete.

Concern: More robust estimates of densities and overall numbers by species should be possible

from the data collected by the Proponent. These estimates should be calculated and included in

the impact statement.

Request that the Proponent: Provide estimates of densities and overall numbers by species of

Migratory Bird and include these numbers in the EIS.

14 423


Issue: The field work for birds in most of the study area appears to have been extensive. However,

the downstream portion of the study area is very poorly surveyed.

Concern: Survey effort for Migratory Birds in the downstream portion of the project appear to be

limited to a single transect and are inadequate to document the impacts and change in avifauna

expected when the hydrological and disturbance regime are changed by the dam.

Request that the Proponent: Consider further baseline surveys of Migratory Birds downstream of

the proposed dam site.



EIS Review Comments



14 424


Issue: Habitat suitability maps have been developed for just a few species of Migratory Bird. Two

of the habitat maps that do exist are poor predictors of actual bird locations.

Concerns:

(i) There is no habitat suitability mapping for the majority of species that will be impacted by the

project.

(ii) Two of the existing habitat maps ( for Cape May and Connecticut Warblers) do not accurately

predict the observed occurrences for the species in the eastern half of the study area. Either the

habitat models are incorrect OR the baseline mapping for parts of the study area is inaccurate or

not sufficiently detailed (concerns about Broad Habitat Mapping are detailed in comments for

Vegetation and Ecological Communities). Errors in habitat maps will misinform the assessment of

impacts on these species and their habitats.


(a) Determine the reason for the poor predictability of habitat maps and either (i) revisit habitat

model assumptions and inputs and correct habitat mapping for Cape May and Connecticut

Warblers so that it more accurately predicts observed occurrences for these species OR (ii) improve

the accuracy of baseline mapping and update habitat maps accordingly.

(b) Consider preparing habitat suitability maps for additional Migratory Bird species to allow an

expanded assessment of impact to this species group.



EIS Review Comments



14 425


Issue: The “Songbirds” are not adequately addressed in Appendix R Part 4 Section 1.1. The data

from the Breeding Bird Survey should have been adequate to allow estimates of numbers of

breeding individuals. The EIS states that 17,000-30,000 Songbirds are estimated to use the study

area, but there is no estimate of the proportion of these that will be lost to inundation or losses due

to the Project as a whole.

Concern: The assessment of effects and their significance may be underestimated without an

analysis of the impacts to numbers of breeding individuals is needed


(a) Provide an estimate of numbers of breeding individuals of Songbird.

(b) Estimate the percentage of Songbirds that will be lost to inundation and the overall loss of

Songbirds due to the Project as a whole.



EIS Review Comments



14 426


Issue: Request more information on the survey data for Migratory Birds.


(a) Consider submitting data from all Project-related bird surveys (not just Migratory Birds) to the

provincial Species Inventory Database (SPI).

(b) Provide the following clarifications re bird surveys:

(i) Were breeding bird point-counts completed in each of the years noted on line 17? If they

weren't, please provide an explanation for why this was not done.

(ii) Were migration encounter transects limited to fall of 2012? Were any undertaken in spring (pg

14-14)?

(iii) Provide a rationale for the use of motor vehicles to undertake encounter transects for Short-

eared Owls (pg 23, App R Part 6)?

(iv) Provide a rationale for why no encounter transects were undertaken within or adjacent to the

reservoir on the south side of the river (App R Map 1.6.16). Is this based on the habitat suitability

spatially depicted on Map 1.6.25?

14 427

Assessment of Impacts - Migratory Birds

Issue: There is no estimate of the expected number of Migratory Birds, by species, whose habitats

will be destroyed or altered as a result of development.

Concern: Table 2.1.1 summarizes projections of the areas of impacted habitats, however an

analysis of bird densities has not been presented that would allow these areas to be expressed as

the number of birds impacted as a result of lost of altered habitat. There is ample survey data to

support this analysis for most species (with the exception of impacted areas downstream of the

dam - see comment above).

Request that the Proponent: Provide an estimate of the numbers of individuals of each Migratory

Bird species that are expected to be impacted by habitat loss and alteration.



EIS Review Comments



14 428

Assessment of Impacts - Migratory Birds

Issue: The potential loss of breeding habitat for beach-nesting birds is not included in this

assessment.

Concern: Nesting habitats along the sandy shore of the Peace River are likely to be lost to the

impoundment with associated impacts to breeding habitat for Nighthawks and other beach-nesting

shorebirds like Killdeer and Spotted Sandpipers.


(a) Describe the potential for (i) beach habitats to re-form post-development and (ii) continued

losses downstream of the dam due to changes in hydrology.

(b) Assess impacts to beach nesting shorebirds such as Nighthawk, Killdeer and Spotted Sandpipers.



EIS Review Comments



14 429

Mitigation Measures - Migratory Birds

Issue: The mitigation measures for Migratory Birds described in Vol 5 Sections P 39.7 and 39.8 are

high level and not species specific. Detailed mitigation measures are not provided for individual

species of Migratory Bird, including the Red-listed species.

Concern: The lack of detail and species specificity makes it difficult to evaluate the effectiveness of

proposed mitigation measures or their ability to mitigate residual effects. A full and detailed

wildlife mitigation plan needs to be developed with areas and timelines defined and funding

identified.


(a) Describe conceptual mitigation measures for individual species of Migratory Birds that are linked

to projected impacts to birds or their habitats (see examples in Details). In particular, provide

mitigation measures for Red-listed species. If no mitigation measures exist, note this and factor it

into the estimate of residual effects.

(b) Explain how the following mitigation measure is expected to reduce impacts to nesting

migratory birds: "If clearing occurs during the critical bird breeding season (see Table 14.15), a nest

search protocol would be developed and implemented prior to clearing, to avoid disturbance and

possible mortality to nesting birds (S 14.5.1.3.3 14-84 line 41). The only way to avoid

disturbance/destruction of these nests would be to stop clearing in the area when nests are

located. Note that migratory birds are protected under the Migratory Birds Convention Act (MBCA)

and the BC Wildlife Act.



EIS Review Comments



14 430


Please consider the following when developing detailed mitigation and monitoring plans for rare

Migratory Birds:

(i) For Nelsons Sparrow: a key avoidance/ mitigation measure is to not disturb the wetland where

this species occurs along the proposed transmission line corridor. Recommend that the Proponent

try secure the other two known sites for the species as partial mitigation for the sites to be

inundated and disturbed.

(ii) Consider the habitat needs of Nelson's Sparrow during the development of compensatory

wetlands. Consider incorporating habitat features into created wetlands to attract this species?

(iii) Partial offsetting of impacts on Common Nighthawk could be achieved if appropriate features

are built into the design of some of the buildings and hard surfaces created in this project (.e.g flat

gravel roofs, gravelled surfaces). Other measures could be taken for species such as Barn and Cliff

Swallows.

(iv) The dam and other associated structures could create nesting opportunities for swallows if

designed for it and managed to encourage them. If this is done, an MOU should be established that

mandates avoidance of structure maintenance activities (cleaning, painting) during breeding

seasons (so that birds aren't disturbed and maintenance activities don't destroy mud nests).

(v) Manage water levels in managed wetlands in consideration of use by shorebirds (pg 39-27 line

52)

(vi) For some species, it may be possible to take nestlings into rehab centres for rising and later

release



EIS Review Comments



14 431


Issue: Few details are provided regarding proposed mitigation for loss of wetlands.

Concern: Wetlands provide a number of ecosystem functions, including providing habitat for a

number of rare plant and bird species. Avoidance is the preferred approach, but if that is not

possible, mitigation for should be carefully designed to capture a range of wetland types and

functions in consideration of the habitats to be compensated.

Request that the Proponent: The Comments for Vegetation and Ecological Communities (Ch 13)

discuss the need for a more comprehensive description of the variety of wetlands in the study area

and estimate of projected losses by wetland type.

(a) Clarify if it is only the wetlands presented in Appendix H that are being considered as

compensation for wetland loss (12.82 ha at Wilder Creek; Pg 14.52 Table 14.15) or is there an

intent to compensate for an equivalent area of lost wetland habitat?

(b) Is wetland management/creation contemplated for the downstream portion of the river?



EIS Review Comments



14 432


Please consider the following when developing detailed mitigation and monitoring plans for

wetlands:

(i) A variety of wetland types need to be created/ recreated/ secured in order to compensate for

the variety of wetlands that different species of birds use in the study area. What are the wetlands

and sensitive habitats that need to be avoided if possible (sizes? maps? water management,

planning, plantings etc?). (ii)

Wetlands will need to be large and/or varied enough to provide suitable nesting/foraging/migratory

habitat for the myriad of wetland species that will be displaced. They will also need to be spaced

appropriately.

(iii) Consider the benefits of one very large complex versus a number of various sized wetland

habitats suitable for water nesters, open-ground/shore nesters, wetland shrub and riparian nesters

(as well as other wildlife)

(iv) An inventory and monitoring program is needed to document the success of mitigation

measures with a commitment to further action if they are not successful.

(v) Consider opportunities for public viewing.

(vi) Involve an experienced agency like Ducks Unlimited Canada in wetland mitigation planning.

14 433

Estimate of Residual Effects - Migratory Birds

Issue: Question about the estimate of Confidence related to habitat alteration and fragmentation

(Pg 14-102 lines 1 - 3).

Concern: The assessment downplays the certainty of impacts on species in high value habitats that

will be irreversibly lost.

Request that the Proponent: Revisit the evaluation of effects of habitat alteration and

fragmentation (pg 14-102 lines 1- 3). The response will definitely vary by species, but one can

predict with confidence that species dependent on the lowland riparian forest habitats that will be

entirely inundated will lose their breeding populations from those habitats.



EIS Review Comments



14 434


Issue: The proposed area to be inundated is the most productive Songbird nesting habitat in the

Peace River, but this loss is not adequately considered in the mitigation or estimates of Residual

Effects.

Concern: The EIS does not report a residual effect on Migratory Birds associated with the very

productive habitats along the valley bottom of the Peace River valley even though the habitat for

tens of thousands of birds will be permanently lost or altered.


(a) Clarify if the assessment considered the impacts and Residual Effects of productive Migratory

Bird habitats along the valley bottom of the Peace River valley.

(b) If not, please undertake an assessment, by species, of impacts to Migratory Birds due to loss or

alteration of productive valley bottom habitats, reported in terms of numbers of individuals

impacted by species. Include an assessment of impacts due to loss of continuity of riparian corridors

used by songbirds during migration.



EIS Review Comments



14 435


Issue: There is no estimate of the number of individuals of each Migratory Bird species-at-risk that

will be lost due to the Project (S14.5.1.3.3). Effects are not reported in their regional and provincial

context.

Concern: Basing estimates of Residual Effect only on the loss of habitat in the local area has the

potential to seriously underestimate population impacts on individual bird species at a regional and

provincial scale. The Proponent has collected adequate data for the LAA to be able to estimate loss

in terms of number of individuals of the majority of species that in the area. For example, there are

only four known sites for Nelson's Sparrow in BC and 100% of these sites are within the Project

footprint. The Project could result in a loss of nearly 25-50% of the breeding sites for this species in

BC (one site is in the inundation zone and another along the transmission line right of way) yet the

EIS characterizes the Residual Effects for Nelsons Sparrow as a 20.4% loss in the LAA. Likewise s

14.5.1.3.3 of Volume 2 estimates the impact on migratory birds at less than "10% of the population

of ground- and shrub-nesting species", which is a broad generalization and does not specify

populations that are being referred to (local? Provincial? global?).


(a) For each species at risk, or nearly at risk (S1-S4), provide an estimate of

(i) the % of the provincial population that will be lost,

(ii) the % habitat lost locally, regionally and provincially, for the species, and

(iii) the potential implications for the CDC assessment of the species

(b) Report whether the Project has the potential to result in a up listing to a higher risk category for

any of the species assessed. Report on all assessments of Residual Effect in terms of impacts at the

local, regional and provincial scale.



EIS Review Comments



14 436


Issue: The estimate of Residual Effects inappropriately groups species of Migratory Birds together.

Concern: Estimating Residual Effects based on a lumping together of species that use different

habitats could result in a masking of impacts and an overall underestimation of effects. For

example, The EIS states that “The percent loss of marsh bird habitat would be similar for Le Conte’s

Sparrow, Nelson’s Sparrow and Yellow Rail. The loss of Watson’s Slough would affect all three

species, although the species were reported present in other areas south of the Peace River." (Vol 5

S 39).

Grouping these marsh species for the purposes of the assessment is not a credible practice; they

use very different types of wetlands and are not present simultaneously in all mapped wetlands.

This assessment is made more difficult because wetland habitats are also inappropriately lumped

together.


(a) Report on all assessments of Residual Effect on a species-by-species basis.

(b) If groupings of species are made, these should be by habitat association and a rationale

provided for reporting by group rather than individual species.

(c) Apply the provincial wetland classification system to map out wetland habitat types and report

on impacts to wetland bird species by wetland type.



EIS Review Comments



14 437


Issue: Only a few of the Project activities are reported in the section on Residual Effects to

Migratory Birds (S 14.5.1.3.3). For example, the EIS states that construction headpond flooding is

considered to be a residual effect but there is no statement about the residual effect of impacts

due to other Project-related developments (flooding and other permanent changes to habitats).

Concern: It is not clear from the reporting of Residual Effects whether all potentially impacting

activities associated with the Project have been factored into the estimate of Residual Effects.

Request that the Proponent: Report on

the estimate of Residual Effects on Migratory Birds related to all potentially impacting Project-

related activities, in particular those that will cause permanent loss or alteration of habitats.



EIS Review Comments



14 438


Issue: Other than a brief sentence, in Section 2.2 of Appendix R, the Habitat Alteration and

Fragmentation Section is missing any consideration of the downstream impacts of the Project.

Concern: The proposed dam will reduce water flows and change the disturbance and hydrologic

regime away from what is required to create low bank riparian islands that provide important

habitats for migratory birds. The natural hydrologic regime reduces the speed of succession and

creates specific habitat types, some of which are heavily used, or solely used by migratory birds.


(a) Clarify whether downstream impacts of the dam (e.g., reduced flows, changed disturbance and

hydrologic regime) were considered in the estimate of Residual Effects on Migratory Birds.

(b) If an assessment of downstream impacts was not done, provide a rationale for this omission

and describe the limitations to the assessment of impacts and residual effects on Migratory Birds

and other waterfowl and shorebird species using downstream habitats. See also comment above

on lack of survey effort downstream of the dam.

14 439


Request that the Proponent: Clarify in the text that clearing of vegetation during breeding season

WILL (not may) cause destruction/disturbance of nests (Pg 14-42 line 27).

Issue: The language in the EIS downplays the potential impacts of the Project.

Concern: Using the word "may" instead of "will" when impacts are inevitable downplays the

potential impacts of clearing vegetation during the breeding season.



EIS Review Comments



14.3 Table

14.5440

Please clarify the definition of Migratory Birds used in the assessment. If defined according to the

Migratory Birds Convention Act, then Rusty Blackbird doesn't belong in this group. Also, technically,

swallows are songbirds.

14.1.1.2 30 - 32

441

The list of birds covered under the MBCA is incomplete. Some missing groups are irrelevant as

they don’t occur in the area (e.g., tubenoses and cuckoos); however, others do occur and breed

there regularly including: Caprimulgidae (goatsuckers, e.g., Common Nighthawk which nests on the

banks of the river and other open ground); Apodidae (swifts); Trochilidae (hummingbirds). It could

be the proponents thought these were included in the category “insectivorous songbirds” but this

only includes Passeriformes. They could correct by changing this category to “migratory

insectivorous birds” a catch all phrase used in the MBCA that does include the aforementioned

groups, or by including the aforementioned groups.

14.1.1.2 30 - 32

442

On p 14-14 line 20-21 songbirds are defined to include passerines, swifts, hummingbirds, pigeons,

doves and kingfishers – this is simply wrong.

14.1.1.2 30 - 32443

Woodpeckers are missing from s14.1.1.2, pg14-1. They are listed in Table 14-4 as Key Species

groups and are included in the assessment S 14.3.1.3).

14.1.1.2 30 - 32

444

Use of the term “seabirds” as a group could be confusing as many people interpret this to include

cormorants/pelicans which are not MBCA birds (as well as other groups like loons, grebes, seaducks

etc). The MBCA uses the word Alcids to specifically restrict the meaning to auks, auklets,

guillemots, puffins and murres as intended – none of which are likely to occur in the impoundment

area.

14.1.1.2 10 - 11

445

Not sure why the discrepancy but I checked MBCA Regulation 6 on-line at the CWS website and its

last statement is: "except under authority of a permit therefore," not "except under authority of

a special permit or as provided in the Migratory Bird Sanctuary Regulations.” - Please Clarify



EIS Review Comments



14.1.4 Table

14.4446

All these Migratory Birds are also protected under the BC Wildlife Act, so don’t understand why

only MBCA is mentioned in the rationale? This is especially relevant in the case of the Rusty

Blackbird, which is included in the Songbird section, as blackbirds are not covered by the MBCA.

14.2.3 34-35

447

Refers to “all seven rare species of warblers”? Presumably this is referring to the 7 species at risk,

two of which aren’t warblers.

14.2.3 15

448

60 species of waterfowl found?...there are not 59 species of waterfowl in the whole of British

Columbia..should this be waterbirds or is the number a typo?

14.2.3 19-20

449

Cormorants and herons are neither waterfowl nor shorebirds do they mean water birds?

14.2.3 22-28450

Likely means waterbirds?, not waterfowl.

14.3.1.3 18

451

Have to be careful about the use of the word “migratory”. Not all birds covered by the MBCA

migrate (e.g., most woodpeckers don’t), and some not covered by it do (e.g., some blackbirds,

some raptors etc). So “birds covered by the MBCA” is a legal not descriptive term. I have

presumed that the section title Migratory Birds referred to MBCA birds. However on line 18 it

states that “All other migratory species...” which is more of a colloquial usage that refers simply to

any species that migrates and wouldn’t be restricted to MBCA birds. It would be more accurate to

state “All other MBCA species...” This is an important distinction as it has legal ramification on

whether the fed’s or province has senior mgmt authority over the species.

App R 452

Wandering Tattler does not occur in the study area, nor would it be expected to. Recommend

removing section

App RTable

1.3.3453

Excessive amount of space is devoted to accidental /vagrant/migrant species and the real impact of

the loss of commoner species is not being addressed in this report.



EIS Review Comments



App RTable

1.3.3454

“waterfowl” - Please define - this number appears far too high for it to be the commonly accepted

list of species that are considered to be waterfowl.

App R P18 455List would be more suitable as a table.

14 456

Selection of VCs - Non-Migratory Birds

Issue: Concern about the lack of focus on Ruffed Grouse in the assessment although the species

account was thorough.

Concern: The species is relatively common provincially but the loss of lowland, old/mature,

riparian forests will have a major effect on individuals locally. This habitat type is unlikely to be

replaced post-inundation. Ruffed Grouse are also a valuable game species.


Provide a more comprehensive assessment of the impacts to Ruffed Grouse in terms of affect on

the number of breeding individuals and downstream impacts caused by changes in hydrology.

Non-Migratory Birds



EIS Review Comments



14 457

Description of VCs - Non-Migratory Birds

Issue: There are important gaps in the coverage of field surveys of Non-Migratory Birds.

Concern: There are portions of the LAA with suitable habitat in which no surveys were conducted

and where data does not exist from previous inventories. The implications of this are that the

habitat models are not well-validated; if at all (there is no detail in the EIS on how the field data

were used to support the habitat models). Examples of gaps in field surveys include: (i) Some Sharp-

tailed Grouse leks may not have been identified due to gaps in survey coverage and therefore

effects on this species may have been underestimated. The EIS implies that areas not surveyed for

the Project are covered by previous inventories but there are known to be gaps in the knowledge of

lek locations in the LAA. (ii) Surveys of the use of low bank riparian islands by Ruffed Grouse

would provide an indication of the numbers of birds using these features.



EIS Review Comments



14 457

Continued


(a) Provide a map of locations where previous surveys have taken place; this would provide the

reader with more background on actual survey coverage. The regional biologist can provide

information and guidance on data and information related to suitable habitat.

(b) Provide a rationale for gaps in survey locations for Sharp-tailed Grouse and discuss the

limitations of incomplete coverage in assessing impacts to this species.

(c) Further to the previous point, the model identifies a large contiguous patch of suitable Sharp-

tailed Grouse habitat between Windy Creek and Moberly River. Has this area been surveyed for

grouse, and if not, does BC Hydro plan to conduct surveys here?

(d) The living-growing season is stated to include June – September, while the living-winter season

includes October – March (App R Pt 5 S B1.6.2 Pg 53). Lekking activities, which were surveyed for

and discussed in the species account, occur in April and May. Were April and May excluded from

the habitat assessment ? If so, please discuss the implications of not including these months.

(e) Consider conducting surveys of the forested islands downstream of the dam site for Ruffed

Grouse and other bird species, including Migratory Birds (see comment above). Report in the EIS

how many Ruffed Grouse may occupy the islands at baseline.



EIS Review Comments



14 458

Description of VCs - Non-Migratory Birds

Please response to the following detailed questions about Ruffed Grouse surveys and habitat map

(ref. Vol 2 AppR Part 5 Section 1.1, Pg 2-4):

1) Were Ruffed Grouse observations from 2006, 2008 and 2011 incorporated into the draft species

model prepared to determine point-count transect locations?

2) Listening time provided by the RISC standards is four minutes; please provide justification for the

longer listening period used for Ruffed Grouse.

3) Station listening time was extended if ambient noise interfered with ability to hear grouse. How

often was this the case? Please comment on how this ambient noise may have affected the survey

results.

4) Please comment on how many survey stations were completed in inclement weather conditions

(statement on page four suggests that only some point-count stations were not completed under

such conditions).

5) Although the number of point-count stations was reasonable (n=214), the distribution of

transects across the LAA is quite limited. Were these limitations due to logistical issues, such as

access, or lack of suitable habitat predicted by the draft model? Please comment on whether the

relatively poor coverage of the area might affect the final habitat model and predictions of project

effects.



EIS Review Comments



14 459

Assessment of Impacts - Non-Migratory Birds

Issue: The EIS attributes the same recovery, disturbance tolerances and habitats to the two grouse

species (Sharp-tailed and Ruffed), when, in fact, the two species are quite different.

Concern: Sharp-tailed and Ruffed Grouse need to be addressed individually in the assessment for a

number of reasons: (i) the time required for the populations to recover will be different for the two

species; (ii) their habitat requirements and life strategies are different; and (iii) their resilience to

fragmentation and alteration of habitats is different. Sharp-tailed Grouse have fairly specific

requirements for all three life requirements and will not necessarily be resilient. There will be

differences in the magnitude of the effect of flooding on each species.

Additional Detailed information:

"The nesting requirement for the two species is different with little overlap (S 14.3.3.4, pg 14-47).

Sharp-tailed Grouse use more open areas and as stated in the Appendix : “Grouse in the Peace

River area used steep grassland slopes along the south and west-facing river breaks and shrub-

steppe communities in moist and gently-sloped areas along the river breaks (Goddard et al. 2009).

Forested habitat was rarely used.” For Ruffed

Grouse there are many references and statements regarding their use of Aspen stands and mixed

forest. (see B.1.5.1 in Appendix 092e1_v2_app_r_terr-veg-wldlf-rpt_p5-non-mig-birds.pdf)

14 459

Continued


(a) Treat Sharp-tailed and Ruffed Grouse as separate species for the purposes of assessment.

Assess and report impacts and residual effects on each species separately.

(b) Correct the statement in the text, and assumption in the assessment, that "the grouse may

move in the following spring" (Pg 14-47 lines 9 - 10). Reasons: i) The resulting vegetation will not

be suitable for both species; and ii) the habitat will possibly only be habitable by the next spring for

Sharp-tailed Grouse.



EIS Review Comments



14 460

Assessment of Impacts - Non-Migratory Birds

Issue: The assessment of impacts to Sharp-tailed and Ruffed Grouse is incomplete.

Concerns:

(i) Incorrect assumptions about the establishment of the vegetation post disturbance. In the case

of the reservoir, dam and associated features, habitat loss can be expected to be permanent and

therefore irreversible.

(ii) Increases in general disturbance, predation, road kill and hunting as a result of increased access

were not quantified. These issues were identified as the major threats in the Appendix.

(iii) The analysis results showing a greater loss of habitat for Sharp-tailed Grouse compared to

Ruffed Grouse is more of an indication of gaps in the habitat mapping for Ruffed Grouse. Ruffed

Grouse are ubiquitous on forested islands in the LAA therefore one would expect a higher loss of

habitat due to the Project compared to Sharp-tailed Grouse which are more of a grassland species.


(a) Re-evaluate the assumptions concerning the establishment of vegetation post-disturbance in

the assessment of impacts.

(b) Provide quantitative estimates of mortality of Sharp-tailed and Ruffed Grouse due to increased

access.

(c) Explain why the results might show a higher area of impact for Sharp-tailed Grouse when so

much of Ruffed Grouse habitat is expected to be lost as part of the development. Is this result a

reasonable reflection of the distribution of habitats in the LAA or is it an artefact of habitat

mapping?

(d) Assess the characterization of effects and determination of significance in the context of the BC

Conservation Framework, given that both Ruffed Grouse and Sharp-tailed Grouse are ranked 2

within the Framework.



EIS Review Comments



14 461

Mitigation Measures - Non-Migratory Birds

Issue: The EIS provides few details regarding mitigation measures for Non-Migratory Birds.

Concern: Options to mitigate habitat loss, particularly as a result of the reservoir and dam, are

very limited for upland gamebirds. There is no mitigation available for the inundation, either during

the construction phase or the actual inundation. The habitats are gone. Even if habitat loss is

temporary, there is the risk of mortality or disturbance that will be long-lasting (especially for

female Sharp-tailed Grouse). Whether they are aspen copses used by Ruffed Grouse or the grassy

slopes used by Sharp-tailed Grouse; these habitats both occur in the footprint of the reservoir.

The EIS states (S 14.4.2, Pg 14-58 Table 14-16) : "If clearing work during the critical bird breeding

season cannot be avoided, develop and implement a nest and lek search prior to clearing."

Searching does not mitigate loss; there needs to be a commitment to avoid disturbances once a

nest is found. Disturbances to known nests during critical bird breeding is in contravention of the

B.C. Wildlife Act.


(a) Consider guidance noted under Details when developing detailed mitigation measures for Non-

Migratory Birds.

(b) There is a known lek site at Area E located “immediately adjacent to the Project component

boundary”, and another adjacent to the Highway 29 realignment. Please clarify the distance that

the leks are located from the Project and whether additional buffers will be incorporated to avoid

disturbance of these wildlife habitat features (pg 14-35 line 15).



EIS Review Comments



14 462


Please consider the following when developing detailed mitigation measures for Non-Migratory

Birds:

(i) Using pre-existing disturbance features (e.g. roads) will help reduce habitat fragmentation.

Mitigation would be more effective if the south bank access road followed existing resource roads;

(ii) Timing is the primary mitigation measure identified to reduce disturbance and displacement, as

well as mortality. Proposals to not clear vegetation during nesting season will be effective in

reducing disturbance to the Ruffed Grouse and to some extent to the Sharp-tailed Grouse. It is

recommended that the Proponent commit to clearing vegetation outside of the critical breeding

windows identified for birds. This will greatly reduce the risk for numerous avian species, not just

upland gamebirds.

(iii) Avoiding the clearing of trees during the nesting season will help to mitigate impacts to Ruffed

Grouse.

(iv) For Sharp-tailed Grouse mitigation should be focussed on minimizing impacts related to

burning of grasslands, flooding and disturbance.

(v) Access will increase as the result of the Project which will result in easier access for hunters.

Mitigation measures are needed to address increases in hunting pressure.

(vi) There is an expectation that agricultural land will increase and provide habitat, however

mitigation measures to intensify agricultural production runs counter to this (see comment below).



EIS Review Comments



14 463


Issue: Mitigation measures proposed for agriculture conflict with mitigation measures proposed for

Sharp-tailed Grouse.

Concern: The EIS proposes to increase the productivity of non-inundated lands by increased

irrigation, addition of the good soil from the dam site, planting of vegetables in certain areas (Vol 3

S20.3). All of these measures, particularly the vegetables, are likely to render cultivated land much

suitable (likely not suitable at all) for Sharp-tailed Grouse. The "High" suitability rating would no

longer apply.


(a) Recognize and reconcile potentially conflicting mitigation measures for agriculture and Sharp-

tailed Grouse. This could include separating each type of mitigation and ensuring adequate areas of

high suitability habitat were retained for Sharp-tailed Grouse.



EIS Review Comments



14 464

Estimate of Residual Effects - Non-Migratory Birds

Issue: Not knowing the extent to which the inundation may displace local populations of the two

grouse species is not a reason for characterizing the Magnitude of effects as “Low”. A

determination of Magnitude = Low must be supported by reasoning and numbers.

Concern: There are three concerns here.

(i) In general, whether an effect is Unknown might influence the Confidence in an estimation of

effect but not the Magnitude of that effect.

(ii) The magnitude of effects to grouse due to flooding should be able to be calculated. Although

the timing of inundation may be unknown – there can be a calculation made if it occurs during

nesting, which appears possible. There are maps of the proposed headponds that can be used

(111_v2_s11-4_fig_11-04-13_chnnlztn-hdpnd-inundtn.pdf and 112_v2_s11-4_fig_11-04-14_dvrsn-

hdpnd-inundtn.pdf).

(iii) There are two disturbances: the clearing and the flooding. These need to be discussed

separately as the approach to mitigating disturbance and displacement and its effectiveness will

differ between the two activities and the two species of grouse.


(a) Provide a more detailed rationale for estimating the magnitude of displacement as Low.

(b) Provide a more robust estimate of the Magnitude of effects on each species of grouse using

available maps of headpond locations.

(c) Discuss clearing and flooding separately for each grouse species and apply this information to

proposed mitigation measures for each.



EIS Review Comments



14 465


Issue: Impacts to Sharp-tailed Grouse due to disturbance during breeding season are

mischaracterized.

Concern: The estimate of Residual Effects downplays the timing and duration of Project-related

disturbance on Sharp-tailed Grouse and, therefore, may over-estimate the resilience of this species

to disturbance (S14.3.2.4, Pg 14-42, line 32). This is not a short-term one-time disturbance. As the

text notes, male Sharp-tailed Grouse wll return to their lekking site if the disturbance is removed.

However, if there is consistent disturbance over the breeding season they may not return and

females will not return (Baydack and Hein 1987).

Request that the Proponent: Clarify in the wording of Vol 2 Section 14.3.2.4 Pg 14-42 line 32 that

although male Sharp-tailed Grouse are somewhat tolerant of disturbance and males may move

back onto their leks, females will not, and the lek will become inactive (i.e., tolerance is not high).



EIS Review Comments



14 466


Issue: More information is requested concerning the methods and assumptions used to model

habitat for Ruffed and Sharp-tailed Grouse.

Concern: More details are needed of how “suitable habitat” was defined in order to review the

estimate of Residual Effects on grouse species (s14.3.1.4; pg 14-34). The original data is in the

appendix but it is too critical to the understanding of much of the analysis to not have some detail

in the main body of the report. Uncertainties related to assumptions in the models need to be

more explicit as they provide an understanding of the confidence with which the conclusions have

been made. For Sharp-tailed Grouse, the habitat models have rated

too highly the suitability of cultivated fields adjacent to the study area (see Detail #1) and along

transmission lines (see Detail #2) . As a result, the effectiveness of mitigation measures may be

over-estimated and the Residual Effects may be under-estimated.

Additional Detail

1. Within the text of the Appendix there are the following statements:

- “Cultivated fields can be greatly influenced with grazing intensity and crop type.”

- “In a study on the Peace River, most nests were found in shrub-steppe and agricultural habitats

although agricultural fields were used less than available” and

- “Agriculture acts as a ‘sink’ where habitat appears suitable but activities on the land reduce

reproductive success (Goddard 2010).”

Continued in following Cells



EIS Review Comments



14 466

Comment Continued

These observations indicate that the suitability of agricultural lands as habitat varies; there is a

great deal of dependence upon the type of agriculture practiced and how it is practiced as to

whether it is good for Sharp-tailed Grouse. These conditions are highly variable and not able to be

managed by the Proponent. This situation is compounded by proposed measures to increase the

productivity of agricultural lands (described in Vol 20.3 and noted above).

2. The assertion that “... the transmission line right-of-way may increase the amount of suitable

habitat, with the creation and maintenance of younger forest types.” is not likely for Sharp-tailed

Grouse The following are a couple of quotes from Appendix R Part 5 (092e1_v2_app_r_terr-veg-

wldlf-rpt_p5-non-mig-birds.pdf) to illustrate this point:

“In a study on the Peace River, ... Aspen forest was rarely used for nesting.”

“[Sharp-tailed]Grouse in the Peace River area used steep grassland slopes along the south and west-

facing river breaks and shrub-steppe communities in moist and gently-sloped areas along the river

breaks (Goddard et al. 2009). "Forested habitat was rarely used.” (Appendix R B.1.5.1;

092e1_v2_app_r_terr-veg-wldlf-rpt_p5-non-mig-birds.pdf) noted in a paragraph on the Growing

season requirements and the ratings used.



EIS Review Comments



466

Comment Continued


(a) Provide contextual information on the inputs, assumptions and uncertainties related to the

habitat models. For example the text should note that the “Reliability Qualifier” for models for

both of these species is “moderate”i.e., there is uncertainty about the models and therefore

uncertainty about the estimate of Residual Effects.

(b) Explain why Cultivated Fields were given a maximum rating of High (App R Table B.1.3). There

are a number of problems with this assumption (see Detail #1). Consider re-running the habitat

model with a reduced rating for Cultivated Fields and transmission line right-of-way and report on

how these changes affect the habitat suitability map and the estimate of Residual Effects.

(c) How were habitat models validated? Were field data used to verify habitat suitability maps?

14.5.2 19-22

467

These statements are untrue. There are no species or subspecies that are listed provincially as “a

result of provincial strategies for managing species and ecosystems at risk.” They are listed based

on a suite of criteria including trends, threats, numbers, range extent and area of occupancy. This

also applies to the statement that provincial listing is based “solely on jurisdictional boundaries”.

Refer to the criteria used.

Raptors



EIS Review Comments



468

Selection of VCs - Raptors

Issue: The EIS Guidelines (S 12.2.3.5) state that “All species observations will be summarized” but

information is not presented on a number of raptor species that are known to breed in the study

area including Redtail Hawk, Merlin, American Kestrel, Golden Eagle, Sharp-shinned Hawk, Northern

Hawk-owl and Osprey. Birds of BC (Vol II 1990) indicates that Peregrine Falcons have been

observed in or near the study area, including breeding, but Peregrine Falcon (and other falcons) do

not appear to have been included in survey efforts, despite the fact that Peregrines are a SAR- listed

species.

Concern: The list of Raptor species described in the assessment is incomplete. Some of these

species would have been seen during other inventory work, even if targeted surveys were not

done. There appears to be no reference to surveys for cliff-dwelling raptors (Golden Eagle,

Peregrine Falcon) despite the fact that both species are recorded in the area (Birds of BC and the BC

Breeding Bird Atlas) and Peregrine Falcons are SARA-listed by COSEWIC and Red-listed by BCMOE.

An estimate of the number of nests in the area and the number of birds projected to be displaced is

only provided for Bald Eagle.


(a) Update the EIS to include all Raptor species known to breed in the LAA. Provide estimates of

the numbers of individuals of each species of Raptor that are known to breed in the LAA and

estimate the numbers that will be impacted by the Project.

(b) Add information about the more common species of Raptor (in addition to the more detailed

information on Bald Eagle, Broad-winged Hawk, Northern Goshawk, Northern Harrier). There is a

good overview chapter on the Owls, although numbers are lacking and the potential impact of the

Project is not included. (c)

Clarify whether surveys for cliff-dwelling raptors (Golden Eagle, Peregrine Falcon) have been

completed. If not, provide a rationale for their omission and discuss the implications for the

assessment of impacts. Consider doing surveys for cliff-dwelling raptors.



EIS Review Comments



469

Description of VCs - Raptors

Issue: Information sought regarding the inputs and assumptions used in habitat models for Owls.

Request that the Proponent: Clarify the following re habitat models for Owls (App R Pg 27):

(i) Why is “nesting habitat” modeled for nocturnal owls and “living habitat” modeled for short-

eared owls?

(ii) What are the key differences between the two modelling scenarios?

470

Description of VCs - Raptors

Issue: Baseline surveys indicated few observations of Short-eared Owl and Northern Harrier, which

is postulated in the EIS to mean low nesting use. It should be noted that neither of these species

respond to call-playback surveys and are difficult to detect.

Concern: Few observations do not necessarily equate to low nesting use. A misinterpretation of

these data could result in an underestimation of impacts and Residual Effects.


(a) Consider the difficulties with detecting Short-eared Owl and Northern Harrier in estimates of

amount of nesting use and impacts to these species.

(b) Clarify whether the surveys were to RIC standards.



EIS Review Comments



471

Mitigation Measures - Raptors

Issue: There are few details in the EIS about proposed mitigation and monitoring plans for Raptors.

Mitigation measures for individual species are not provided for any of the Raptors except Bald

Eagles, Northern Harrier and Short-eared Owl. There is also little information about monitoring to

track the effectiveness of mitigation measures.

Concern: Wetland compensation will be made available to address some habitat losses for

Northern Harrier and Short-eared Owl. However, there is no indication of whether the amount and

types of habitat eliminated will be compensated. Bald Eagles appear to be the only Raptor that will

gain some mitigation measures in the construction phase.


Provide conceptual species-specific mitigation measures for Raptor species in addition to Bald

Eagles, Northern Harrier and Short-eared Owl. In particular, provide proposed measures for at-risk

species including those dealt with in more detail in the assessment (Broad-winged Hawk, Northern

Goshawk). (b) Clarify whether

the intent is to provide compensation equivalent to the amounts and type of habitat that will be

eliminated.

Please consider the following during detailed mitigation and monitoring planning for Raptors:

(i) Implement measures prevent Raptors from nesting on power poles along transmission line.

(ii) Refer to the recently revised MOE Best Management Practices for Raptors.



EIS Review Comments



472

Mitigation Measures - Raptors

Issue: Artificial platforms for Bald Eagles will be unlikely to compensate entirely for loss of eagle

nests. It is also unlikely that reservoir will have the capacity to support the number of pairs of eagle

that currently exist.

Concern: The EIS projects a loss of 54% of known Bald Eagle nest sites. It is not reasonable to

assume that natural riparian habitats for Bald Eagles will be completely replaced by the

construction of artificial platforms (Pg 14-73 line 15). The proposed installation of eagle nesting

platforms adjacent to the reservoir shoreline will not necessarily be in the same habitat type as

those nests presently situated within the reservoir flood zone and will likely have a lower capacity

to support Eagles. Additionally, the effectiveness of nest platforms for Bald Eagles is not proven;

nest platforms have been very successful with Ospreys, but, based on experience, the success rate

is lower with Bald Eagles.


(a) Re-evaluate the estimate of Residual Effects to account for potential Project-related reductions

in carrying capacity for Bald Eagles due to changes to the riparian environment, potential

reductions in fish and waterbird prey due to the change to a large, deep impoundment, and

uncertainties related to the effectiveness of artificial nest platforms.

(b) The effects of habitat alteration and fragmentation on Bald Eagles are characterized as Low

because of the provision of nesting platforms. Provide examples from the literature on the

effectiveness of nesting platforms for Bald Eagles and the optimal habitat in which to place the

platforms (e.g., away from human disturbance, surrounded by mature forest etc.).

(c) Consider the following when planning to mitigate the loss of nest trees for Bald Eagles:

(i) Consider installing platforms in other riparian habitats that will not be directly impacted by the

reservoir;

(ii) Provide a variety of platform designs;

(ii) Monitor platforms for their effectiveness as replacement nesting habitat.



EIS Review Comments



14.1.1.2 30 - 35

473

This statement is incorrect as written: Some species, including Eurasian Skylarks (Alauda arvensis),

all raptors, and 33 some native and some introduced upland game birds, have additional

protection. None of them have “additional protection”. Perhaps what they meant is that “In

addition, some non-native species are also covered under the BC WA including Eurasian Skylarks, all

non-native raptors and some introduced upland game birds”. Note that these species are added to

enable us to manage them, not necessarily to protect them. The raptors are there so we can

control falconry import/export; non-native game birds are there so we can enable hunting; species

like skylarks, starlings, House Sparrow and Rock Pigeons are there so we can manage/control them.

14.1.1.2 30 - 35

474

BCWA s 34 para provides year-round protection to the nests of Bald and Golden eagles, Peregrine

Falcons, Gyrfalcons, Ospreys, herons and Burrowing Owls regardless of whether the nest is active or

not. This is extremely relevant in the case of Bald Eagles nests that will be lost during construction

and flooding as a permit will be needed before such activities.

14.3.25 13 - 15

475

The statement: "Other species with nests within 500 m of the Project 13 activity zone include Broad-

winged Hawk (one nest) and Northern Goshawk (three 14 nests) is somewhat misleading as it

suggests these are the only other species of raptors nesting in the activity zone, rather than just the

nests they happened to find (whereas I recall finding a couple of Merlin nests during bird surveys

there in the 1970s). It would be better stated as “Other species for which nests were located within

500m....”

14.42 Table

14-16476

Removal of trees holding eagle (or Osprey) nests requires a permit regardless of time of year.

14.4 2 Table

14-16477

Note that the Wildlife Act protects some species nests whether they are active or not – including

eagles. This means removal of trees holding eagle (or Osprey) nests requires a permit regardless of

time of year.

14.7 478 This list would be more suitable in a table.

Birds - General



EIS Review Comments



479

Assessment of Impacts - Birds

Issue: The EIS does not consider impacts to bird resulting from collisions with powerlines,

particularly if they are placed over wetlands.

Concern: Locating transmission lines over wetlands significantly increases the likelihood of birds

dying from collisions with powerlines, especially swans, raptors and sandhill cranes. In particular,

collisions with power lines could be of significance to Trumpeter Swans if the lines are close to the

wetlands where this species has been recorded breeding. Lines and towers can also increase

predation by raptors, ravens, crows and magpies.


(a) Include an assessment of mortality risk to birds (Trumpeter swans, Raptors and Sandhill Cranes)

as a result of collisions with powerlines built as part of the Project.

(b) Outline mitigation measures to reduce powerline collisions such as locating transmission lines

away from wetlands and, where avoidance is not feasible, applying techniques such as attaching

appropriately-placed deterrents to the wires.



EIS Review Comments



480

Assessment of Impacts - Birds

Issue: The EIS does not consider impacts to bird resulting from collisions with powerlines,

particularly if they are placed over wetlands.

Concern: Locating transmission lines over wetlands significantly increases the likelihood of birds

dying from collisions with powerlines, especially swans, raptors and sandhill cranes. In particular,

collisions with power lines could be of significance to Trumpeter Swans if the lines are close to the

wetlands where this species has been recorded breeding. Lines and towers can also increase

predation by raptors, ravens, crows and magpies.


(a) Include an assessment of mortality risk to birds (Trumpeter swans, Raptors and Sandhill Cranes)

as a result of collisions with powerlines built as part of the Project.

(b) Outline mitigation measures to reduce powerline collisions such as locating transmission lines

away from wetlands and, where avoidance is not feasible, applying techniques such as attaching

appropriately-placed deterrents to the wires.



EIS Review Comments



481

Mitigation Measures - Birds

Issue: The loss of valuable lowland riparian forested habitat will be difficult to mitigate effectively.

Concern: Impacts to birds that rely on lowland riparian forests, such as cavity-nesters, may be

underestimated if mitigation is assumed to offset this habitat loss.

(i) Species dependent on the lowland riparian forest habitats that will be entirely inundated will

lose their breeding populations with an impact disproportionate to the amount of high value

habitat lost.

(ii) There is a high level of uncertainty regarding the effectiveness of proposed mitigation for loss of

lowland riparian forests. The edge of the impoundment will move inland and cause the land/water

border to be closer to private ranch/ agricultural/ developed lands in many places where it may not

be possible to re-establish a riparian forest zone and even where it can be created, it is unlikely to

grow into the large, old-growth forests evident now on islands and lowland benches that provide

habitat for large raptors, Pileated Woodpeckers, Ruffed Grouse etc.

(ii) The EIS states that "Woodpeckers are known to persist when subject to natural disturbance,

and are considered to have high resilience to the effects of habitat alteration and fragmentations,

providing suitable nesting trees persist.” (pg 14.72 line 7). This statement does not clarify the

ability of Woodpeckers to adapt when nesting trees do not persist. Woodpecker nesting is likely to

be most dense in the lowland riparian forests that are going to be lost.


(a) Consider securing an equal amount of lowland riparian habitat in another location.

(b) Use data on the number of pairs of nesting birds to assess loss and effectiveness of mitigation.



EIS Review Comments



482

Mitigation Measures - Birds

Issue: The loss of valuable lowland riparian forested habitat will be difficult to mitigate effectively.

Concern: Impacts to birds that rely on lowland riparian forests, such as cavity-nesters, may be

underestimated if mitigation is assumed to offset this habitat loss.

(i) Species dependent on the lowland riparian forest habitats that will be entirely inundated will

lose their breeding populations with an impact disproportionate to the amount of high value

habitat lost.

(ii) There is a high level of uncertainty regarding the effectiveness of proposed mitigation for loss of

lowland riparian forests. The edge of the impoundment will move inland and cause the land/water

border to be closer to private ranch/ agricultural/ developed lands in many places where it may not

be possible to re-establish a riparian forest zone and even where it can be created, it is unlikely to

grow into the large, old-growth forests evident now on islands and lowland benches that provide

habitat for large raptors, Pileated Woodpeckers, Ruffed Grouse etc.

(ii) The EIS states that "Woodpeckers are known to persist when subject to natural disturbance,

and are considered to have high resilience to the effects of habitat alteration and fragmentations,

providing suitable nesting trees persist.” (pg 14.72 line 7). This statement does not clarify the

ability of Woodpeckers to adapt when nesting trees do not persist. Woodpecker nesting is likely to

be most dense in the lowland riparian forests that are going to be lost.


(a) Consider securing an equal amount of lowland riparian habitat in another location.

(b) Use data on the number of pairs of nesting birds to assess loss and effectiveness of mitigation.



EIS Review Comments



483

Impact on birding as a rec/tourism activity

Issue: There is no recognition of the residual impact on birding as a recreational activity. Examples:

Watson Slough, which will be lost if the project goes ahead, is promoted Tourism BC as a important

birding spot in Fort St John http://www.hellobc.com/fort-st-john/things-to-do/parks-wildlife/bird-

watching.aspx and that ebird has listed this location as a birding “hotspot” in British Columbia

http://ebird.org/content/canada.

(ii) Tables 1.3.4 - 1.3.6 show use of the LAA by thousands of waterfowl, especially ducks and geese.

Concern: This is a potential social and economic impact to recreation, tourism and sustenance use.

Request that the Proponent: Clarify whether the following are included in the assessment of social

and economic impacts.

(i) Loss of tourism e.g., bird-watching, nature-based tourism) related to impacts to bird species and

Watson's Slough; and

(ii) Loss of hunting opportunities as a result of impacts to waterfowl

Note: the loss of birding spots could be mitigated by creation of new wetlands that include areas

for viewing.

14.2.3 18

484

Line 18 – swallows are listed separately from songbirds whereas both are passerines and both

typically referred to as songbirds. Swallows are weak singers and often surveyed differently from

other songbirds, so it might be better to state “songbirds (including swallows)”.



EIS Review Comments



14.2.3 26

485

EIS states that there are 7 R&B species, then identifies the 3 SARA species and gives their COSEWIC

rankings, but not their R&B status - and also does not identify and give status for the other 4. The

other 4 are identified in the following paragraph, but without acknowledgment of their status.

Further down the R&B status is given in lines 38-42 and line 1 on the next page for all but OSFL. For

consistency please consider placing the Red and Blue status in lines 29-32

14.2.3 19 - 20486

Cormorants and herons are neither waterfowl nor shorebirds – again – do they mean water birds?

14.2.3 20 - 21487

Songbirds are defined incorrectly as passerines (correct), swifts, hummingbirds, pigeons, doves and

kingfishers. Please clarify how this definition was formulated.

14.2.3 22 - 28

488

Of the 13 species listed as waterfowl, only the White-fronted Goose, Harlequin Duck, and Snow

Goose fit this category. Arctic, Caspian and Common terns; California, Ring-billed and Mew gulls;

and Black-bellied Plover are all in the shorebird Order Charadriiformes. The Pacific and Common

loon are in the Loon Order Gaviiformes. The Sandhill Crane is in the Order Gruiformes.

14.1.1.2 30 - 35

489

The list of bird species exempt from protection under the BCWA is complete, so no need to state

“includes”. Also “molthrus ater” is two words. Suggest revising to:

A few select species are exempted from protection for management reasons – these are crows,

European Starlings (Sturnus vulgaris), Rock Pigeons (Columba livia), Brown-headed Cowbirds

(Molothrus ater), House Sparrows (Passer domesticus), and Black-billed Magpies (Pica hudsonia).

14.3.2.4 32-33

490

Leupin (2003) only refers to Sharp-tailed Grouse. Please change grouse to Sharp-tailed Grouse.

14.2.3 40 (and

followi

ng

14

491

The text of S 14.2.3 refers to 7 species of woodpecker that occur in the Peace Region but only

identify 4 of them specifically.

App R Part

5. S 1.6.5492

The adjustment description for steep slopes as being downgraded to a maximum of low for winter

does not match the information presented in Table B.1.7.



EIS Review Comments



App R

Section 4.2493

There are a number of tables in Section 4.2 that have missed the sections on the residual impacts

associated with the operations phase (e.g. 4.2.3 Residual Effects. Waterfowl and Shorebirds Table

4.2.4 habitat alteration and fragmentation – marsh birds. Please correct.

14 494

Selection of VC’s – Non flying small mammals

Issue: The final EIS Guidelines did not include non-flying small mammals as indicators or as focal

species despite a request during the consultation phase that they be included. An explanation is

not provided Table 14. 2 Rationale for the Exclusion of Suggested Species (in the Wildlife Summary

document).

Concern: Although none of these animals are listed to be of conservation concern, they likely

comprise an important prey base for higher trophic levels and may have a key role as basal food

web species.


(a) Provide a rationale for why non-flying small mammals were not included in the assessment;

(b) Collate existing data and baseline information (e.g., from the literature) and provide an

assessment of impacts to non-flying mammals at the local population and species level within the

LAA and RAA ; and

(c) describe potential trophic effects of displacement of non-flying small mammals from the

inundation area, including the predators that might be affected.

14 495

Selection of VCs - bats

All bat species in the regions were included as VC in the assessment and well-described– this is

appropriate as the survey methods for all the species are similar.

Mammals - Bats & Small Mammals



EIS Review Comments



14 496

Assessment of impacts - bats

Vol 2 Appendix R Part 7 Pg 226 Table 2.1.1 of the EIS states: "Project construction could directly

affect 22.7% of the available suitable foraging habitat for bats within the LAA and 11.3% of the total

reproducing habitat within the LAA."

There are serious limitations with the estimation of impacts on bats.

i) The probable outcome has been accurately described as adverse, however, by only considering

roosting habitat, rather than roosting and hibernating habitat, the magnitude of potential effects is

underestimated (see comment above).

ii) Floodplain older forests were correctly described as extremely important roosting habitat

(reproductive and non-reproductive) by a variety of methods (acoustic, radio-tracking, mist-

netting). However, these important habitats were not included in the estimation of impacts.

(iii) A < 20% loss of roosting sites associated with riparian balsam poplar forests is estimated to

have an impact of moderate magnitude (Vol 2, Section 14.5.1.1.6) but there is no estimation of

resulting impacts at the population level.

Concern: Hibernation, roost and maternity roost sites are limiting in the environment and

significant use of the LAA by bats for these specialized habitats was demonstrated during surveys.

Since the loss of important habitats can have a proportionally larger impact at the population level,

it is not defensible to assume a 1:1 correlation between loss of habitat and impact to bats. The loss

of foraging habitat is less of a concern. To estimate impacts on bats based just on habitat loss,

without considering the larger impact on populations will very likely result in an underestimation of

residual effects.



EIS Review Comments



496

Continued

Request the Proponent:

(a) Provide a synthesis of all available bat data, including known and potential roosting, hibernating,

swarming and foraging sites by (i) year and between years, (ii) bat species, and (iii) seasonal habitat

use; (b) Use

best available science to re-evaluate potential impacts to bat habitats in consideration of project

effects on known and potential hibernation, roost and maternity roost sites; and

(c) Estimate population level impacts to bat species based on projected loss of habitats within the

LAA and RAA and report on uncertainties associated with this estimate; and (d)

Provide easily comparable summary of the data collected, so that a reviewer can readily make year

to year, season to season, habitat to habitat comparisons.

14 497

Mitigation measures - bats

Issue: Insufficient detail is provided in the EIS to assess effectiveness of proposed mitigation

measures and, therefore, residual effects on bats. The creation of man-made hibernacula at

Portage Mountain has a very high degree of uncertainty surrounding it and can be considered too

little, too late. (Vol 2 S 14.4.1, Table 14.15, Pg 14.51 - 14.56). For example, bat hibernacula have

particular microclimates (Klys and Woloczyn 2010). There is no consideration of whether a drill

hole in a logged landscape on the lakeshore will have a suitable microclimate for a hibernacula.

Concern: Overlooking the uncertainties or limitations associated with untested or ineffective

mitigation measures may result in an under-estimation of potential residual effects and a high level

of uncertainty concerning long-term outcomes for bats. Mitigation measures need to be

conceptualized in enough detail and with support from the literature to provide a level of

confidence in their effectiveness or, at the very least, to clearly identify where the main

uncertainties lie. This is important to guide monitoring efforts and to ensure that appropriate

adaptive management plans are in place.



EIS Review Comments



14 497

Continued


(a) Provide a conceptual plan for mitigation to loss of bat habitat that is clearly tied to the impacts

identified in the assessment. Please include the following:

i) Timing of mitigation measures (pre- or post-construction)

ii) More conceptual details such as spatial and temporal buffers to disturbance and timing of

project activities

iii) References supporting the effectiveness of proposed mitigation measures for Portage Mountain

bat habitats.

iv) Monitoring to assess effectiveness as some of the mitigation measures proposed are

experimental.

v) Responsibility for maintenance of these mitigation measures.

(b) Initiate mitigation planning and implementation prior to construction to remove animals from

the area of impact and into alternative habitats and to test the effectiveness of mitigation

measures.

(reference) Klys, G, and B.W. Woloczyn. 2010. Ecological aspects of bat hibernacula in the

temperate clmate zone f Central Europe. Travaux du Museum National d'Histoire Naturelle 53: 489 -

497.



EIS Review Comments



14 498

Mitigation measures - bats

Please consider the following recommendations for effective measures when developing a detailed

mitigation plan

(a) Mitigation needs to start before construction, before the impacts occur. For example, bat boxes

need to be constructed before cottonwood trees are logged and flooding commences. This will

provide an opportunity to translocate bats and test mitigation meatures before impacts occur.

(b) It is important both to avoid destruction (during construction) and to minimize disturbance

(lights, noise, vibrations etc) when the bats are using hibernacula. Need to ensure proper set-backs

and seasonal timing of construction/disturbance.

(c) Recommend the Proponent do some spot pre-construction surveys with an experienced bat

biologist in previously unsurveyed areas once access opens up and before major construction

begins.

(d) It is recommended that lights be directly downwards to minimize light pollution and attraction

of birds and potentially bats.

(e) Highway bridge locations need to be in habitat suitable for bats (i.e. foraging) to warrant the

incorporation of bat roosting features onto bridges. Similarly, bat boxes (i.e. facility walls, artificial

nest poles) need to be located within habitat suitable for bats(Vol 2 App R Part 13 pg 244 and 245).

(f) Recommend monitoring for mortality during construction for bats at Portage Mountain Quarry,

and that bat boxes be monitored for use.

(g) The use of bat boxes on Bald Eagle nesting platform poles should be investigated more fully;

bats may not use boxes in such close proximity to a potential predator (Vol 2, S 14, Pg 14-55, Table

14.5).



EIS Review Comments



14 499

Estimates of residual effects - bats

Issue: It is difficult to assess whether the EIS estimates the residual effects appropriately when the

conclusions about impacts are so general and qualitative. The impact is estimated as habitat lost

whether the habitat is foraging habitat (widely distributed, not limiting and easily replaced) or

hibernating habitat (specific areas, limiting across the landscape (RAA) and not easily replaced if

ever). The impact of the habitat lost on population size and future growth (recovery) will be very

different for foraging habitat compared to reproducing or hibernation habitat.

Concern: Since the assessment of significant adverse effects is based on the assessment of residual

effects it is necessary to provide a full accounting of how residual effects were determined


(a) Provide a rationale for the estimation of residual effects on bats.

(b) Demonstrate how proposed mitigation measures will reduce residual effects to the EIS

determination of 'non-significance'.

(c) Provide justification for the determination of a “low” magnitude of effect associated with

construction around the bat hibernaculum at Portage Mountain (Vol 2 S14.5.1.3, Pg 14-84).

(d) Clarify if consideration was given to bat mortality resulting from winter construction and

clearing of the Portage Mountain hibernaculum when concluding that the effects of the Project on

wildlife mortality are Not Significant. (Vol 2 S 14.5.3 Pg 14.90).

Mammals - Beaver



EIS Review Comments



500

Description of VCs - Beaver

Issue: There are limitations in the surveys for beavers. Gaps include bank dens, surveys along the

proposed transmission line and south bank access roads, which appear to intersect watercourses

and waterbodies.


Clarify (i) the extent to which bank dens were considered in the recent surveys and used to

calculate the number of beaver potentially affected by the project; and (ii) rationale for how far

upstream the tributaries were surveyed (e.g., expected impact lines).

(b) If bank dens, the proposed transmission line and south bank access roads were not surveyed,

please provide a rationale for why these areas were not included.



EIS Review Comments



App R 501

Assessment of impacts - Beavers

Issue: The probable outcome for beavers has been accurately described as adverse, however there

are a number of weaknesses in the assessment of impacts for beavers.

(i) it is unclear how bank denning beavers factored into the total number that might be affected;

(ii) Effects of construction and operations on habitat for beaver are said to be restricted to the

Peace River; this is not strictly accurate however, because effects will extend up the tributaries and

affect beavers in these locations (Vol 2, App R, S 4.2.2, Pg 253); and

(iii) it is unclear how suitable the reservoir and flooded tributaries will be for beaver, nor how many

beaver are likely to be supported in compensatory wetlands.

Concern: Half of the beavers in the Peace River between Hudson’s Hope and the Alberta border

will be lost with the project. The current estimates (loss of 335 beavers) suggest that development

will affect half of the beavers on the Peace River system. Some assessment is needed of the

regional context of impacts to beavers at a population level.


(a) Provide estimates of the percentage of bank dens, lodges and beavers that will be affected by

project development.

(b) Provide a population level assessment of beavers in the local and regional context (LAA and

RAA), including effects on bank dens and tributaries to the Peace River.

(c) Explain how the effects on beavers were determined in the EIS to be 'not significant and

reversible'. Include a consideration of the suitability of the reservoir and flooded tributaries and

proposed mitigation measures (see comment below).



EIS Review Comments



14.4.1 502

Mitigation measures – Beaver

Issue: There are no species-specific mitigation measures proposed for beaver, other than potential

moving of beavers, which has a high degree of uncertainty with regards to success (Vol 2 S 14.4.1

Table 14.15). The general mitigation measures have limited applicability for beaver, other than

maintenance of riparian vegetation wherever possible.

Concern: The EIS needs to be clear that mitigation measures for beavers have a low probability of

success.


(a) Comment on the suitability of the reservoir and compensatory wetlands as mitigating habitat for

beavers.

(b) Consider measures that could stabilize the banks to provide suitable habitat for beaver during

operations

Mammals - Fisher



EIS Review Comments



503

Description of VCs - Fisher

Issue: Although the proponent did a thorough survey of potential den trees in the LAA, the

interpretation of the data used to determine a criteria for “suitable rearing habitat” (upon which

the majority of the effects assessment was based) appears to be flawed and should be revised. The

criteria by which suitable rearing habitat was determined was based on measurements at different

spatial scales (i.e., stand- vs. home-range scale). That is, the criteria proposed uses, in part, the

average density of Tier 3 trees across the home range (0.225 SPH) to define suitable rearing habitat.

This is not equivalent to saying that all stands that are > 0.225 are suitable for reproduction. This

minimum density does not necessarily equate with stands suitable for reproduction. Thus, the

average density of Tier 3 trees within a home range does not necessarily translate to being the

minimum that would support a female fisher, so using this metric to estimate “suitable habitat” is

not justifiable.

Concern: Errors in baseline habitat suitability mapping compound through the assessment process

resulting in high uncertainty about the overall conclusions, specifically the estimation of Potential

Effects and Residual Effects.


(a) Rerun the analysis to correct mis-interpretation of scale in the assessment in the identification

of suitable reproductive habitat.

(b) Recalculate density of den trees within fisher home ranges (see Details).

(c) Undertake a moving-window analysis to show where the mean density is high enough to support

female reproductive use. (d) It is

an over-statement to say that cavity tree surveys reflect 'suitable habitat'. Reword to say 'suitable

reproductive habitat' throughout the document. Use the density of Tier 3 trees that occurred in

stands used by the radio-tagged fishers rearing to identify suitable rearing habitat (Site C and KPF

dens).



EIS Review Comments



14 504


Issue: An assessment of seasonal habitats for fishers does not seem to have been adequately

performed. Substantially more analysis of the considerable site-specific telemetry data could be

used to develop seasonal resource selection functions that would have provided for a much better

assessment of potential effects (E.g., build upon/revise existing RSFs for fishers developed for the

Kiskatinaw region). Why not use the habitat models from the Kiskatinaw, updated with existing

telemetry data to develop specific RSFs for rearing and resting habitat for the LAA and RAA?

Concern: The assessment does not sufficiently meet the requirement for the examination of

seasonal habitat use, other than some element-scale reporting of reproductive dens and rest sites

in winter versus non-winter periods. It only focuses on reproductive habitat - which is where most

effect will occur but there are a number of other habitat-related factors associated with project

development that could affect fisher populations - movement, foraging, resting habitats and should

be included in the assessment. The Proponent has the data to support this work.


(a) Provide resource selection functions to evaluation probability of use for the full range of

seasonal habitats in the LAA and RAA (including movement, foraging, rearing and resting habitats)

to develop predictive models for assessing impacts.

(b) Conduct an assessment of impacts that includes the full range of seasonal habitat uses and not

just reproductive habitat.



EIS Review Comments



505

Description of VCs – Fisher

Issue: There are errors in the analysis of plot level data. FPP/PCP comparisons are only relevant

within stand types (i.e., site series/structural stage combinations), not among stand types, as seems

to have been done in this analysis. The analytical design that should be used is that of Weir and

Corbould 2008: 90 (Vol 2 App R Pg 95).

Concern: FPP/PCP comparisons do not hold true when all plots are lumped because they are

confounded by stand-scale habitat attributes. Thus, you can't compare the FPP/PCP in one stand

type with a pair from a different stand type.

Request that the Proponent rerun the analysis using an estimation that correctly incorporates

stand scale factors

(a) Why were there a different number of PCPs than FPPs in each stratum? If they were paired

plots (as indicated in Section 1.3.2.4), then there should be equal numbers in each, because each

FPP would be paired with a PCP in each VRI polygon in which the radiolocation occurred (Vol2 App

R Pg 110 Table 1.3.12). (b)

FPP and PCPs habitat evaluation results need to be stratified by ecosystem/structural stage (this

was the basis for the pair-wise comparison). Stand-scale habitat factors confound any comparison

between the FPPs and PCPs. Without considering stand-scale factors, these comparisons are

uninformative and potentially misleading

References: (Vol 2 App r Pg 111).Richard D. Weir and Fraser B. Corbould June 2008 PWFWCP Report

No. 315 Ecology of Fishers in the Sub-boreal Forests of North-central British Columbia



EIS Review Comments



506


Issue: Cavity-bearing tree surveys used a negative binomial distribution to estimate measures of

central tendency for the density of Tier 3 trees in each stratum, instead of a zero-inflated Poisson

(or zero-inflated negative binomial) model, which seems to be more suited to the data as described.

Also, the measure proposed to evaluate aggregation of cavity-bearing trees could be explained by

the fact that some ecosystems produce more Tier 3 trees than others. Thus, this metric may not be

the best for estimating "clumpiness".

Concern: The use of inappropriate statistical methods can result in misleading outcomes.

Request that the Proponent : Revise the analysis using appropriate statistical methods or provide a

rationalization for a negative binomial model and use the spatial information in the surveys to

provide a better estimate of aggregation.

(a) (Vol 2 App R Pg 116) The decision to group would confound your results, if you expect

ecosystem/struct stage to be the best stratification criteria? "increasing your sample size" shouldn't

be the justification for grouping them together - you need to consider the effects of introducing

bias and chance error when deciding to group strata.

(b) Did you evaluate means and variances to consider which strata to lump, or an ecological basis?

(Vol 2 App R Pg 116)

(c) Perhaps evaluating the count data with respect to neg-binom or Poisson distn would allow for a

better evaluations of aggregation. Since the location of the Trees along the transect were recorded,

why not use nearest-neighbour measurements to assess this?



EIS Review Comments



507

Description of VCs – Fisher

Issue: The amount of reproductive habitat in the landscape is overestimated because the definition

of 'suitable' is too coarse. Habitat is defined as either suitable or not without gradation (ie., stands

are identified only as suitable or not). Data on the density of cavity trees across the different strata

should be used to better inform this section.

Concern: Overestimation of the amount of reproductive habitat may result in an underestimation

of impacts and residual effects.

Request to the Proponent: Re-run the assessment of effects using a corrected estimate of suitable

reproductive habitat.

508


Issue: Data on the dens used by the radio-tagged fishers is not included in the cavity-tree survey

description and compared to the observed values of fisher repro dens (n=51).

Concern: Including data on actual fisher dens would provide some support for the contention that

the trees surveyed during the cavity-tree surveys look an awful lot like real den trees.

Request that the Proponent clarify whether the actual dens were used in the cavity tree

assessment. If they were not, please include this data during reassessment.



EIS Review Comments



14 509

Assessment of impacts - Fisher

Issue: The scale of much of the analysis for fishers is too simplified and too small to adequately

assess potential and residual impacts (i.e., focussed in the LAA). As with other wide-range

carnivores, the impacts of development extend outside the LAA to include the RAA. This is done in

some portions of the assessment, but not all. For example, Table 14.13 just lists how much will be

removed, not how much is available (both within the LAA and RAA). This is particularly an issue for

the assessment of the loss of reproductive habitat, where the coarse nature of the classification

does not allow for a thorough evaluation of the quality of habitats lost. More detailed assessment

and reporting is needed at the LAA and RAA scales.

Concern: The scale of reporting may result in an underestimation of impacts and residual effects.


Provide a table with the area in each of the cavity tree survey stratum in each zone within the LAA

and RAA (impacted, not impacted) (b)

Evaluate and predict the loss of reproductive denning opportunities on both the individual fishers

and the entire population.



EIS Review Comments



14 510

Assessment of impacts - Fisher

Issue: The EIS states no separation of populations across the reservoir based on genetic studies

(therefore assume same population). However, one would not expect any recent changes in gene

flow associated with past developments (i.e., reservoir development, flow regulation) to be

expressed within the timeframe at which past impacts occurred (~40 years). Because of this, the

EIS makes a potentially flawed argument or at least should state that there is no HISTORIC

separation in the population.

In addition to the assumption that gene flow is not affected, the consideration of the effects of

fragmentation seem to be fairly narrow in its spatial scale (i.e., impacts on stand-scale

fragmentation to individuals). At larger scales (ie., regional, landscape), changing the Peace River to

a reservoir is also a substantial fragmentation process for both individuals and populations (Vol 2, S

14, Pg 14-26).

Concern: The effect of habitat alteration and fragmentation of the reservoir on the regional

population does not seem to be addressed for the furbearers. Converting a 300-500-m wide river

to a 1-2 km wide reservoir may restrict gene flow within the population beyond what has been

historically observed.



EIS Review Comments



14 510

Continued


(a) Estimate how much the gene flow might be reduced from the 1940s, when the river froze in the

winter, to the 1970s when the river remained open, to the proposed open reservoir.

(b) Clarify the data used for this estimate and how it was calculated. Please report the likelihood of

detecting a difference, given that one existed, for a sample of 51 individuals (Vol 2 App R Pg 116).

(c) Provide justification (e.g., reference to scientific literature) as to why the reservoir is not

expected to impede movement of fishers across the landscape.

(d) Estimate potential population-level effects of the decrease in gene flow caused by this type of

habitat fragmentation. Kyle, C. J. 2002. Genotyping of re-introduced Williams Lake fishers (Martes

pennanti) and the identification of unknown individuals post-release. Unpublished report prepared

for Ministry of Water, Land and Air Protection

14 511

Mitigation measures - Fisher

Issue: The EIS does not explain why the proposed prescriptions are expected to mitigate losses (Vol

2 S14.4.1 Pg 14-56).

Concern: An estimation of residual effects is not possible without an evaluation of the

effectiveness of mitigation measures on specified impacts.


Explicitly identify what loss factor each measure is attempting to mitigate.

(b) Given that the efficacy of artificial den boxes for fishers are unknown and loss of rearing habitat

is listed as a potential effect of development, other mitigation measures should be applied in

addition to den boxes (see Details). Since information has already been collected on Tier 2 trees,

why not try adding the holes necessary to facilitate formation of den trees, particularly in

depauperate stands?



EIS Review Comments



14 512

Estimate of residual effects - Fisher

Issue: A thorough assessment of the net residual effects is not really calculated, as the mitigation

plan does not outline concrete mitigation results. Which leaves for a weak assessment of residual

effects. They are not really characterized or documented, just broad statements about what could

occur with the habitat loss. There is a lot of data available that could be used to create a more

quantitative analysis.

Concern: A careful and defensible estimate of residual effects is needed to determine whether

there will be a significant adverse effect to fisher as a result of the Project.

Request the Proponent provide a more quantitative analysis of residual effects that incorporates

baseline data and includes the revised methods for suitability mapping and other inputs detailed in

earlier comments.

App R 513

Estimate of residual effects - fisher

Issue: The method used to estimate residual effects would be more defensible if the assessment

was based on the proportion of each animal’s home range that will be impacted by development

rather than the number of radio tagged fishers whose home ranges overlap the LAA (Vol 2 App R Pg

228).

Request that the Proponent revisit their methods of estimating residual effects. The EIS states the

effect is 0.72 fishers, this appears to be incorrect as the Project will affect the proportion of the

home range of 6 fishers.



EIS Review Comments



14.3.2 514

Estimate of residual effects – Fisher

Issue: Section 14.3.2 (Vol2 Pg 14-44) doesn’t predict what the potential effects of

construction/operation will have for displacing fishers. The assessment overlooked impacts

associated with habitat alienation from development - e.g., the proposed road will go through high

value fisher habitat. Access by trappers will also be increased, which will increase mortality risk.

Concern: It is particularly important to consider the disturbance and alienation of good habitat

downstream of dam associated with construction/operation. The amount of disturbance and

displacement affects habitat effectiveness and is an important component of any assessment of

residual effects.


(a) Outline all of the effects on fisher including potential for displacement due to road development

and use and increased mortality risk due to increased trapping pressure.

(b) Consider developing a predictive model to assess how much the construction and operation of

the facility would decrease habitat value. There is ample data to use in an RSF model to assess

these effects. Recommended monitoring follow-up: Monitoring of fisher harvest, follow up studies

of other mitigation (CWD piles, arboreal rest sites), also invest in research trials to understand

manner in which natural cavities form in Acb and At to develop programs to expedite development

of these features.



EIS Review Comments



14 515

Assessment of cumulative effects - general

Issue: The Cumulative Effects section appears to simply list other projects that occur within the

RAA with no concrete estimation of effects to the VCs. The probability of a cumulative effect will

vary by species/habitat issue but the EIS makes blanket statements irrespective of the species that

might be affected. Statements like “A cumulative effect is not expected” need some additional

information to be supported.


Provide a more quantitative analysis that details potential cumulative effects by species or species

groups. More information is required.

(b) Please clarify whether the EIS considers the possibility of cumulative effects regardless of

whether there were any significant residual effects of the project. If not, please justify this

approach. Examples of what's been omitted: Seismic exploration and danger tree falling will greatly

reduce the availability of reproductive dens for fishers across the landscape and will result in a

considerable cumulative effect for this VC. Forest harvest, road building, and danger tree falling

will greatly reduce the availability of reproductive dens for fishers across the landscape and will

result in a considerable cumulative effect for this VC.

14 19 24 516

Given the sampling approach (pair-plots sampled within stands)this conclusion may not be

appropriate

14 38 6 517Please change “carrying capacity” to “expected density” as it is not know what the carrying capacity

of the area is.

14 38 15 518

Recommend changing to “The abundance of marten suggests that fur-harvest may not be

substantially reducing the marten population.”

14 39 2 519

As it is uncertain whether gene flow will continue at the same rate with a reservoir. Recommend

changing “south sides of the river form” to “south sides of the river historically formed”.



EIS Review Comments



14 49 8 - 9 520 Reference should be Naney et al. 2012?

14 64 Row 2 521Fishers aren’t explicitly identified, although they are previously. Mortality can be mitigated by not

clearing during March – June (as mentioned elsewhere in document).

14 82 22-23 522

Please clarify the following statement: “Residual effects of mortality during operations are not

expected for migratory birds, non-migratory birds, raptors, bats, fur-bearers, or ungulates, and are

not discussed.” - They seem to be discussed in the following sections.

App R 87 Para 4 523

Fisher citations incorrect throughout documents. Kiskatinaw study citations should be Weir and

others 2011 (density, Citation: Weir, R. D., E. C. Lofroth, and M. Phinney. 2011. Density of fishers in

boreal mixedwood forests of northeastern British Columbia. Northwestern Naturalist 92:65-69.),

2012 (reproductive habitat; Citation: ), 2013 (spatial and genetic relationships, Citation: Weir, R. D.,

E. C. Lofroth, M. Phinney, and L. R. Harris. 2013. Spatial and genetic relationships of fishers in boreal

mixed-wood forests of north-eastern British Columbia. Northwest Science 87.)

App R 88 Para 3 524

Citation should be Weir and others 2004: Weir, R., F. Corbould, and A. Harestad. 2004. Effect of

ambient temperature on the selection of rest structures by fishers. Pages 187-197 in D. J. Harrison,

A. K. Fuller, and G. Proulx, editors. Martens and Fishers (Martes) in Human-altered Environments:

An International Perspective. Springer Science+Business Media, New York, New York, USA.

App R 89

Section

1.3.2.1

and

others

525

“Trap” or “trapping” should not be used to refer to live-capture activities. Trapping is used

elsewhere in the EIS to mean killing a furbearing animal and harvesting its pelt. Instead, use live-

trap, livetrapping, or capture to indicate that the animals were captured then released for clarity

and consistency

App R 90Para 4,

last line526

Should read “hair with attached follicle roots”

App R 93 Line 7 527Citation should be Weir et al. 2011 and LFD for that study was 10 days.



EIS Review Comments



App R 94

Para 2,

last

sentenc

e

528

Consider employing the same methodology as Weir and Corbould (2006) and Weir and others

(2011) and use the empirical data that was collected on this study to generate a effective radius for

the Site C dataset.

App R 94Para 4,

line 5529

Please define “den type”. Does this refer to natal, maternal or cavity?

App R 94 Para 5 530

Consider changing this statement to “When the transmitter on a radiotagged animal indicated that

it had not moved for 8 hours and the animals was presumed to have died”

App R 95Para 4,

sent 3.531

The analytical design to which this refers is that of Weir and Corbould 2008:90, which doesn't

appear to be used in this analysis.

App R 99 Para 2 532

Please clarify if any samples were collected from trappers in 2012.

App R 100 Para 5 533

This needs to be reworded. For example: "We identified ecosystem units and structural stages that

were known to support reproductive dens for fishers in the BWBSmw (Weir et al. 2012). We then

stratified these combinations of ecosystem units and structural stages based upon the presence or

absence of balsam poplar in the ecosystem unit and age of the stand (young: <80 years old; mature:

>= 80 years old). The result was that we sampled 4 strata for cavity-bearing trees.”

App R 101 Para 1 534Reference should be Weir 2010.

App R 101 Para 2 535Reference Jenness 2008 for Longest Lines extension.



EIS Review Comments



App R 101

Table

1.3.2 &

1.3.3

536

Please clarify these 2 tables to reduce confusion, they don't identify the stratification units used for

the analysis. E.g.:

1) young - Acb absent,

2) mature - Acb absent,

3) young - Acb present,

4) mature - Acb present

App R Part

7. S 1.3.2.7101 537

Cavity tree transects were 333.3 m in length. Please provide some detail justifying this distance;

e.g., one side of a 1 km Swedish triangle.


Please consider rewording this paragraph as it is currently confusing. There seems to be

considerable confusion as the sampling are called both quadrats (which they are) and transects

(which they aren’t) in various places throughout the document.

App R 103 Para 2 539Please define what is meant by “architectural”

App R 103Para 3,

sent 3540

Move this sentence to the first paragraph on this page. It will explain things better if the reader

understands that the Tier 1 and 2 trees were assessed using variable-area quadrats, whereas the

Tier 3 trees were assessed in 1-ha fixed area quadrats.


This paragraph appears to be saying that BC Hydro estimated Tier 3 density for each age strata

(young, mature), moisture strata (mesic, moist) and for age-moisture strata, however this is

unclear. It is also unclear what happened to the Acb-age stratification. Please clarify.

App R 104 Para 1 542Please explain what information the resulting comparisons provided.

App R 104Para 1,

sent 1543

Please define the treatment classes.

App R 104Para 3,

sent 1544

Please provide data (or references) to support the statements.

App R 104 Para 5 545Capture rate is usually expressed as captures/100 trap-nights (e.g., Weir and Corbould 2006, Weir

et al. 2011)

App R 105Table

1.3.6546

Is the +/- the range, SD, or SE?



EIS Review Comments



App R 106Para 1,

sect 2547

As this is discussed later, consider reporting the capture rate of American martens for both the

south and north portions of the study area

App R 107 Para 3 548 Please clarify if these are mortalities of untagged animals.

App R 110Para 4,

sent 2549

Please clarify if these are paired plots, only 56 pairs of plots were conducted.

App R 114 Para 2 550Consider not using the word relative, otherwise the average values of these trees found at random

points should be included.

App R 115Para 2,

sent 1551

Note: Weir et al. 2011 had 16.3 fishers/1000 km² for the March 31st period.

App R 115Para 2,

sent 2552

reference should be Weir and Corbould 2006. Citation: Weir, R. D., and F. B. Corbould. 2006.

Density of fishers in the Sub-boreal Spruce biogeoclimatic zone of British Columbia. Northwestern

Naturalist 87:118-127.

App R 116Para 5,

sent 1-2553

Evidence for these statements is needed, such as descriptive statistics, assignment tests, etc. E.g.,

He, Fst, Dlr, Structure assignment tests.

App R 117Table

1.3.30554

It isn't clear which of the ecosystem codes correspond to the Acb present, Acb not present strata.

Please clarify where the "mesic, young" etc strata came from. It appears that the intent was to

have Strata as the first column and have the age and ecosystem association as footnotes - Please

clarify and correct if necessary

App R 118

Para 1,

last

sent

555

Please Include the data from this study as well

App R 118

Para 2,

last

sent

556

Unless a comparison is being made, please consider reporting the SD (not SE) and n for each.



EIS Review Comments



App R 119 Fig 3.7a 557

Please consider converting this from a histogram to a table that includes mean, SD and n for each

tier and stratum. This would provide a succinct summary of all data, which is missing from the

histogram.

App R 120Para 2,

sent 2-3558

Should this not be "more than 1" not "groups of" - from the methods it doesn't seem that "groups"

were identified on the transects, other than by tally. A spatial component (e.g., distance along the

transect) would need to be analysed to be able to comment on the "groupiness" of the trees. From

the data as presented.

App R 121 Para 1 559Please define "high densities of cavity bearing trees"

App R 121Table

1.3.35560

This table could be explained a bit better... it appears that this was figured out by how much area

was in each of the 4 strata in each home range, multiplied the area in each stratum by its estimated

density of Tier 3 trees, then estimated the total number of tier 3 trees by tallying the amount

projected in each stratum in each home range. Perhaps explain this in the text, or add another 4

columns to the table (for the area/number of trees in each stratum for each fisher).

App R 121Table

1.3.35561

Suitable REPRODUCTIVE habitat needs to be defined in the column label as "Area within home

range where >0.xx Tier 3 trees/ha occurred" (or whatever is the cutoff as identified after addressing

comment above).

App R Part

7. S 1.4.2.1123 562

The Technical Study Area is unclear on Map 1.6.23.

App R 228Throug

hout563

Consider replacing “suitable habitat” in this section with “suitable reproductive habitat”

App R Part

7. S 1.5

Map

1.6.45564

b) The fisher study area is referred to on this map. Since this map focusses on large carnivores, this

is somewhat confusing.

Mammals - Large Carnivores



EIS Review Comments



14 565

Description of VCs - Cougars

Issue: There are gaps in information about Cougars in the proposed project area.

Concern: Additional information about Cougars and their status would provide a more

comprehensive assessment of potential impacts (or lack thereof) on Cougars.

Request that the Proponent provide additional information, including local knowledge where

available, about Cougars with reference to the provincial Cougar Management Plan. Include a

description of their current status in the Project Area and human-Cougar interactions and use this

information in a re-assessment of potential impacts on the species.



EIS Review Comments



14 566

Assessment of impacts - Grizzly Bears

Issue: The road density analysis for Grizzly Bears was only undertaken for the Fisher study area

which has only a very small overlap with the Rocky Grizzly Bear Population Unit (GBPU). The EIS

would benefit from an equivalent road density analysis for the entire 'Grizzly Bear-Occupied Area'

within the RRA (i.e., overlaps with the Rocky and Moberly GBPUs) and subset for reporting by

Landscape Units or adult female home range equivalents. TRIM and other Resource Road data

could be used to provide a more complete study.

Concern: Basing the road density analysis for Grizzly Bears on only a small portion of the Grizzly

Bear-occupied area within the RAA may misinform the assessment of impacts to Grizzly Bears

(displacement and mortality risk).


(a) Provide a rationale for why the road density analysis was limited to the Fisher study area rather

than the entire 'Grizzly Bear-Occupied Area' within the RAA.

(b) Recommend repeating the road density analysis to include the entire 'Grizzly Bear-Occupied

Area' within the RAA, reported by Landscape Unit and/or adult female home range equivalents.



EIS Review Comments



14 567


Issue: The EIS does not provide any assessment of potential incremental effects of the proposed

Project on the core Grizzly Bear habitat area to the North and the north-south linkage area itself.

There is an assessment of effects south of Peace Reach but this lacks an evaluation of overall effects

in the context of an objective to maintain north-south Grizzly bear population linkage across Peace

Reach. Factors such as increased recreational use by construction workers, incremental traffic

volumes and associated mortality risk on ungulates and therefore on Grizzly bears feeding on

ungulate carcasses, and other potential cumulative effects on Grizzly bear population linkage and

mortality risk do not appear to have been fully examined in the western part of the RAA and in the

larger area. A cursory examination of our Grizzly mortality history database shows a relatively high

concentration adult female mortalities on Dunlevy Creek (west of Hudson’s Hope, north of Peace

Arm) suggesting that there has already been a considerable negative influence on linkage through

area-concentrated mortality.

Concern: If core populations of Grizzly Bears to the north and south are healthy then occasional

dispersers may provide the genetic linkage that is a key part of our provincial and regional

objectives for Grizzly Bears. The potential for north-south linkage, already compromised by the

physiography of the Peace Canyon, is further likely to be compromised by the proposed major new

rock quarry (required for dam construction) just west of Hudson’s Hope.



EIS Review Comments



14 567

Continued


(a) Examine the incremental effect of the proposed Project on population linkage between the

Moberly and Rocky Grizzly Bear Population Units across Peace Reach. To be meaningful, this

cumulative effects assessment must include the 'Grizzly Bear Occupied Area' north of the Peace

River (outside of the RAA) comprising Management Units 7-36, 7-43 and 7-44 (the Cameron,

Graham and Halfway River drainages that flow into the Peace River from the north).

(b) Undertake a comprehensive, localized analysis of mortality history for the RAA + Management

Units 7-36, 7-43 and 7-44.

14 568


Issue: Regardless of road density(see above comments), it is not clear whether the EIS accounts

for the impact to Grizzly Bears of traffic volume and human behaviour along roads within the

'Grizzly Bear-Occupied Area' within the RAA.

Concern: Road density alone may mask the potential for human-bear conflict due traffic and

human behaviour along roads.


(a) Clarify whether there was any evaluation of traffic volumes or human behaviour along specific

road segments to identify segments that are more or less likely to lead to lethal encounters

between humans and Grizzly Bears.

(b) If an assessment traffic volume and human behaviour along roads was not done, please provide

this assessment.



EIS Review Comments



14 569


Issue: “...risk of grizzly bear mortality...will increase in construction areas in proximity to high-

quality food sources...”. However, on pg 232 of 347, the EIS notes “Resident grizzly use within

much of the project area is considered to be limited or not existent and habitat loss to the species is

not considered.”. Hence, are there high-quality food sources within/proximal to the project

footprint?

Concern: It is not clear whether there is high quality food sources in proximity to the proposed

Project is a risk to Grizzly Bears.

Request that the Proponent: clarify the apparently contradictory statements described in the

comment. Is the proximity of high-quality food sources to the project footprint of concern to

Grizzly Bears or is this a concern only to Black Bears?

14 570

Mitigation measures - Grizzly Bears

Issue: The EIS currently does not include proposed measures to mitigate increased mortality risks

and increased fracture of the north-south linkage for Grizzly Bears (see comment on incremental

effects on north-south linkage above).

Concern: Linkage and mortality risk are inter-twined. Any cumulative impact on mortality risk in

the Moberly or the southern section of the Rocky GBPU may affect the achievement of the

provincial objective to maintain a north-south Grizzly bear population linkage across Peace Reach.

This is because populations below carrying capacity experience less dispersal (there is less

motivation of sub-adults to venture far from their maternal home ranges as would occur naturally).

Request that the Proponent: Engage

in a direct discussion with the Province about (i) mitigation of potential impacts to the north-south

population linkage for Grizzly Bears (see comment above) and (ii) monitoring to determine if the

mitigation is being effective



EIS Review Comments



14 571

Mitigation measures - Bears

Issue: There is a need for a comprehensive Human-Bear Conflict Management Plan to minimize

impacts to Bears during construction and operations. Because Grizzly Bears occasionally occur

within and near the Project footprint (LAA), a Human-Bear Conflict Management Plan for this

Project must also include Grizzly Bears.

Concern: A conflict management plan is essential to minimize risk to worker safety and the

unnecessary killing of bears. Mitigating conflict with Grizzly Bears requires a higher standard of

conflict management planning than for Black Bears alone.


(a) Prepare and implement a comprehensive Human-Bear Conflict Management Plan prior to the

commencement of construction and operations (see Details); and

(b) Provide a comprehensive list of Grizzly Bear sightings for the 'Grizzly Bear- Unoccupied Area'

within the RAA to assist with effective conflict management planning. If the applicant is fully

committed to zero tolerance of any incremental Black or Grizzly bear mortality associated with the

provision of bear attractants, such Human-Bear Conflict Management Plans can be highly successful

when implemented. Effective prevention of conflicts and detailed conflict response protocols can

go a long way to bringing the incremental mortality risk associated with even such large

developments to near zero. In addition, comprehensive plans include mandatory worker safety

training, providing assurance to Work Safe BC and worker Safety Committees that bear-related risks

are at least minimized, if not eliminated. Provisions for bear proof (not bear resistant) food and

waste containment, electric fencing, complete waste incineration or bear-proof transport and so

on, all need to be included in the specific plans for each component of the development. The

Management Plan is the place to lay all that out in writing, for commitment for implementation by

senior BC Hydro approvers.



EIS Review Comments



14 572

Estimate of residual effects - Wolves

Issue: There is no reference to Wolves when characterizing residual effects.

Concern: A comprehensive assessment of impacts must identify all effects even if they are not

significant. The subject appendix acknowledges (pg 170 of 347) documented Wolf presence south

of the Moberly River off the proposed transmission line. Request that the Proponent review BC's

current Wolf Management Plan (2013) and provide a response with regard to potential impacts on

Wolves.

14 573

Selection of VCs - Caribou

Issue: Values assessed are considered appropriate. Mitigation is provided in Volume 1 for caribou

at West Pine Quarry, but this species is not mentioned thereafter in the EIS. It is agreed that

interaction with caribou will be next to nil, and therefore no detail on this species is required.

Concern: It is potentially confusing to provide mitigation measures for caribou but not include an

assessment of impacts for the species.

Ungulates



EIS Review Comments



14 574

Assessment of Impacts - Ungulates

Issue: Intensive field work has been conducted for ungulates; however, there were no data around

the transmission line and south bank access roads.

Concern: This data gap makes it difficult to fully assess the potential effects of these developments

on ungulates. The transmission line and access road have the potential to affect movement and to

increase mortality risk due to improved predator access and vehicular collisions. Assessment of

these factors is very difficult without data on the south bank. Request that the Proponent:

(a) Provide a rationale for the lack of data for ungulates around the proposed transmission line and

south bank access roads.

(b) Describe how the lack of data could affect characterization and estimation of effects on

ungulates, particularly with respect to movement and mortality.

(c) Complete an assessment of the effects of the transmission line and access roads on ungulates.



EIS Review Comments



14 575

Assessment of Impacts - Ungulates

Issue: The probable outcome for ungulates has been accurately described as adverse. However,

the EIS does not quantify the amount of habitat indirectly lost through disturbance and

displacement during construction. This indirect loss has the potential to continue into operations

around the dam area, access roads and transmission line, depending on levels of human use.

Concern: The effects of habitat alteration and fragmentation may have been underestimated

without assessment of habitat loss as a result of disturbance and displacement.

Request that the Proponent: Incorporate road avoidance into the habitat models for ungulates to

quantify indirect effects of the Project on habitat availability and displacement.

14 576

Mitigation measures - Ungulates

Issue: The proponent has identified supplemental feeding as a potential mitigation measure for loss

of ungulate habitat.

Concern: Supplemental feeding could result in damage of stored hay and other feed on

neighbouring farms, due to attraction of ungulates to certain areas. In addition, there is some

evidence that hay is not well-digested by deer and may increase mortality risk. Supplemental

feeding of wildlife is also contrary to provincial government policy.

Request that the Proponent: Remove this mitigation measure as it is against provincial

government policy.



EIS Review Comments



14 577

Mitigation measures - Ungulates

Issue: The EIS acknowledges that several thousand hectares of moose habitat, deer habitat, elk

habitat and ungulate winter range will be flooded. Further detail is required on mitigation measures

and follow-up monitoring plans.

Concern: Some level of conceptual detail with supporting references is needed to evaluate the

effectiveness of proposed mitigation measures and, therefore, the estimate of residual effects.

Request that the Proponent: Include an assessment of the suitability of BC Hydro-owned land (east

of the Halfway River and west of Wilder Creek) to mitigate loss of Ungulate Winter Range and

include this in the estimate of residual effects. Suggestions re mitigation of impacts to ungulates:

(a) The timing of clearing during the winter could result in disturbance of ungulates, particularly

within the Ungulate Winter Range. It is suggested BC Hydro consider the timing suggested within

the General Wildlife Measures to minimize impacts within the Ungulate Winter Range.

(b) Consider reducing Project-related traffic levels, where feasible, to reduce the mortality risk to

wildlife, especially ungulates.

(c) Consider directing funds to ungulate counts / inventories / ongoing monitoring of ungulate

species in management units bordering the Project area in recognition of the importance of

ungulates as game species to local residents and First Nations.

14.2 14-8 5 578

The table states that cougar was not observed during any study since detailed fieldwork began in

2005. However, this is in contradiction to Section 1.5.1 in Appendix R, Part 7, where the text states

that cougar tracks were seen sporadically during field surveys. Please clarify as it appears cougar is

present in the area.

Section 14 General Comments



EIS Review Comments



14.3 25 5-8 579


Issue: Section 14.3 Effects Assessment describes the assessment of the likelihood of mortality

resulting from the Project as follows: "The number of individuals hunted, poached, hit by vehicles,

or lost due to construction and filling of the reservoir is difficult to quantify. A qualitative

assessment of the likelihood of mortality based on the timing and frequency of activities and the

proximity of roads and other Project components to suitable habitats is included"(pg 14-25 lines 5 -

8).

Concern: A quantitative assessment of the likelihood of mortality would provide more robust

information about Project-related effects.


Consider quantifying the effects of habitat loss on numbers of individuals by using field data to

determine species densities.

14.3.2 41 3-13 580


Issue: The assessment focuses on disturbance and displacement resulting from headpond flooding

(pg 14-41 lines 3 - 13)

Concern: Disturbance and displacement are also expected to occur as a result of noise, traffic and

increased levels of human activity in the area.


Include more detailed consideration of the effects of disturbance and displacement on species

groups and species as a result of noise, traffic and increased levels of human activity in the PAZ.



EIS Review Comments



14.5.1Table

14.1969 581


Issue: According to EIS Guideline 8.5.2.3, characterization of Residual Effects is supposed to be

quantitative “where possible". In the EIS, tables summarizing the characterization of Residual

Effects (e.g., Table 14.19) do not indicate whether the inputs are quantitative or qualitative or how

these inputs were used to estimate the Residual Effect.

Concern: It is not clear what quantitative data was used (if any) to characterize Residual Effects and

how qualitative descriptors and quantitative data were used to estimate effects.


(a) Provide a description of quantitative and qualitative data used to characterize Residual Effects

(magnitude, duration, etc.), for each key species group (e.g., bats).

(b) How is the combined quantitative and qualitative information tallied up to characterize the

Residual Effects and form a basis for determination of significance? (What is “the math”?)

(c) What are the specific Residual Effects that are characterized for each of the key species groups

in Tables 14.19, 14.20, and 14.21? Is there another table summing up Residual Effects for each

species group (e.g., bats), for purpose of characterization?

(d) Provide summary tables in future iterations of the EIS that quantify Residual Effects and, from

that, "the math" to move from that quantification to a determination of significance. Provide a

rationale for each species group for determining what is significant or not.

8.5.2.3



EIS Review Comments



14.5.2 582


Issue: According to Sections 13.4.2 and 14.5.2, a Residual Effect becomes significant when: (a) a

species or ecosystem is currently designated (or candidate for) threatened and endangered status

and the Magnitude of the Residual Effect is characterized as 'High'; or (b) the species or ecosystem

currently has a lower listing (e.g., provincially blue-listed or SARA Schedule 1 special concern) and

the Magnitude of the Residual Effect is characterized as 'High', which may result in the key

indicator being elevated to a threatened or endangered status listing. “Significance” is reported in

Table 13.18 for 'Vegetation and Ecological Communities' as a whole and in Table 14.22 for 'Wildlife

Resources' as a whole and not for individual species or ecosystems that may be threatened or

endangered or at risk of becoming so.

Concern:

The criteria used to interpret significance are too limiting. Under these criteria, a Moderate impact

on a red-listed species or ecosystem or federally-listed species would not qualify as significant.

Given that these are already entities for which there is considerable conservation concern this is

too conservative an approach. Similarly, the limitations attached to Blue-listed species and

ecosystems (only where Residual Effects are of High Magnitide and where the project changes the

status) are too restrictive. These species and ecosystems are characterized as such because of

recognized inherent vulnerabilities. A project does not have to result in a change in status (which

represents a dramatic shift) to be Significant, nor should the Residual Effects considered be limited

to those characterized as High.




EIS Review Comments



14.5.2 582

Comment Continued


(a) Explain whether the thresholds of determining a significant adverse effect for Vegetation and

Ecological Communities and Wildlife Resources only what is written in sections 13.4.2 and 14.5.2?

Provide a more detailed description of the method for determining significance, if one exists.

(b) If these thresholds are the only criteria for determining significance, how will the EIS identify

and address unlisted species that risk becoming listed as a result of the Project or moderately

impacted Red- or Blue-listed species whose conservation status becomes more uncertain?

(c) Provide a comprehensive reporting of the link between impacts, mitigation measures, Residual

Effects and determination of significance for each species assessed within each species group.

Explain assumptions and quantify uncertainties for each step in this process, noting how

uncertainties may compound from step-to-step. and the implications of this for the final estimate

of Residual Effects and determination of significance.



EIS Review Comments



14.7 103 7-21 583


Issue: The EIS Guidelines require specific detail to be provided for each Follow-up Plan; however,

this detail has not been provided in the outline of the Wildlife Resources Follow-up Plan in Section

14.7.

Concern: It is difficult to ascertain if proposed mitigation/compensation measures are likely to be

adequate and robust over the long-term without more detail about monitoring plans.


(a) Provide more conceptual details about the Wildlife Resources Follow-up Plan, such as

techniques, frequency of monitoring activities and length of time to monitor. The concept of

adaptive management should be incorporated into all monitoring with the understanding that the

design and implementation of alternative techniques/methods of mitigation/compensation

measures should be undertaken, if necessary.

(b) Consider replacing should with will with respect to what the Follow-up Plan and directed studies

might include (pg 14-103 lines 7 and 18).

(c) Clarify how the results of directed studies will be used (e.g., for adaptive management,

modification of construction schedule) (pg 14-103 lines 18 - 21).

App R Part

1, S 280 584

Please comment on the potential role of erosion during operations to result in further habitat

alteration and fragmentation.

App R Part

7. S 1.1

Throug

hout585

Please check subheading numbering, it seems inconsistent among levels. For example, the fifth

order subheading 1.1.1.1.7 is under heading 1.1.3.1.

App R Part

7. S 1.5

Map

1.6.45586

There are several roads that are located in areas mapped as 0 km/km2 road density.. Please clarify

this inconsistency

Section 15 - Greenhouse Gases



EIS Review Comments



15 8 1 - 17 587

Please clarify why there is a section comparing reservoir emissions to natural lakes. Even if the river

has the same emissions level as a lake, which is unlikely, the volume is much smaller. This section

and similar discussions should be removed as they are potentially misleading.13

15

General

comme

nt

588

Please revise this section as In general, the section and especially the technical appendix are

confusingly written, difficult to follow at times, and repetitive at other times.13

15 11 5 - 9 589

The assumption of 100% permanent storage of merchantable carbon removed from the site is

inaccurate. Based on BC averages and the offset protocol, 25% storage for 100 years is a reasonable

assumption. See page 79-86 in BC Government (2011) and Dymond (2012). Please adjust using 25%

storage. References: BC

Government 2011. Protocol for the Creation of Forest Carbon Offsets in British Columbia. Victoria,

B.C., Dymond, C.C. 2012. Forest carbon in North America: annual storage and emissions from

British Columbia's harvest, 1965-2065. Carbon Balance and Management 7(8).

13

15

General

comme

nt

590

There are a number of places where the project emissions and impacts are underestimated:

Emissions associated with land-use change do not include burning of biomass which generates

methane and nitrous oxide in addition to CO2 and can create health (smoke) problems to nearby

communities. Extensive burning was carried out during clearing of the NW Transmission line and

caused great concern to professionals, public servants, and the public. Burning of harvest residues

contributes a significant portion of the GHG emissions caused by deforestation and forest

management. It is estimated for the NE BC, when forest is cleared for conversion to settlements,

burning of the harvest residues doubled the CO2 emissions in the first year. The burning should be

incorporated in both the emissions estimates and the plans to mitigate them.

13



EIS Review Comments



15

General

comme

nt

591

There are a number of places where the project emissions and impacts are underestimated:

The current conditions analysis assumes that the vegetation has a net 0 flux, i.e. is carbon neutral,

and this assumption is not explained or justified. There are a number of scientific papers

demonstrating the area as a net biological sink (e.g. Chen et al. 2003, Stinson et al. 2011).

Therefore, assuming it is neutral will underestimate the impact of the project. References: Chen,

Jing M., et al. 2003. Spatial distribution of carbon sources and sinks in Canada's forests. Tellus

B 55.2 (2003): 622-641. Stinson, G, W.A. Kurz, C. Smyth, E.T. Neilson, C.C. Dymond, J. Metsaranta,

C. Boisvenue, G.J. Rampley, Q. Li, White, T.M., and Blain, D. 2010. An inventory-based analysis of

Canada's managed forest carbon dynamics, 1990 to 2008. Global Change Biology, Vol. 17 Issue 6,

p2227-2244

13

15

General

comme

nt

592

There are a number of places where the project emissions and impacts are underestimated: The

emissions associated with land-use change due to infrastructure around the flooded area appear to

be an after-thought. The methodology changed to more of a back-of-the envelope approach,

ignoring emissions from non-merchantable forests, non-forest vegetation types, dead organic

material and soil. This analysis should be redone in the same manner as the EOSD vegetation cover

types within the flooded area. Plus it is estimated for the NE BC, when forest is cleared for

conversion to settlements, burning of the harvest residues doubled the CO2 emissions in the first

year. The burning should be incorporated in both the emissions estimates and the plans to mitigate

them

15

General

comme

nt

593

In general, the EIS provides a decent first attempt at quantifying GHG emissions and removals for

the current conditions and the Site C project, especially since there is no standard practice for land

and flooded areas. 13



EIS Review Comments



15.4 18-22 594

In year 1 of the deforestation and flooding the land-based emission are estimated at about

1,000,000 t CO2e (Figure 15.2). These are not low and the estimate should be higher. In that year,

Site C will certainly show up as a significant source in the provincial GHG emissions report. How will

these emissions be mitigated? Note that spreading them out over a number of years would not be

helpful to the atmosphere. Can the biomass be used for other purposes such as bioenerg,

landscaping, or another use where the CH4 emissions are reduced.

15.4 18-22 595

The stated criteria for low magnitude GHG emissions is <105 t CO2e/yr (Table 15.10). The stated

emissions are 45,000 t CO2e/yr for 8 years + 43,000-58,000 t CO2e/yr for 100 years. The emissions

are approximately 500 times the cut-off for low, therefore they should be characterized as high.

Please correct.

15.1 and

15.46 & 23 596

The report should compare the Site C emission estimates with those currently reported in the

Provincial GHG emissions report. For deforestation: 660-1,159 t CO2e/ha/yr and For “mature”

hydro reservoirs: 42,000 t CO2e per year and 1.6 - 5 t CO2e/ha/yr.

15.1.5.15-6 &

15

10-19

and

Tables

15.2 &

15.4

597

Note that on page 15-15, line 30-31 there is a sentence describing carbon losses due to

transmission lines and new roads. Why are these “losses” included under Operational emissions?

Are they converted to CO2e and added in the totals? 13

15.1.5.15-6 &

15

10-19

and

Tables

15.2 &

15.4

598

The spatial boundaries for land-use change only include the inundated area as reported in Table

15.4. However, a much larger area will be deforested, including for all of the physical works listed in

Table 15.2. Please include the following: i) In Table 15.2 add columns stating the temporary

affected area and permanently affected area (i.e. land-use change) for each of the rows. ii) In

section 15.1.5 explain why some GHG emissions from land-use change were not estimated how

they might influence the conclusions.

13



EIS Review Comments



15.1.5.2 599

15.1.5.2 Greenhouse gas calculations include a 30m buffer around the project activity zone over a

100 year period. See table 15.1 for a summary of how key issues were addressed by the approach. 9.2.1 Geology, Terrain

and Soils

App F 5.2.2 29 600

According to the summary and technical reports, estimated changes in GW elevations are based on

2D steady-state GW modeling using SEEP2/W, which was calibrated to existing water levels. The

calibrated conductivities appear to be generally consistent with media conductivities shown in

Figure 2 (GEOMETRIC MEANS OF HIGH-CONFIDENCE HYDRAULIC CONDUCTIVITY VALUES). It is

noted, however, that reported conductivity values exhibit a wide range of values. For example,

conductivity of shale and silty shale varies by more than 6 orders of magnitude from about 1(-6) to

1(-12) m/s.

A sensitivity analysis should be included that discusses whether and to what extent model

predictions of GW elevation change are affected by model parameters (conductivity, anisotropy

ratio), over a reasonable range of parameter values.

9.3.3

601

EIS Guidelines state: "This will include....Regional seismicity and seismic hazard" There is mention of

increasing seismic activity reported by the Oil and Gas Commission in Volume 2 Appendix B part 2.

Please clarify how this has been taken into account.


and Soils

App B 602

EIS Guidelines state: "Sources of information regarding geology and terrain stability conditions

within the technical study area will include:"- Part 1 and Part 2 of appendix B do not reference

existing soils and terrain inventory in the area including Soils of Fort St John Dawson Creek Area

(1986) and 1:20 000 bioterrain mapping of the Blueberry Area in the Fort St John TEMVRI inventory

(request by BAPID = 5608 through [email protected])

Part 2 of Appendix B references previous shoreline and landslide inspections. These are not

mentioned in section 11.

For example, the clay fan at Bear Flat was misidentified as glaciofluvial plain on the terrain map yet

it is mapped correctly in the Soils of For St John Dawson Creek Area map.


and Soils



EIS Review Comments



App B, Part

1603

Terrain mapping in Appendix B part 1 and the related PDF maps do not fully reflect the geotechnical

findings (materials and mass movement processes) outlined in Appendix B part 2, even though the

TSIL (terrain survey intensity level) takes geotechnical field visits into account.

Terrain stability is the only management and decision theme that has been produced from the

terrain mapping. The project would benefit from updating the terrain mapping in light of the

geotechnical findings (e.g., the scarps of the Cache Cr. slide are mapped as glaciolacustrine in

contrast to the detailed landslide description).

The project would also benefit from terrain hazards and constraints maps derived from the terrain

mapping, such as: erosion potential, drainage, landslide runout, rock fall runout zones, fans subject

to flooding and debris flow hazards, zones of slow mass movement, etc. These themes would

inform safety plans, more accurate road construction and maintenance cost estimates, evaluation

of inherent stability and erosion sensitivities on the project. Targeted extension of terrain

investigation up the tributary streams could identify areas of potential debris damming and flooding

potential for further investigation.

Information gained through terrain mapping and geotechnical investigation should be better

utilized and cross referenced by other sections (soils, agriculture capability, ecosystem inventory,

forestry operations, recreation planning, safety planning, etc.).


and Soils

604

EIS Guidelines state: "Sources of information regarding geology and terrain stability conditions

within the technical study area will include: Topography and digital elevation models generated

from aerial photography and from LiDAR; "- DEM and LiDAR data was not provided to the province.

Images of this information were provided as a base map in PDF format. An overview of the area

was viewed in 2D with BGC on March 7, 2012 with a focus of large landslide features, slope above

the dam site, and potential geohazards along the reservoir shoreline.


and Soils



EIS Review Comments



App B2 2.35 of

13010 - 11 605

It is noted that in some areas geotechnical drillholes are spaced at greater than 5kms.

Overestimation of Impact Lines could potentially restrict future and existing development in areas

adjacent to the reservoir. This would be contrary to the recommendation contained in the EIS by

the BCUC “...that every effort be made to minimize the disruption caused by the Project by

acquiring as little land as possible.” Please provide rationale for the adequacy of geotechnical

investigation of the underlying soils stratigraphy throughout the project length to justify the

limitations to future and existing development imposed by the impact lines.

9.2

App B2

2.4.1

6 of

1306 606

Report terms of reference state, “...outlining the requirements for monitoring and updating of the

reservoir impact lines.” There appears to be no firm recommendations or details of the monitoring

and maintenance program associated with the reservoir slopes and mitigation areas. Please

provide the details on the recommended monitoring and maintenance programs for the project. 9.2

App B2

2.4.3

7 of

1302 - 10 607

Impact Lines will restrict the use of some existing structures. Please clarify when sufficient

information will be made available to make structure-specific decisions with respect to whether or

not a structure will be impacted.

9.2

App B2 13.1118 of

13011 - 14 608

3rd bullet - Please quantify and provide additional information as to the "period of time"

structures would be permitted to remain. 9.2

App B2 13.1118 of

13011 - 14 609

bullets 2 & 3 "pending site-specific geotechnical assessments" Please clarify who will be

responsible for the costs of these geotechnical assessments. 9.2

App B2 13.1118 of

13033 - 35 610

Report states a berm/slope recontouring is proposed to protect properties within the District of

Hudson's Hope from “...shoreline erosion and to offset changes in slope stability caused by the

reservoir.” Do the proposed works fully compensate for any adverse affects to the global stability

at private properties and Highway 29? Please provide technical evidence that the global factor of

safety for existing structures and Highway 29 is not reduced post reservoir construction works and

filling.

9.2



EIS Review Comments



App B2 13.1120 of

1305 - 8 611

Are the existing development guidelines for residential setbacks within the District of Hudson's

Hope still valid following proposed slope changes for the reservoir berm/slope recontouring? Has

the applicability of the existing development guidelines been confirmed by the original Engineer of

Record responsible for the development guideline recommendations? 9.2

App B2 13.1120 of

13016 - 17 612

Report states that, “...some existing segments of Highway 29 are currently situated on marginally

stable slopes.” The Stability Impact Line (shown in impact line Map #25-26) between the Halfway

Hill and Watson Hill along Highway 29 is located on the upslope side of the existing highway. Does

the presence of the reservoir result in an adverse effect on the global stability for this section of

Highway 29, located south west of the Bear Flats area. If the global stability is adversely affected,

what are the proposed measures to offset this effect?

9.2

App CFigure

1 613

Please consider revising map theming as the BC Hydro owned land dose not readily stand out at

this scale.

App B 614

Appendix B part 2 characterizes erosion and slope stability issues based on reservoir edge geology

and quantifies the expected loss of lands at the shoreline at the 5 and 100 year marks. However,

this volume of sediment influx into the reservoir/potential downstream water courses does not

appear to be considered as an impact on fish or fish habitats (in: 058_v2_s12_fsh-fsh-habitat.pdf).

There seems to be a lack of integration of studies when assessing impacts.


and Soils



EIS Review Comments



App B 615


carried out, including: Predictions of potential for groundwater changes, including sensitivity to

changes in recharge rates and other aquifer characteristics, that could alter the potential for

landslides;" - Issues of wind erosion and dust coming from the exposed beaches during lower

water levels in the Williston Reservoir - N end near the Tse Kay Dene community are documented

on BCHydro website and referenced in section 11.1.3. How are issues relating to dust caused by

slope failures and wind erosion of the fine textured sediments along the banks or beaches of this

proposed reservoir, which could create dust and potential air quality issues for residents at Hudson

Hope/Ft St John (report only seems to consider dust from construction activities as per 172_v2_s11-

11_fig_11-11-09_max-prdctd-30day-dust-wth-bckgrnd.pdf ), being addressed? Clarification needed

re: how this reservoir is different from the other? Have potential dust issues (from reservoir

shorelines) for residents at Hudson Hope & Ft St John been considered?


and Soils



EIS Review Comments



19 616

It is noted throughout this document, that in many areas, consultation and information sharing

between BC Hydro and First Nations is ongoing, therefore not all concerns may yet have been

expressed by First Nations nor all concerns addressed by BC Hydro. It will also not be known until

consultation is complete, what accommodation will be required to address First Nations concerns.

As several of the Natural Resource Sector agencies would be responsible for ensuring First Nations

consultation is adequate on authorizations related to the construction and operation of the Project,

should an EA certificate be granted we request the following

a) that BC Hydro ensure that concerns expressed by First Nations on the project are documented,

not only on issues at the Environmental Assessment level, but at the permitting level as well.

b) That BC Hydro document accommodations that have been proposed by BC Hydro and identified

or requested by First Nations.

19 19 19-4 617

The approach to addressing key issues has been developed through consideration of traditional

land use studies. Although the confidentiality issues surrounding the TUSs are understood,

wherever possible please provide this information to the Natural Resource Sector Agencies for

consultation purposes on applications for authorizations related to the construction and operation

of the Project.

Volume 3

Section 16 - Local Government Revenue - Not Reviewed

Section 17 - Labour Market - Not Reviewed

Section 18 - Regional Economic Development - Not Reviewed

Section 19 - Current Use of Lands and Resources for Traditional Purposes



EIS Review Comments



19 19.4.5 618

Many of the detailed mitigation plans, management plans and follow up measures have not yet

been completed and included in the EIS. It is anticipated that many of these plans will assist in

accommodating concerns raised by First Nations and will be critical for First Nations consultation on

applications for the construction and operation of the Project. Please clarify when these plans will

be available and how these plans will be shared with First Nations once complete.

19 19.4 19-82 619

Please provide further evidence to support the statement that there will only be a “temporary” and

not a permanent reduction to moose availability within the LAA.

19 19.6.2 19-111 620

The effects from many recent operational activities are not reflected in the baseline conditions. It is

noted that the residual effects from other projects are not known. It is also noted that a number of

current and proposed activities (eg: Gething coal mine, Portage quarries, Septimus wind, Spectra

gas plant) in the area appear to be not included in the cumulative effects assessment. More detail

could be provided on specific residual effects of the many projects and activities that were

reviewed.

20 621

Assessment identifies agricultural lands within the Stability impact line, but discounts potential loss

of land impacts due to stated low probability of land slides. No probability assessment is

mentioned, yet there exist 3 large slides bordering the valley. Bank areas are mapped as slope

stability class IV and V (potentially unstable and unstable). Therefore, impact on agricultural

capability lands is underestimated - an estimate of the probable land area that could be lost due to

landslides would be informative.


and Soils

20 1 10 622

Consider including reference to Agriculture Land Commission Act (ALCA) Section 40 - Reference of a

matter to the board, as an option (Public interest).

Section 20 - Agriculture



EIS Review Comments



20 623

Existing soil and land capability maps are included or referenced. Additional soils assessment in the

field was done. Consideration of permanent loss of agricultural land was carried out by class and in

comparison to the province, the Peace Region, and the Peace Valley. Four mitigation measures

were proposed including a proposed compensation program to increase ag productivity. However,

comparison is not made to the historic state prior to installation of the first 2 dams. This is

important information that should be included for context.


and Soils

20 20-27 12 624

Has BC Hydro given consideration to the possibility that there could be diversion of local labour

away from agriculture to construction?

20 20-28 9-11 625

Note that the estimate of 25% loss of Class 1 & 2 lands within the Peace River valley excludes the

islands even though these will be inaccessible for agriculture or range (p 20-28 lines 9-11) and

excludes potential loss of land due to landslides - therefore this value is an underestimate. The

reported loss represents 2.1%+ of the most productive lands in the Peace River Region and 1.0%+

of the most productive lands in BC. (as per the table).


and Soils

20 626

The executive summary fails to mention the Ha of agricultural lands lost, or the lost proportion of

total available land in the Peace Region, giving the impression that this is insignificant. The exec

summary needs to provide tables summarizing the impacts on all VECs. 9.2.1 Geology, Terrain

and Soils

20 38 17 627

There is no mention of this impact on Agricultural lands in the Exec summary. >>Vol 5 Section 38 -

Summary of potential residual effects (p 38-17) categorizes this permanent loss of high quality

Agricultural land as 'Insignificant'. Please provide additional rationale for considering a loss of 1% of

provincial class 1-2 agricultural lands as insignificant. Please include the details of impacts in the

Exec Summary.


and Soils

20.15 628

Table 20.15 shows that 7663 ha of land with agricultural capability is located within the impact

lines, however section 11.2.3.7 shows total area within the impact lines = 9648 ha. What accounts

for this inconsistency/discrepancy?


and Soils



EIS Review Comments



20.2 13 37 629

Information Requested - “Agricultural land use, determined from recent air photos...” historic

land use should also be taken into account when classifying agriculture capability.

20.1.3 2 1 630

Please Clarify - Table 20.1 (line 2 of table) – "which has been updated with current fieldwork and

technical analysis of soil conditions, climate conditions, and crop suitability" Please describe the

approach used and provide rationale. Also, please consider providing data from Canada Land

Inventory Agriculture Capability maps and discuss changes to the classification

20.1.3 2 1 631

Table 20.1 (line 4 of table) – “The agriculture assessment takes into count lands both currently

developed and undeveloped for agricultural uses, by considering land capability (irrespective of

current use) ” – In other places in the EIS (eg page 20-5 Table 20.3 and page 20-6 line 33) it states

that ag land utility is used as an indicator. Please clarify as there appears to be some inconsistency.

20.1.3 2 632

There are potential benefits that are not listed including increased road access (eg south project

access road) and potential for irrigation, consumption of local produce by camps, that may be

worthwhile to include in the discussion.

20.1.4 5 1 633

Correction: Table 20.3 Row 1/column 3. Land capability ratings are described by: Kenk, E. and I.

Cotic. April, 1983. Land Capability Classification for Agriculture in British Columbia. MOE Manual 1.

Surveys and Resource Mapping Branch, Ministry of Environment and Soils Branch, Ministry of

Agriculture and Food. Kelowna, B.C. 68 pp. ISSN 0821-0640 not by the Agricultural Land

Commission.

20.1.4 11, 12 1 634

Please clarify if the wildlife impacts on agricultural operations during dam construction and

operation have been discussed and dealt with in the EIS. If not please consider adding.

20.1.4 5 1 635

Please clarify key indicators- Table 20.3 Row 2/column 2 – Effects on individual farm operations: the

impacts in changes to wildlife/waterfowl habitat and the potential impact on agricultural operations

are not indicated as key indicators although are mentioned as a key issue in Table 20.1.



EIS Review Comments



20.2.3 20-13 15-24 636

Please explain the rationale for jumping from Land Capability to Agricultural Suitability? The

methodology used in the Okanagan and Similkameen Valleys (Gough et al. 1994) has not been peer

reviewed in the context of use for the Peace River Valley. Two additional references related to this

subject were not used “Soil Management Handbook for the Lower Fraser Valley” (Bertrand et al.

1991), as well as “Land Suitability Rating System for Agricultural Crops: 1. Spring-seeded small

grains.” Pettapiece et al 1995.

20.2.3 20-15Table

20.6637

Please provide rationale for exclusion of oats rye wheat, canola, peas from class 4 and 3

respectively. Local experience indicates those crops (except for Canola due to some climate

portion) would be suitable up to class 4.

20.2.3 14, 15 1 638

Table 20. 5 is an acceptable discussion for Suitability not Capability as it is labelled. The reference

source for Table 20.6 is not given. Volume 3 Appendix D Agricultural Assessment Support

Documents does not contain any discussion of how Land Capability was transcribed to Crop

Suitability. Please address and correct these issues.

20.2.4 20-15 10 639

Please provide more discussion/evidence of how the term “Agricultural Utility” is defined and how

this relates to the previous discussion/interpretation of Land Capability and Crop Suitability. No

reference documentation was found to clearly demonstrate how the concept of agricultural utility

was defined or determined for individual parcels.

20.2.420-15,

20-16

4 – 14,

1 - 14640

The section describing “Agricultural Utility” appears to ignore or discount the potential for non-soil

bound agricultural operations (i.e., intensive poultry or greenhouse production) on smaller parcels

which could become viable based on the availability of local market (population) and energy

(electrical). Please include an explanation of whether this was considered or disregarded.

20.2.7 20-19 1 641

Clarification required: Was the total size of each operation determined? The relevance of those

operations classed as unknown might become clearer if the aerial extent of all 34 operations was

known. Tables 20.25 and 20.26 provide more detail and should be referenced as part of Table 20.7

20.2.7 20-19 1 642Table 20.7 - Please quantify the data source and the size/extent of these operations. Are these

Cadastral properties or individual operations?



EIS Review Comments



20.2.7.2.2 20-21

1 – 3,

14, 25-

28

643

Data suggest that non-soil bound agricultural operations – e.g. poultry, have been considered– yet

in discussion of agricultural utility these same classes of agriculture seem to have been excluded.

Please explain this discrepancy and correct accordingly.

20.2.8.1 20-23 18 644

Note: In June 2011, British Columbia (BC) was provided notice of CFIA’s intention to withdraw

provincial meat inspection services after December 31, 2013, requiring a provincially run meat

inspection system for Class A and B abattoirs.

20.2.8.2 20-23 23 645Please include other communal settlements in the region, specifically the Macabees at Mile 95

20.2.8.3 20-24 10-33 646 Request further discussion on this section

20.2.9.2 20-25 22-31 647Data used for surplus calculations seems to include non-human grade food in

production/consumption stats. Please clarify.

20.2.9.2 20-26 4 - 5 648

Future consideration related to climate change and population change is alluded to elsewhere in

Vol 20/Section 3 – yet future economic feasibility of alternate agricultural enterprises that may be

supported by factors of population/market demand, climate change and availability of inputs are

not considered.

20.2.9.2 20-26 1-8 649 Please clarify the source of the sugars.

20.2.9.2 20-26 1-8 650The information about livestock being finished outside BC should parallel how grain is handled in

this section as well.

20.2.9.2 20-26 4 - 5 651

What is the basis of the statement regarding poultry and dairy operations being “not currently

economically feasible” in the Peace Region? Pelase provide evidence to support this statement.

20.3.1.3 20-28 9-11 652

The concept of permanent loss of land from use by agriculture needs further review. Islands that

exist prior to reservoir filling and are unusable for agricultural purposes would fall into the “low

utility” definition. However, if an island is created by reservoir filling and the island is not accessible

or useable (e.g., agricultural utility is low), then is this land not a permanent loss?



EIS Review Comments



20.3.1.3 &

Table 20.2

20-3,

20-28

to29

653

Section 20 and Table 20.2 do discuss the potential impact of decreased precipitation during the

spring and summer (as noted in 163_v2_s11-10_fig_11-10-14_prdctd-chngs-in-prcptn-mnthly.pdf)

resulting from the presence of the reservoir, but it is unclear of increased wind speeds (which will

affect evapotranspiration) are also considered. Implications of decreased moisture availability to

crops during their active growing season, and potential crop losses or increased irrigation costs are

not discussed.


and Soils

20.3.1.3 ,

Table 2654

Islands in the reservoir with Agriculture Capability are not included in the lands lost, even though it

is likely that these lands would be inaccessible for the purposes of agricultural operations. This

then under-estimates total area with Agriculture Capability that is impacted.


and Soils

20.3.10.1.1 20-62 19 655

Projects for the compensation fund need further discussion. The conversation about options should

precede the decision about the scope of options. The EIS appears to have concluded that a regional

approach is needed. The ALR is a provincial resource that suggests a provincial approach.

20.3.10.1.120-62

20-6328 – 41, 656

The discussion of improvements and support for agriculture to mitigate the permanent loss of

agricultural land refers to the Environmental Farm Plan Program (EFP) in several places as a

mechanism to fund activities. The concept of the EFP and its complementary Beneficial

Management Practices (BMP) program are a means of assessing a farm operation and the types of

activities that the farm should undertake to mitigate agri-environmental risk. A Site C mitigation

program should be designed to provide mitigation for the loss of agricultural production in a

broader sense, not the mitigation of agri-environmental risks in a narrow sense like the EFP/BMP

Programs.

20.3.10.1.1 20-64 1 – 38, 657

The list of projects the proposed fund may support presupposes some ideas and may be best

generated with the agriculture sector as proposed in the document, at a later date. Perhaps higher

levels bullets provide enough detail?

20.3.2.1 20-34 1-3 658 Is this flooding from freshet/storm generated events?

20.3.2.1 20-34 1-3 659 Can mitigation not be put in place (i.e., dykes) to prevent this flooding?



EIS Review Comments



20.3.2.1 20-34 5 660Reference is made in the text to a section 20.3.2.4 supposedly containing a summary table. Section

20.3.2.4 is missing.9.2.1 Geology, Terrain

and Soils

20.3.2.1 20-34 1-3 661The flood impact area has total area of 203 ha – what is the anticipated inundation depth and

duration that was used to calculate this?

20.3.2.1 20-34 1-3 662 What is the flooding risk and potential?

20.3.3.220-38,

39, 40all 663

Discussion of loss of by agriculture utility class needs more review.

20.3.4.1.2

20-41

(and 20-

71)

35 664

“Relocation of suitable quality soils” concept raises some considerable concerns. The

appropriateness of moving topsoil to areas without a good handle on the site specific

needs/concerns is questionable. It may make sense to salvage topsoil from areas that are going to

be flooded and store that soil for use in reclamation of temporary disturbance area. Invasive

species management will be critical. As noted in section 20.4.2 the use of topsoil for local

reclamation is more advisable than whole sale transfer.

20.3.4.1.2 20-41 37 665“will be implemented...” Discussion of how to apply compensation fund is premature.

20.3.4.1.2 20-42 2-27 666

Has BC Hydro considered providing hydrants for water access by agriculture, fully realizing that

there would be water licensing issues to sort out? This could be similar to the water stations at

Blackfoot park, on the Peace at the Clayhurst Bridge.

20.3.4.1.2 20-42 2-27 667The hydrant water access idea applies not only to irrigation, but for many other agriculture uses,

such as crop spraying, livestock watering, etc.

20.3.7.1.2 20-53 11-17 668 What will the process be to identify individual producers whose current practices are impacted by

wildlife?

20.3.7.1.2 20-53 11-17 669How will agriculture wildlife (including waterfowl) impact issues be attributed to dam construction?

Dam operation?

20.3.7.1.2 20-53 18-24 670How will crop maturity issues be addressed? Is it expected that crops or varieties suitable for this

land will change due to microclimate?



EIS Review Comments



20.3.7.1.2 20-53 18-24 671How will impacts on producers(especially renters) be handled in terms of compensation and

assistance in education?

20.3.7.1.2 20-53 11-17 672

Please include discussion that construction activities may also affect the migration and movement

patterns of ungulates and wolves leading to increased agriculture wildlife conflicts through the term

of the project.

20.3.7.1.2 20-52 1 673

Table 20.28 Mitigation of Operation-Specific Effects Farm yard and field access - Is this also being

negotiated with rental land access issues? Specific examples like access to Peck’s bottom fields

currently in grain crops, and changes in access due to stream back up. Will site specific details be

worked out with the renter and owner?

20.3.7.1.2 20-53 11-17 674

The loss of habitat and changes in use may result in longer term wildlife depredation issues for the

region. Is there a mitigation strategy, and any linkages drawn with or to current compensation

program?

20.3.8.1

20-54

and 20-

55

11- 37

and 1 -

20

675

Please provide more discussion and evidence of how the term “Agricultural Utility” is defined and

how this relates to the discussion/interpretation of Land Capability and Crop Suitability and apply

those definitions to the land base. The discussion in these sections needs to be revisited.

20.3.8.4 20-57 1 676

Table 20.31 - The table omits all non-soil bound agriculture (including livestock or greenhouse)

operations. Future agriculture development should consider the impact of climate change and

population/market growth.

20.4.1 20-67 11-28 677It should be noted that wildlife impacts could occur during construction also.

20.4.1 20-67 11-28 678More discussion is needed about compensation for the adverse affect on economic opportunities.

20.4.1 20-67 11-28 679

Please clarify if agriculture land offers have been made for producers inside of the impacted area

(i.e. land for producers outside of the impact zone of equal value)?



EIS Review Comments



20.4.1 20-68 680

Table 20.37: Please clarify who manages “agricultural compensation fund in evaluating and funding

irrigation and drainage improvements and in evaluating and funding other opportunities to increase

production on remaining lands”?

20 68 681Please clarify if it is expected that micro-climate will affect downstream operations

20 68 35 682Please clarify if it is expected that water levels will affect downstream operations.

20 68 35 683Please clarify if the quality of quarries and other material site been inventoried for invasive plants

presence.

21 684There is no mention of soils in this section. 9.2.1 Geology, Terrain

and Soils

21 8 / 13 33 / 32 685

Correction - The Timber Supply Review for the Dawson Creek TSA is anticipated to be complete in

2013 and the Timber Supply Review for Fort St. John is anticipated to start in 2013.

21 1 18 686

Correction: Section 8 (1) of the Forest Act stipulates that the chief forester must determine an

allowable annual cut at least once every 10 years after the date of the last determination, not 5

years as indicated in the EIS.

2121-1 to

21-19All 687

Mill capacity and harvest trends are presented with the indication that the merchantable volume

cleared from the Project area can be utilized by the existing timber processing facilities. Please

provide additional information on BC Hydro's contingency plans to utilize or dispose of

merchantable timber volume should exisiting facilities not be able to fully utilize merchantable

timber volume harvested as a result of this project.

Section 21 - Forestry



EIS Review Comments



2121-1 to

21-19All 688

There are some errors noted in Table 21.8 in the total volume under licence in both the Dawson

Creek & Fort St John Timber Supply Areas that require correction. Updated information is available

from the Ministry of Forests Lands and Natural Resource Operations upon request.

21.1.3 2 1 689

PTable 20.1 (line 5 of table) – Regional food self reliance is included, but it does not appear that ag

products exported from the region are dealt with. Please clarify and provide rationale for this

approach.

21.3.5

21-10

to 21-

11

All 690

Please ensure that section 21.3.5 is reviewed for changes resulting from updates to table 21.8

based on updated information provided by the Ministry of Forests, Lands and Natural Resource

Operations.

21 All 691 Throughout - Correction - AAC is Allowable Annual Cut (not annual allowable cut)

22.1.2 3 1 692a) Has BC Hydro confirmed that all well heads are above the new water level, and that any wells

that are to be inundated are appropriately sealed?

22.1.2 3 1 693

Has BC hydro or contractors completed geotechnical assessment work to understand whether any

wells, sealed in the vadose zone, would remain sealed once the surrounding sediments were

saturated?

22.1.2 3 1 694

On Table 22.1 the key issue that “the project would limit fracking activity in the vicinity of the Site C

dam site due to seismic concerns” lists an approach that BC Hydro would not request restrictions.

Whether BC Hydro requests restrictions in fracking may not address the key issue. Has the OGC

been contacted to satisfy whether fracking could be safely conducted in the vicinity of Site C? Has

BC Hydro evaluated whether normal faults and deep seated basement faults could interact with

hydraulically generated fractures? If so, what would the impact be?

Section 22 - Oil, Gas and Energy



EIS Review Comments



22.1.2 3 1 695

There are deep seated basement faults in the area that appear to control the geography of the

Peace River. Saline aquifers underlying the Peace River in this region appear to be significantly

fresher than elsewhere according to the Geoscience BC Montney Water Project Aquifer study of

2012 (http://www.geosciencebc.com/s/Report2011-11.asp). Has BC Hydro evaluated whether

raising the water level will drive fresh water into to saline aquifers? If so, what, if any would the

impacts be?

22.3.1 8 17 - 18 696

According to Canadian Association of Petroleum Producers, oil and gas industry expenditures for

the previous 8 years, not including 2009, totalled $37 billion, not $30 billion as indicated. - Please

correct

22.3.2 9 5 - 7 697

Correction: The Montney now accounts for almost 43% of BC’s total daily gas production, not 26%

as indicated. - Please correct

22.3.3 9 10 - 21 698

Note comment made in Volume 2, Section 11.3 regarding separation of Oil and Gas Commission

(OGC) permits and approvals discussed in this section (surface tenures) versus Ministry of Energy,

Mines and Natural Gas-issued title (subsurface).

The well and facility information in this section (Section 22.3.3) contains some errors in interpreting

the OGC data sources: wells with the status “wag” in the OGC database are Not water-air-gas

injectors. They are wells that have well authorization granted (“wag”) but have not yet been

drilled. This results in more wells being identified than physically exist (Figure 22.3). OGC data

indicates NO Wells with ground level elevation below peak reservoir level elevation +461.8 m,

rather than the one well identified. Communication with the OGC is recommended regarding OGC

approvals, well and facility data, and surface tenure to land.

22.3.4 9 28 - 29 699

Clarification to correct intent of this information: All subsurface titles that fall within the Site C

Order-in-Council reserve are both advertised and issued with caveats advising of this, and these

caveats adhere to the titles throughout their duration.



EIS Review Comments



22.3.5 10 7 - 8 700

Clarification regarding accessing coalbed gas resources by directional drilling in future: A directional

drilling technique known as “slant hole” drilling may be used over moderate lateral distances

(approximately 600 metres) to access thick coalbed gas-bearing coals beneath the flooded area,

from the north bank of the river. Due to the great thickness of the coal measures, horizontal

drilling is not applicable; however slant holes can cross all the coals in the objective zone, with

lateral reach limited by the relatively shallow depths of the coal measures.

22.3.7 13 15 - 25 701

Clarification and correction of detail regarding outlook for oil and gas development affected by the

proposed Peace River – Boudreau Lake protected area, the Peace Moberly Tract (PMT - MEMNG

Information Letter TITLES-08-08), and the Area of Critical Community Interest (ACCI) -

http://www.ilmb.gov.bc.ca/slrp/srmp/north/peace_moberly/index.html:

Directional drilling to access existing subsurface title under the proposed Peace R - Boudreau area is

currently allowed (MEMNG Information Letter EMD99-01) and this policy is expected to continue if

the area becomes designated protected or a park. Development of a Sustainable Resource

Management Plan in the PMT or the ACCI may result in acceleration of subsurface oil and gas title

disposition and drilling. In this case the Montney Formation is expected to be developed by

horizontal drilling from multi-well pads.

22.3.7 13 5 - 8 702

Clarification: Development has curtailed in many regions in northeast British Columbia, but activity

within the Montney has remained relatively steady because of the liquids-rich potential.

22.3.7 13 5 - 14 703

Clarification: Lower natural gas prices over the past three years have reduced dry natural gas

activity in Alberta and parts of BC, but investment and activity has remained strong in a number of

areas in British Columbia’s Montney play that contain natural gas liquids (NGL).

22.3.712 &

13

29 - 22

and 1

- 4

704

Please provide the most recent National Energy Board and British Columbia Ministry of Energy,

Mines and Natural Gas estimates of undiscovered remaining conventional natural gas, and of

recoverable or marketable unconventional natural gas in the Montney Formation. These figures are

important to demonstrate the value of these resources to backstop the proposed mitigation

solutions.



EIS Review Comments



22.3.7 12 33 705

Table 22.8 - Updated CAPP number for remaining established reserves of Natural gas liquids (2010)

in British Columbia is 28,900 Thousand m3. Updated CAPP number for BC’s remaining established

reserves of Pentanes plus (2010) is 11,000 Thousand m3. - please correct

22.4.1 14 10 706

An apparent error appears on line 10: Oil and Gas Commission (OGC) data indicates NO wells with

ground elevations below the peak reservoir elevation +461.8 metres.

Communication with the OGC is recommended regarding OGC approvals, well and facility data, and

surface tenure to land. Note: Six wells, eight facilities, and 2.9 hectares of pipeline-right-of-way

exist within the Local Assessment Area

22.4.1 15 21 - 22 707

Request: Please include mitigation measures for oil and gas companies tenure holders adjacent to

the LAA. The proposed mitigation measures would apply to tenure holders within the LAA.

However, mitigation measures may also be required to address impacts to oil and gas companies

who hold tenure adjacent to the LAA and use Hwy 29 and the other petroleum development roads

in the area to access their lands. These companies may also be impacted by change in land use

associated with the development and construction of the Site C dam project.

22.4.1 13 37 - 39 708

While the proponent recognized the current status of oil and gas activity in the LAA, it should be

noted that current development in the area has been postponed due to low commodity prices.

When gas prices increase and/or LNG projects move forward as planned, gas development and

production activity will significantly increase. Realignment of Hwy 29 and the construction access

roads will have significant impacts for industry, in terms mobilization time and costs, and potentially

the pace and cost of development.

22.4.2 and

22.8

14, 15

& 19

31 – 41

1 – 19

25 – 35 709

Affect on Spectra Energy water intake in the Peace River, due to changes in water temperature as

well as increased suspended sediment : Increased river temperature will increase the number of

days Spectra Energy will be required to reduce operating capacity. Has BC Hydro developed a plan

to mitigate economic losses to Spectra Energy incurred from increased water temperature?



EIS Review Comments



22.4.4

15, 16,

17 &

18

30 – 38

1 – 27

1 – 12

8 – 11

710

Impacts on drilling access to subsurface title, proposed mitigation of these impacts by directional,

horizontal, and slant-hole (for coalbed gas) drilling are addressed in previous comments on Volume

3, Section 22. However, has the Oil and Gas Commission (OGC) been interviewed and supplied

comments regarding impacts on, and proposed mitigation solutions for, the surface activities that

the OGC regulates?

23 711

There is an outstanding question as to the specific requirements for BC Hydro's quarry/aggregate

extraction operations that will need to be addressed during the following Mines Act stages: Notices

of Work (NOW), Mine Permitting, and Reclamation Bonding. BC Hydro will need to work closely

with MEMNG Inspection and Permitting staff to discuss Mines Act Permitting and Inspection

options and considerations.

23 712

Please consider adding further detail on how extraction operations will be designed, operated and

reclaimed (e.g., Portage Mountain Quarry's pit slope, drainage, reclamation, etc.)

23 713

The EIS states that there were, "no mineral tenures in the LAA" (local area assessment).

It is MEMNG review indicates Coal and Mineral Tenures in the LAA. It is suggested that BC Hydro

conduct a final check against the tenure map and documentation as highlighted in comments made

in relation to EIS Section 11.3.4.

23 714

It should be noted that there are a few coal reports that fall within the Site C Project Area, These

Include report 894 (Knnecott) in the Farrell Ck Watershed that concluded seams were not

economically viable from a single drill hole. Also of note is report 577 (Cinnabar Peak Mines) for an

open-cut mine at Peace River Canyon.. It is worth noting that estimated cumulative coal

thicknesses of 14 to 18 meters and might be worth further comment within the EIS. Further

information is available on request.

Section 23 - Minerals and Aggregates



EIS Review Comments



23 715

There is an outstanding question about the application of regulatory requirements as it applies to

mining/quarrying for private, Ministry of Transportation and Infrastructure (MOTI) and BC Hydro

mining operations for this project. Addressing the issue of tenure, ownership, permitting,

reclamation, safety and the regulatory oversight of mining will be required during the course of the

Project. BC Hydro should work closely with MEMNG Permitting and Inspection staff to address this

issue and add further information to the EIS where appropriate.

23.1.1 1 16-35 716

Discussion of Acts – There is no mention of the BC Hydro Authority Act. This should be included as

it may have impact on applicability of other legislation.

23.1.4 4

Ln 7,

Table

23.2

717

“Identifies the Volume of aggregate that may be for other applications ” From Vol 1, Appendix C:

yield rates in quarries are as low as 20%. Please include discussion on the quality of material that

will be left for others and provide rationale.

23.3.1 7 7-9 718

“...at the 5% confidence level (a low level of confidence) occur in the LAA (Kilby 2004). At the 90%

confidence level (a high level of confidence), there are no deposits indicated.” Please provide the

standards or guidelines used.

23.3.4 10 4 719

“Future pit development...” Please clarify if this future pit development is for the project of for the

“Total aggregate consumption” of the previous paragraph. “...over the next two decades...” Please

provide rationale for this timeframe (Eg: MOTI plans for 50 years.)

23.4 23 11 720(Ln 9 “The first two aspects...” appears to refer to the 1st and 3rd aspect.) - this appears to be an

error, please correct.

24.1.1 2 18-40 721

All the changes listed in this section are related to the “use” of the resources. Even though the

“supply” aspect of the resource may have been dealt with in another section, it should still be

recognized and mentioned here that potential adverse effects will also impact the “supply” of fish

and wildlife populations, not only their “use”.

Section 24 - Harvest of Fish and Wildlife Resources



EIS Review Comments



24.1.1 3 27 722

Another important consideration is the replacement of river habitat for high-throughput reservoir

habitat. A survey of current users may indicate a lower perceived value of reservoir habitat, so that

the two areas are not weighted equally, meaning a significant VC loss overall. LGL 2009 (and

roughly, table 24-7) indicates that the vast majority of fishing effort is currently upstream of Site C.

To answer this properly, a proper stated preference survey (or some similar method) would have

been useful

24.1.1 3 10 - 12 723

The does not appear to be supporting evidence for statement “not anticipated”. Suggest it should

be “unknown”. Angling may in fact be a very attractive recreational activity for a workforce that will

stationed in camps at the project site.

24.1.1 4Table

24.1724

Second “Key Issue” under “Hunting Opportunities” should also include “and those non-game

populations which impact game species”

24.1.2 5 14 725

Statement is made that a Traffic Management Plan will mitigate effects on fish and wildlife harvest.

Looking at the plan in Vol 5 Sec 35 (pages 35-6 and 35-7) this plan deals solely with mitigating

impacts on wildlife from traffic-related causes. Wildlife harvest may also be impacted by increased

access into previously inaccessible areas. Wildlife harvest will still go on based on hunting

opportunities created within the regulatory framework, minimizing road mortalities does not

mitigate fish and wildlife harvest.

24.1.2 5 7 - 14 726

The text refers to Table 2 of Vol 2 Appendix A having rankings of 0 and 1. Looking at Table 2 it has

rankings of 0, 1, 2 and n/a. These rankings are not explained in the table, at least 2 and n/a are not.

24.1.1 5Table

24.2727

Under “Project Component and Activities” Hwy 29 realignment and worker Accommodation

Construction and Operations are not identified as impacting changes in fishing opportunities. This

may not be the case, please provide additional rationale to support this statement



EIS Review Comments



24.1.1 7Table

24.3728

It is unclear whether BC Hydro is going to examine spatial shift in effort or even if effort on the

Peace River in general is maintained (in terms of angler days). You may be able to maintain effort in

the region, but it may be spatially shifted to smaller populations (i.e. in lakes), potentially leading to

collapse of other, more vulnerable populations

24.1.1 7Table

24.3729

Please clarify if creel surveys are going to be conducted to monitor the change in catch

composition and effort.

24.1.3 7Table

24.3730

Please clarify if First Nations harvest levels for food and ceremonial purposes where considered as

an indicator, and provide rationale why it was excluded

24.1.3 7Table

24.3731

Under “Key Aspects” the “Opportunities” are being measured by metrics such as license sales,

trapping returns, etc. This approach is incorrect; many of these metrics are affected by a variety of

factors which may have little to do with opportunities or potential for harvest or recreation of fish

and wildlife resources. The table assumes a direct and causal relationship between “opportunities”

and current utilization.

24.2.3 9 40 732

You state that LGL 2010 includes information on spatial distribution of angling effort, but is not

reported, please include.

24.3.2.2 22Table

24.11733

Percent change figures in the last column do not appear to be correct, and it’s not clear if that

change is supposed to be calculated for the years 1999 and 2010.

24.4.1.2 30 39 734

Harvested fish are those that have been removed from the system, so yes, there won’t be an effect

on them, but there will be an effect on those fish that are still in the river. Perhaps what is meant

here is game fish populations. Please clarify



EIS Review Comments



24.4.2 31 27 735

Please clarify what is meant by changes in “public fishing areas”. Is it the number of public access

points or area of access points?

24.4.2.1 31 39 736

“Good navigational opportunities to support fishing” – unsure what this means, there will be more

surface area of water in the reservoir, but increased erosion may decrease the access to shore for

fishing-related activities (ex. angling from shore, camping, etc.). Please explain.

24.4.2.1 31 34-35 737

Given that a “fishing area” has not been defined, it’s not clear how the reservoir would provide new

ones both from the water and shoreline. Presumably there are many fishing areas from the

shoreline right now, and an even greater number from the water. There will be “new” areas

because it will be a totally different ecosystem, but that does not provide a quantitative measure of

this descriptor.

24.4.2.1 32 15 738

It is assumed that all fishing areas are equal, but while there will be an increase access to fishing

areas in general, access to highly used river fishing areas upstream has been removed, which may

be of intrinsically higher value to anglers than the reservoir. Due to its importance to the

community, this should be addressed and acknowledged

24 32 16 738

“In summary, the Project would result in a beneficial effect on fishing areas during operations.” -

this statement requires further rationale to support it in light of the identified effects or the project

that indicate otherwise.

24.4.2.2 32 24 739

Again, each species has been weighed equally, which is misleading. Surveys of anglers for species

preference and relative access to different species within the LAA may indicate that species whose

biomass decreases (such as walleye) may have a higher weighting than others, meaning that

although biomass increases, the total value of harvestable species declines. It may be that users

(anglers) will find that the new harvestable community is preferable to that in place now, Please

provide additional information to support the weighting.

24.4.2.2 32 30 740Consideration should be given to relative weighting of species and the weighting of how far and

where anglers want to travel to access various species



EIS Review Comments



24.4.2.1 32 11-14 741

Please qualify the statement “supports a wider variety of boats”. There may be new ice fishing

opportunities, but at best they may replace open water fishing that occurs presently during winter.

24.4.2.1 32 15-16 742

Please provide further rationale for this statement, and clarify what the metric used is.

24.4.2.1 32 6, 7 743Angling opportunities may not change, but angling pressure will be concentrated in certain

locations due to structures and restrictions.

24.4.3 33 13 744

What is the impact of trap and haul activities on fish populations, particularly bull trout? It is

understood from the Columbia is that survival is lower than other methods of bypass

24.4.4 33 26 745

Please clarify what is meant here, is it number of areas for hunting, access to them, etc.?

24 33 5 - 8 746

Please replace ...will mitigate...”

with “...will aid in mitigating...” as this statement implies that the identified mitigation measures

will be 100% effective.

24.4.4.1 34 20-21 747

Unclear statement, presumably if new roads are created, there would be changes to hunting

access.

24.4.4.2 35 5 - 6 748

Unclear of how the statement about current harvest level is related to displacement of ungulates

by construction activities.

24.4.4.2 35 8 - 11 749

Please clarify why black bears are excluded from large carnivores. Also, please explain what is

meant by “additive effect”, is this trying to portray an increase in numbers?

24.4.5.1 35 27-29 750

Full boater use assumes unrestricted access to the whole reservoir shoreline, This will likely not be

the case and should be clarified in the EIS.



EIS Review Comments



24.4.7 36 26-28 751

The term “population” in this case refers to human population, this was not evident until confirmed

by looking at the referenced report, adds ambiguity if not properly described.

24.4.7 37 13-15 752

Please clarify the spatial boundary that the Peace Region is meant to describe. Is this governments

(NRS agencies) administrative boundary. This conflicts with figures from Table 24.13. Please clarify

24.4.7 37 21-22 753

Please clarified how positive is measured in this instance.

24.4.8 37 24-28 754

Increased participation in hunting and harvest due to the project may result in regulatory changes

by the Ministry. Mitigation measures for this are not being considered because increased

participation is seen as a Ministry goal. However, in this case there is no choice of where the

increased participation is occurring and it may not be compatible with wildlife population levels.

24.4.9.1 38 18 755

Please clarify which regulatory tools will BC Hydro anticipates being used to restrict trapping.

24.5 451, Table

24.21756

There will not necessarily be a net positive increase in the VALUE of harvestable fish during

operations

24.5 48 3 - 6 757

The conclusion are not well supported. The use of "Beneficial” is subjective and not referring to any

specific aspect. There is no guarantee that fishing opportunities will increase, some aspects of

fishing will change, but opportunity is also used subjectively here. And it’s important to note that

the term “baseline conditions” implies that we’ll have the same ecosystem after the flooding, with

directly comparable attributes when in fact we have a river ecosystem before flooding and a

reservoir ecosystem after flooding.



EIS Review Comments



24.6.1 50 3 758

As a whole, the changes to public fishing areas and harvest may be within historic norms, but when

weightings are placed on various species and the relative access to get to them, there are certainly

significant changes outside of historic norms (i.e. some species will be lost in some areas).

24.6.2 53 25 759

As considered in the previous section, it is possible that anglers will move to other fishing

opportunities in response to changes in the harvestable community. This could potentially result in

changes to the regulations in those other areas (although they may be outside the Peace River) to

protect them from overharvest, which could be perceived as crossing the significance threshold.

24 all 760

Spatial information on effort and harvest has not been included. Please consider providing this

information if available.

24 all 761

Please provide rationale for the assumption that a reservoir is of equal value to anglers as a river.

24 all 762

Values differ between river and reservoir habitat. Similarly, there is higher value in catching a bull

trout than a kokanee, but overall harvest is the value examined. Talking to the resource users about

their perceived valuation of these components would be useful (and relevant), and could by used to

further define the VC's

25 1 36 763

List of legislation on this line should also reference the Forest and Range Practices Act.

25 1 39 764consider replacing "approved and established" with "Authorized"

Section 25 - Outdoor Recreation and Tourism



EIS Review Comments



25 2 18 764

“...Changes in outdoor recreation and tourism infrastructure including:...” - Consider including

identification of the impact the dam structure to “Water travel passage” as a bullet under this

heading.

25 30 17 765“Boat access restricted permanently at the Site C dam site for safety reasons” Reference should be

made to specific figures in section 26 Navigation (26.4.1.1) for clarity.

25 32 38 766

“...shoreline recreation within the Peace River and tributaries through to the Alberta...”

Consider re-wording to: “...shoreline recreation within the RAA, Peace River and tributaries

through to the Alberta...”

25 33 16 767

“The involvement of Aboriginal groups is also supported” Suggest also including other groups such

as Provincial Government agencies, local governments and user groups.

25 33 23 768Please Clarify - identified hunting camp on private or Crown Land? If on Crown Land is this a

tenured interest that will be impacted?

25 33 6 - 9 769

While mitigation for loss of recreation opportunities and impacted sites are identified in the EIS, it

appears that the majority of the identified mitigation will not come into effect until after

construction of the project is complete. Impacts to recreation will begin to occur as soon as

construction of the Project is initiated, and will persist throughout the muli-year construction

period. Has BC Hydro identified mitigation measures to offset impacts to recreation opportunities

during the construction period of the project? If not please include discussion of this in the EIS.

25.5 36, 37 N/A 770

The mitigation proposed in Table 25.17 is not considered to adequate to offset the proposed

removal of 28 river-based recreation sites within the LAA and the change in current recreation

opportunities from river-based recreation to reservoir-based recreation, especially considering the

Recreation Plan is to be funded but not implemented or monitored by BC Hydro, and no ongoing

monitoring to evaluate the effectiveness of the mitigation is proposed. To increase the success of

the mitigation strategy, BC Hydro should consider broadening the area where the fund could apply

to allow for development of alternative river-recreation based sites in the South Peace. BC Hydro

may want to also consider implementation and monitoring of the plan to evaluate the effectiveness

of the mitigation and an alternative strategy should the mitigation be determined to be

unsuccessful.

16.7.3



EIS Review Comments



26.1 26-1 1 771Table 26.1 mentions vessel clearances for navigation for Highway 29 bridges. Does the pipe-arch

structure at Dry Creek on Highway 29 also need navigable clearance?

27.2.2 3 3 772

This paragraph makes reference to the Project Interaction Matrix found in Table2 of Vol 2-App A,

which shows the Project Activities that were ranked as “0” i.e. not interacting with visual resources,

including the activity “Right-of-way vegetation maintenance” shown on p.11 of the appendix.

Depending on how this maintenance is carried out, it could impact the visual resources so the “0”

ranking may not be appropriate for this activity. Transmission line corridors are permanent features

on the landscape and the usual harsh straight boundaries used for the clearing soften over time

with the growth of vegetation by reducing the contrast in shape and colour. Eliminating all the

vegetation using herbicides simply re-create the same visual impact over and over. A better

alternative from a visual impact point of view is to eliminate only the deciduous and coniferous

trees and leave as much of the shrubs/ground cover intact. Please provide additional information

on how this activity will be carried out and re-assess its ranking and mitigation measures in light of

the comments above. If alternative measures need to be taken, keep in mind that these would

apply only to the portions of the transmission line corridors within the scenic area polygons found

on the Ministry’s Visual Landscape Inventory data warehouse.

27.2.3 3 8 773

The 5 receptor sites chosen as key indicators are fine but their number and coverage are

insufficient. All are from Highway 29 and none offer views to the dam site itself, unlike what is

stated in Table 27.3. Recommend two additional Receptor Sites be added: one on the reservoir

upstream from the proposed dam and one just downstream. These water-based points are

accessible to the public so should be considered valid for analysis and visual simulations.

Section 26 - Navigation

Section 27 - Visual Resources



EIS Review Comments



27.3 4 24 774

For clarity, please consider rewording the sentence starting on line 24 as follows: "Visually

Sensitive Areas are areas of specific concern for visual quality and usually include ratings on their

Existing Visual Conditions.”

27.3 4 24 775

The baseline viewpoints were selected from the Visual Landscape Inventory (VLI) but none of the

viewpoints selected in the EIS include the VLI viewpoints on the Peace River. When the VLI was

completed in 1996, it was done not only from Highway 29, but also from the Peace River by jet

boat. These viewpoints are shown in the provincial VLI database but were not included in the EIS.

Some of these key river viewpoints should be added to the baseline viewpoints and analyzed similar

to how the ground-based viewpoints were treated.

27.3 4 31 776should more sites be added, the number of receptor sites and Figure 27.3 will need to be updated.

The same adjustment needs to be done on page 27-11, line 7.

27.3.1 5 15 777

This sentence is not technically correct and should be clarified. The VLI does provide ratings for

Existing Visual Conditions (EVC) but not for "each" Visually Sensitive Area. Only those polygons

inventoried in the field are rated for EVCs, among other things, like the ones on the south side of

the Peace River. The proponent should be aware that field mapping was only originally done for

the south side of the river and broad visual polygons on the north side of the river were added later

as an office exercise based on contour line interpretation as the Peace River viewshed was deemed

important by river users and various planning tables. Although broad in nature, these Visually

Sensitive Areas have the same legal status as the detailed areas inventoried in the field. Since these

broad polygons have no rating under the EVC field, it appears that they were inadvertently

excluded when producing the map in Figure 27.2 which is likely to create confusion. Please add the

missing polygons to the map and add a new entry in the legend explaining that no EVC ratings are

available for those broad polygons.

27.3.1 Table

27.55 21 778

The wording in the table was slightly modified compared to the source document it makes

reference to, please restate the caption at the bottom of the table to say: "Source: Adapted from

BCMOF (1997)".



EIS Review Comments



27.3.1 5 23 779

Please add a caveat to this paragraph explaining that using the EVC ratings as an input to the

baseline description do not present the complete picture of the existing visual condition since many

of the ratings are missing from the VLI. Equally important is the fact that the EVC ratings that are in

place represented the visual conditions in 1996, so the conditions have likely changed in the past 17

years.

27.3.2 Table

27.67 1 780

Should water-based viewpoints be added as requested, the baseline viewpoints listing will need to

be updated accordingly.

27.3.4,

Table 27.79 N/A 781

This table is intended to provide the definitions of the VQO ratings used by the Province of BC and

makes specific reference to the source document where these definitions are coming from and so

the wording should not be changed. It is also noted that these definitions are the old VQO

definitions used under the Forest Practices Code. The source document referred to in the text is

the old Visual Impact Assessment Guidebook that is currently being updated. Since 2004, the legal

VQO definitions that are entrenched in FRPA's Forest Planning and Practices Regulation, Section 1.1

have been used. These are the definitions that must be used in the table, verbatim.

27.4 10 2 782

The text states: "Prominent hills are found in the southwest, with Portage Mountain (located 1 km

west of the LAA) being one of the most noticeable topographical 1 features (see Figure 27.2)". It is

not indicated on the map where Portage Mountain actually is.

27.4 10 40 783

In reference to other comments on this section, this sentence should be revised, suggest the

following wording: "Accordingly, the Visual Landscape Inventory determines Visual Sensitive Areas

on the southern slopes of the Peace River Valley as seen from Highway 29 and the Peace River and

on the northern slopes as approximated from the Peace River." also, please replace the "Halfway

River" with "Moberly River" as a valley within the LAA where there is a Visual Landscape Inventory

in place. There is a section of Halfway River mapped but it is significantly north of the project area.

27.4 11 1 784This paragraph should also describe the established VQOs situation on the northern slopes of the

Peace River.



EIS Review Comments



27.5 11 10 785As a general comment for the entire section, the text will require updating should receptor sites be

added to the reservoir and river.

27.5.1.1 11 33 786

There may have not been any ground-based receptor sites with a line of sight to the Site C dam but

by adding water-based viewpoints near the proposed dam those views would be provided. This

sentence should be deleted should sites be added.

27.5.1.3 12 34 787

This kind of prediction is receptor site dependent and since boaters will be on the reservoir, the

Hudson's Hope shoreline protection project would be visible. Recommend the proponent assess

potential impact on visual resources even if an activity is outside a Visually Sensitive Area.

27.5.1.7 14 6 788

The EIS States "The resulting visible disturbances would be rated as acceptable for an established

visual quality objective of “modification”, since they could dominate the views in the short term."

Please clarify if consideration has been given to the long-term. Has consideration of this issue been

given to reclamation and rehabilitate plans for quarry and pit sites?

27.5.2.1 15 9 789

Please consider providing visual simulations of the proposed Site C dam site and its surroundings

from various locations as all that appears to be available at this point is the bird’s eye view

simulation shown on the cover of the EIS documents.

27.5.2.2 15 47 790Please consider adding the following statement to this sentence: "... and from the reservoir itself as

seen by boaters."



EIS Review Comments



27.7.3,

Table 27.1122 18 - 24 791

As currently identified in the EIS, the determination that the effects of the project on visual

resources are not significant is not supported. Request that the proponent revisit its assessment of

the significance of the effects of the Project on visual resources for the following reasons.

1. Inundation of a portion of the landscape and the addition of major structures to it such as dam,

generating stations, transmission lines, and other related components will significantly and

permanently alter the current landscape

2. The use of only 3 of the 9 criteria to characterize the residual effects on visual resources to make

a final decision on significance has not been adequately rationalized. In the EIS the proponent has

rated the Direction criterion as being "adverse" i.e. the project is worsening the condition of the VC

compared to the baseline conditions and trends. Other sections of the text have also indicated that

the acceptable level of disturbance would be exceeded in certain areas in reference to the VQO

definitions and that scenic values would be lowered.

3. The 5 receptor sites selected are limited in coverage and do not take into account views and

baseline viewpoints from the Peace River itself and future reservoir.



EIS Review Comments



791

Comment Continued

4.The statements concerning existing anthropogenic disturbances (including industrial

developments in the LAA) and social context referring to an environment previously disturbed by

human development require further discussion and rational. The presence of existing

anthropogenic disturbance in the area does not necessarily mean that the addition of this project

would not add significantly to the already disturbed state of the project area. This is very similar to

the Visual Absorption Capability (VAC) rating that is assessed for each visual unit. As an example

Natural or human-made openings on a landform make it easier to add a cutblock because of the

higher VAC but there is still a threshold to respect, which is expressed in the form of the VQO set

for that landform. It is not clear that a defensible disturbance threshold has been established for

the Peace River corridor and that the disturbance created by the Project would fall within those

thresholds. Additional detail explaining how existing versus forecasted disturbances will be

rationalized should be added or the section should be revised accordingly.

As currently identified in the EIS the determination that the effects of the project on visual

resources are not significant is not supported.

27.6, Table

27.8

16 &

171 792

As correctly stated in this section, the project construction and operations phases will create

changes to the visual resources. The construction of the Project features and a number of its

components will undoubtedly alter the existing condition of the landscape. The re-alignment of

Hwy 29 and the reservoir itself will create new viewing opportunities while others will be

eliminated. The actual extent of these changes will have to be assessed by re-doing the Visual

Landscape Inventory of the Peace Valley corridor. The proponent has identified no mitigation

measure to assess the actual changes to the landscape in the field after project completion.

Request that BC Hydro provide funding as mitigation for this impact to undertake the Visual

Landscape Inventory after project completion. Such funding has been proposed for other VCs such

as Vegetation and Ecological Communities, Wildlife Resources, Navigation, Heritage Resources, and

Outdoor Recreation and Tourism. It would be appropriate to extend similar funding measures to

the Visual Resources VC so that past investments by the Province are not lost.



EIS Review Comments



App C3 3 24 - 29 793

For additional information and clarification regarding the caveats attached to posted parcels in

Project area: If a parcel is south of the Peace River in the Area of Critical Community Interest ACCI -

http://www.ilmb.gov.bc.ca/slrp/srmp/north/peace_moberly/index.html

then it will have a caveat advising of consultation requests from Saulteau and West Moberly First

Nations; if a Sustainable Resource Management Plan is developed within this area in the Peace

Moberly Tract (PMT - MEMNG Information Letter TITLES-08-08) parcels dispositions may resume

with caveats attached to parcels.

App C3 1 22 - 25 794Note that Canadian Association of Petroleum Producers drilling activity numbers in Table 1 differ

from the Oil and Gas Commission’s official drilling activity totals.

App C3 3 18 - 19 795

Request wording change for clarification and correction, as explained on page 4 of same document:

“drilling licences, conveying the exclusive right for permission to drill wells exploring for oil and gas”

Delete reference to “in a defined area” because a drilling licence may contain only certain zones

and other title may exist in the same area.

App C3 3 7 - 9 796The area of the Montney play region in NEBC is 26,412 square kilometres, not 7,669 km2 as

indicated. Please consider correcting

App E 4 797

In addition to the objectives that were considered in the development of the Project's Outdoor

Recreation Mitigation Plan, please consider adding mitigation to enhance Family Friendly Fishing

opportunities (i.e., fish stocking program, fishing facilities/docks, learn to fish program) inside the

RAA, for the lost opportunities during construction and water and shoreline based access

restrictions.

Figure

27.1,27.2,

27.3

N/A N/A 798

It is unclear in the legends of these 3 maps what the small red polygon just south of Boudreau Lake

is supposed to represent. Please correct or discuss.

Volume 4

Section 28 - Population Demographics - Not Reviewed



EIS Review Comments



31 31-18Table

31.12799

District sideroads: Please ensure that all permits are in place on district side-roads for work within

right-of-way not being commissioned by MoTI. For example; the conveyor belt, improvements to

Old Fort Road.

31 31-18Table

31.12800

85th Industrial Lands: There are currently MoTI RoW within the extents of where BC Hydro will be

extracting gravel. MoTI would like to define a permit and agree to what the RoW will be left as

following reclamation of the lands.

3131.3.1.

510 801

Are there any roads the BC Hydro requires year-round that are not 100% during spring?

31 31-45Table

31.29802

BC Hydro will monitor fog in the area, especially near Taylor, but what are mitigative measures?

And what is the warrant threshold for action?

31 31-18Table

31.12803

Chetwynd: please address concern for turning movements into Canfor Sawmill on H29 and

increased traffic on H29 causing delays. There is also local concern from District of Chetwynd over

left turn lane length from H97 to H29. (Maybe signal timing could be considered).

3131.3.1.

510 804

Does BC Hydro predict the need to haul overweight (greater than 100% axle loading) on any road,

including numbered highways, during the course of the construction project?

Section 29 - Housing - Not Reviewed

Section 30 - Community Infrastructure and Services - Not Reviewed

Section 31 - Transportation



EIS Review Comments



31 31-18Table

31.12805

H97 - South Taylor Hill: Please note that the Ministry of Transportation and Infrastructure is

tentatively scheduled to 4-lane the bottom 2 kilometres of H97 - South Taylor Hill beginning in

Summer 2014, ending Fall 2015. Traffic delays could be cause for concern for BC Hydro. The

Ministry may proceed with 4-laning the remainder of the South Taylor Hill during the construction

of Site C which could result in additional traffic delays.

31 31-18Table

31.12806

Maintenance: There are concern over BC Hydro expectations for summer and winter maintenance

on MoTI roads, especially sideroads. For example, will the level of expectation for winter

maintenance increase on Jackfish Lake Road? (currently a class ‘c’)

31 31-34 38 807Please clarify if BC Hydro is reviewing all intersections for illumination. What standard is BC Hydro

using as a warrant base?

31 31-18Table

31.12808

Please ensure all new right-of-way acquired during the projects are properly surveyed and

registered.

31 31-18Table

31.12809

Please include considerations for 100 Avenue between YXJ Airport and Fort St John. The MoTI

District is undergoing conceptual options review of this corridor in 2013. Increased traffic from

airport to town, combined with growth of corporate offices along the road could make this section

a point of congestion.

31 31-18Table

31.12810

Taylor Bridge: The steel deck on Taylor Bridge continues to wear, and requires a greater frequency

of repair. Possible construction delays or even re-routing of traffic in the event of an emergency

deck repair.

31 31-25 13 811

The EIS predicts level of service change at signalized intersection, but no comment is made of

mitigation efforts. This could be as simple as investigating signalized light timing. This should be

included in the EIS

31 31-2Table

31.1812

While in existence, would other industrial users or groups (such as the Ministry of Transportation

and Infrastructure) be permitted to utilize the temporary construction bridge for access across the

Peace River, or would it be restricted to BC Hydro use only. And if so, to what level.



EIS Review Comments



31.3.1.5 14 10 813

The technical data report on Microclimate (Volume 2, Appendix K) indicates a rise of 1 degree

Celsius in average temperature within 1 km of the new reservoir. How much sooner will Regional

Road Restrictions likely have to be imposed on Hwy 29 and other roads adjacent to the reservoir

due to this higher temperature? If road restrictions on these roads need to be put on sooner, it may

put them out of sync with other roads in the area and lengthen the overall duration of restrictions

for industrial traffic.

32 814EIS Guidelines 32 - Please include further discussion of residual effects and how they will be dealt

with and mitigated8.5.3.2

32 815EIS Guidelines P24 Baseline description re and inventory are OK, but please provide further

description of context as well as synthesis: 8.2

32 816 EIS Guidelines P33 - Please provide a clear characterization of the residual effects 8.5.2.4

32 817EIS Guidelines p23: no real hypotheses or models have been presented and there are limited

discussion of gaps. Please consider addressing these issues.8.1

32 818EIS Guidelines P25 - Please clarify why a predictive model was used and if not why? If so, why was

it not presented?8.3

32 819

General Comments: Technical Merit -Generally looks OK for this level of assessment but as noted

missing any predictive models and needs follow up on specimen Identification.

Assumptions- Not well explained, in particular not sure exactly how the numerical values in

appendix C Table E were determined explicitly

Strategies -Too general, not enough discussion of which are best for which types of sites, see earlier

points, Discussion of residuals too brief to estimate how much effort and of what kind needs to be

applied to which specific sites

Gaps : Geological context missing, Predictive models missing, Specific mitigation strategies missing,

P32-28 line 23 mitigation strategy must include detailed geological strata mapping , Strategies for

residuals missing, Explicit explanation of ranking (Overall significance score) and certainty

percentage a few specific example calculations would help, P32-62 (32.4.3) seems inadequate as an

explanation

Section 32 - Heritage Resources



EIS Review Comments



32 820

Please include a separate discussion of the occurrence of Quaternary deposits and fossils and

potential relationship to First Nations sites and resources, especially knowing the old age of nearby

arch sites such as Charlie Lake cave

32 821Please ensure a very thorough inventory and study of vertebrate remains is undertaken by

vertebrate paleo experts.

32 822

Please include an assessment of potential Quaternary deposits and section that might be impacted

thus providing an opportunity for microfossils studies (pollen spores diatoms etc.).

32 823

The report contains and great deal of data from varying sources and of varying quality. It consists

largely of field visit data and literature review, with limited consultation with experts, and pending

expert analysis of field collections. However more needs to be done to construct a mitigation

strategy and mechanism to deal with residual effects.

32.2 824

Field collections should be fully identified before preparation of final Paleontology report. Please

include further discussion and explanation of geological and stratigraphic and paleontological

context.

32.2 825

Baseline: Consider including synthesis of the paleontological resource in comparison to other better

known sites outside (uniqueness and quality) in the area and in context of the geological

framework. Please include a detailed map of sites and rankings of bedrock geology (including

lithological facies) would be very helpful to identify zones of high concern and likely impact, and

would help quickly appreciate the extent of impact.



EIS Review Comments



32.4 826

Please clarify the following:

• What time period?

• Which sites provide best representation for each age? What kinds of fossils do they contain? At

which sites

• Summary occurrence and description of content of the sites, and are there representative of

other sites elsewhere in the region, on the continent ? globally?

• Characteristics of the site geology and exposure (see a Table 32-2 in Vol 4 p32-11 to help assess

indicators)

o physical characteristics (slope, extent): Kind of fossils found in the exposures and outside of

exposures (loose on the surface)

o Paleo characteristics: lithology, special features, abundance, quality of preservation

32.4 827

Request: all Class I and II sites that are likely to be inundated or destroyed, or at least a solid

representative sample (if there are duplications) need to have their stratigraphy and lithology

described and comprehensive fossil collections made for future study. The site may not be available

for study for many decades and even centuries otherwise. In this context if Class II sites on p32-29

require 20 % representative collections then Class I sites require at least this which is not suggested

(an oversight perhaps).

32.4 828

Please clarify how the index of “Overall Significance Score” (see page 11 of 108 I appendix E) was

derived. An example of how this can be done based on paleontologically important criteria was

used in the comparison of sites representing the McAbee beds of Eocene age in southern interior

BC. Without a more comprehensive context and analysis it becomes difficult to estimate the need

for resources for mitigation and certainly for dealing with adverse residual effects.



EIS Review Comments



32.4 829

Request: please clarify the results by providing more context and data synthesis. Should include an

analysis of the paleontological significance of the LAA, or RAA compared to extra regional,

continental and global paleontology nor an analysis among sites (this site is a better representation

than that site or group of sites etc.) for a particular geological age and paleo-environment. Such an

analysis is fundamental in developing a ranking system.

32.4 830

Request: please include a clear statement of the need for these specimens to go into properly

curated facilities and the need for these facilities to be financially supported. The likely number of

specimens and space required for them will be large. Considering the likely residual effects,

probably thousands of specimens will need to be collected and these need to be collected by

professionals who also correctly describe the context (stratigraphy, lithology, distribution of fossils)

at each collecting site. Following, or in tandem with construction activities, monitoring and

presumed collecting as impacts occur will generate additional material.

32.4 831

Request: please include a description of the regional Paleontology through the interval represented

by the sites in the Site C area, certainly those in the LAA and RAA.

32.4 832

Request: please include greater context and comparative assessment and develop more specific

mitigation and residual effects analysis.

32.4 833

Request: The large clusters of Extreme Sensitivity sites (Figure 4.5) need to be individually

identified, characterized and analyzed with respect to value, impact, mitigation or otherwise.

Examples are Moberly River, Tea Creek, Wilder Creek and so on up the drainage. The PRA clearly

identifies the Site C project will have unambiguous adverse effects on Paleontological Heritage

Resources (PHR) p 32-27 173 positive Paleontologically sensitive areas). Summary maps clearly

indicate that much of the river course to be inundated and impacted has high to extreme

paleontological value (purple and red dots) and can be thought of as a more or less continuous

paleo sensitivity area.



EIS Review Comments



32.3.3 32-27 34-35 834

Request: 35 please note the importance of the opportunity to add to the knowledge base of paleo,

however to do this must have a more comprehensive description of sites and analysis of sites

compared to each other and the regional geological and paleontological context including: at each

site abundance, uniqueness, specimen quality (both individually and as assemblages), representivity

of the fossils.

32.3.3 32-28 41 835P 32-28 line 41 Please note the high number of positive PSA’s

32.3.3.1 836Please make mitigation measures more specific. It is not well spelled out and not well linked to

specific sites or to the considerable value of the resource.

32.3.3.3 32-46

38 (Also

Table

32.6)

837

Please consider expanding measures of compensation in kind to include signage and other

measures: "compensation-in-kind (including replication)" as mitigation of Rocky Mountain Fort

should also include other compensation-in-kind mitigation measures (e.g., near-site

commemorative signage).

32.4.3 838

Residual effects not well explored and are needing more specific discussion and explicit

recommendations for dealing with them. As it stands seems to be left to some future discussion

with experts and institutions.

32.3.3.2 28 839Clarificaiton required: what is a systematic data recovery program p32-28?



EIS Review Comments



App C

Section

5.2.5.5

154-

169840

The EIS Guidelines State: "The EIS will summarize the potential adverse effects of the Project on

heritage resources, including physical and cultural heritage resources, and any structure, site or

thing that is of historical, archaeological, paleontological or architectural significance. " and

“Archaeological and historical site inventory field work will include surface and subsurface

inspections, completed in accordance with British Columbia Archaeological Impact Assessment

Guidelines (BCMNRO1998:13) and permits issued under the Heritage Conservation Act. ”

Request:

a) Please provide estimates of the areal extent of the Archaeological deposits that would be

impacted by the project based on the data obtained during the archeological impact assessment

fieldwork.

b) Request the proponent address the question of "How much archaeological deposit would be

impacted by the Project?”

18.2.3

App C

Section

5.2.5.5

154-

169841



thing that is of historical, archaeological, paleontological or architectural significance. "

Request that the proponent address Treaty 8 Tribal Association’s stated concern that the

archaeological impact assessment study has focused on the discovery of large, complex sites, and

has given insufficient attention to understanding the distribution of smaller, sparser sites.

18.2.3



EIS Review Comments



App C

Section

5.2.5.5

169 842



thing that is of historical, archaeological, paleontological or architectural significance."

Request that the proponent explain the derivation of the estimated numbers of archaeological sites

in different parts of the LAA that were generated by earlier studies, and reconcile these estimates

with the data obtained during the archaeological impact assessment fieldwork reported in the EIS.

Analysis of the limited data presented in the EIS suggests that the earlier estimates significantly

under-represent the number of archaeological sites in the LAA.

18.2.3

App C

Section

5.2.5.5

169 843




Request that the proponent clarify the statement that “based on statistical tests, few large sites

(often the most significant sites) have been missed”, by identifying the statistical tests employed,

and quantitatively defining the terms “few” and “large.”

18.2.3

App C / App

F Section

5.2.5.5

1 –

311;

Figs.

5.16.1

–

5.16.24

1

844

Figs. 5.16.1 – 5.16.241




Request that the proponent define archaeological sites in a consistent manner, based on the

observed distribution of archaeological materials, so as to facilitate estimation of the quantity of

archaeological deposit that would be impacted by the Project.

18.2.3



EIS Review Comments



App C / App

F Section

5.2.5.5

76-77;

Figs.

5.16.1

–

5.16.24

1

845



thing that is of historical, archaeological, paleontological or architectural significance." and



Guidelines (BCMNRO1998:13) and permits issued under the Heritage Conservation Act.”

Request the proponent complete the reported ‘adaptive testing’ program, where necessary, to

allow consistent estimation of the extent of the archaeological deposit associated with each

positive systematic test.

18.2.3

App C

Section

5.2.5.5

158 846







Request the proponent calculate the density of identified archaeological deposits as the number of

artifacts identified in subsurface tests, divided by the total excavated area within the site boundary,

rather than the number of identified artifacts divided by the total area within the defined site

boundary.

18.2.3



EIS Review Comments



App C

Section

5.2.5.4

75 &

113847







Request the proponent individually report the areas subjected to surface inspection in: 1) fallow

fields; 2) cultivated fields; and 3) vegetated lands “when proceeding to and from targeted testing

locations.”

18.2.3

App C

Section

5.2.5.4

75 &

113848







Request the proponent address the reported failure to employ “Prescribed tillage with a plough,

cultivator, or harrow to increase visibility in previously cultivated fields.” Request that proponent

provide for completion of this prescribed program.

18.2.3



EIS Review Comments



App C

Section

5.1.5.4

75 &

113849







Request the proponent estimate the extent of archaeological deposits on lands modeled as having

low or moderate archaeological potential, with reference to the data recorded during systematic

survey of cultivated and fallow fields .

18.2.3

App C

Section 8.0

224

850

Mitigation - In section 8.3.4, the report identifies documentation of existing conditions as one

means of mitigating the adverse effects of the Project on heritage resources. However, it does not

specifically refer to archaeological data in this context, and distribution of the results of the

completed and recommended studies is not discussed.

Request that publication of all data that have been collected during the development of the model

of archaeological potential (including the underlying LIDAR data) and the archaeological impact

assessment, as well as the results of any future archaeological data recovery projects, be identified

as a potential mitigative measure.

18.2.3



EIS Review Comments



App C

32.2.2.220 39-44 851







Request the proponent compare different parts of the LAA (e.g., the north and south banks of the

Peace River) in terms of the areal extent of identified archaeological deposits, rather than the

number of identified sites. This will require that sites be consistently defined with reference to the

observed distributions of archaeological materials. Comparison in terms of the numbers of

reported sites is less meaningful, due to the considerable variability in the size and density of

reported sites.

18.2.3

App C 5.1 168 852







Request the proponent identify, and report the size of “Certain locations (that) could not be

assessed in the field due to access restrictions (section 5.1, p 68)”, and propose remedies for these

omissions.

18.2.3



EIS Review Comments



App C

5.1.5.172 853







Request the proponent indicate whether identified discrepancies between the archaeological

potential model, based on LIDAR data, and assessed potential, based on field observation during

model testing, were used to revise and improve the model, prior to its implementation for

archaeological inventory. Request that the extent of all re-evaluated areas be reported.

18.2.3

32 10, 26

P10: 21-

22

&

p26: 13-

16

854

The EIS appears to present contradictory conclusions as to the expected effects of installation of

worker accommodations.

On page 10 of Section 32 it states,

‘Activities for which there is no interaction between the Project activity or component and heritage

resources ... include:

Temporary accommodation – dam and generating station: installation of 21 prefabricated units in

the north and south bank camps; operation of both camps “

On page 26 it states,

“Ground-disturbing activities associated with erecting worker accommodation and infrastructure

have the potential to affect heritage resources, if present. Increased 15 loading from temporary

facilities may cause compaction to buried heritage resources. “

Request the proponent clarify the expected effects of installation of worker accommodation on

heritage resources.

18.2.3



EIS Review Comments



32.3.327 &

28

P 27: 18-

43;

P 28: 1-

20

855

Request that the proponent acknowledge that a significant proportion (possibly the majority) of the

archaeological resources that would be affected by the Project have not been, and are not

expected to be, identified.

Request that the proponent acknowledge that it will not be possible to mitigate the effects of the

Project on unidentified archaeological resources through intentional avoidance, protective

measures, data recovery or documentation.

18.2.3

32 56-61Table

32.9856

Table 3.29 represents the Magnitude of the Residual Heritage Effect of most Project activities as

Low. This includes activities such as site clearing; dam construction; road construction, upgrading &

realignment; aggregate extraction; diversion & channelization, etc., which are likely to result in total

destruction of archaeological sites, including many sites that have not been and are not expected to

be identified.

Request the proponent explain the evaluation of the Magnitude of the Residual Heritage Effect of

Project activities on heritage resources.

18.2.3

App C 221 N/A 857Please include Ministry of Environment, BC Parks in relevant parties for mitigation discussions

regarding heritage resources moving forward

33 2 33-35 858

For recreational water quality, MOE adopts Health Canada’s water quality guidelines for recreation.

This standard should be used. http://www.hc-sc.gc.ca/ewh-semt/water-eau/recreat/index-eng.php

. You may also wish to consult with Ministry of Health and Health Authorities regarding recreational

water quality.

33 2Table

33.11859

Recreational water quality and exposure through primary and secondary contact is not included,

please explain why this was omitted.

33.1.1 2 860

Please clarify if the proponent consulted with the Ministry of Health regarding the authority to issue

fish consumption advisories. The Ministry of Health may advise if this is a function authorized by

the Public Health Act. Managing the risks of environmental contaminants in country foods is a

provincial responsibility lying with the Ministry of Health and/or Health Authorities

33.1.1 2 861Please clarify why the following source water guidelines were not considered in this table: total

organic carbon, phosphorus.

Section 33 - Human Health



EIS Review Comments



33.1.1 2 862Please include whether the guidelines are maximum acceptable concentrations (MAC) or aesthetic

concentrations (AO).

33.1.1 2 863Please indicate which recreational water quality guidelines are relevant to this project and also

consider placing them in a table for comparison.

33.1.1 2 864Regulatory Framework. Please include a section on the Environmental Management Act.

33.1.1 2 865

Table 33.1 Drinking Water Guidelines. It is unclear why these contaminants were included in this

table. Are these the potential contaminants of concern? They are not the full suite of drinking

water guidelines. For most contaminants, the BC Ministry of Environment has policy to adopt the

Guidelines for Canadian Drinking Water Quality when Health Canada’s guideline is also appropriate

as a source water benchmark. Therefore, when Health Canada updates a guideline, MOE will

typically update its guideline as well. Please see

http://www.env.gov.bc.ca/wat/wq/BCguidelines/working.html#table1 for a list of working water

quality guidelines including those for drinking water sources.

33.1.1 2 866

The Ministry of Environment establishes Water Quality Guidelines (see Environmental Management

Act Part 5). MOE’s “drinking water guidelines” are developed to be achieved at the source. These

benchmarks are used to assess changes in source water quality used for drinking water, irrigations

supplies and aquatic life.

33.1.1 2 867

The Public Health Act may need to be included for food contamination and possible fish

consumption advisories (please check with the Ministry of Health and Health Canada regarding First

Nations).

33 3 868

Please clarify what ‘studies’ were used to determine if a water quality contaminant exceeded a

guideline and was therefore screened as a COPC? Eg. Baseline monitoring, studies showing that

contaminant x increased as a result of flooding, etc....

33 22Table

33.11869

Please clarify why ingestion of birds such as ducks that may feed on MeHg fish is not carried

forward?

33 22Table

33.11870

Section 33.2.2 : Please clarify if this section is an assessment specific to MeHg or an outline of the

screening procedure for all COPC. Best to keep specific assessments and general procedures

separate for clarity.



EIS Review Comments



33 24 871

Often agencies use screening values for contaminants in fish tissue in monitoring programs. If

monitoring demonstrates that a screening value is exceeded, a more thorough health assessment is

conducted to determine appropriate consumption limits. The Ministry of Environment is currently

updating the health-based guideline for Hg in fish and shellfish tissue and therefore, this may not be

an appropriate screening value at this time. Please clarify if the proponent has consulted with

Health agencies such as Ministry of Health, Health Authorities, or First Nations and Inuit Health

Branch to determine if the recommendations in Table 33.29 are appropriate.

33 25Line 30-

31872

Please clarify the specific "First Nations Communities" that are being referred to here and where

they obtain drinking water?

33.3.1 25 873

Please clarify if there has been a survey of surface water intake licences? Has the proponent

considered all surface water users including intakes serving small water systems and individual

dwellings?

33 26Line 11-

13874

Please note that for drinking water parameters, it is important to report how often (ie frequency)

parameters exceed maximum acceptable concentrations (MAC) rather than reporting means or

averages.

33 26 Line 7 875

Please be specific regarding what parameters exceeded Health Canada’s drinking water or

recreational guidelines rather than reporting “in general, these baseline parameters....etc”

33 27Table

33.12876

Please clarify why only these parameters were reported? How does this compare to those listed in

Table 33.1.? Please clarify what are the water quality parameters of potential concern as a result of

this project.



EIS Review Comments



33 27Table

33.12877

The turbidity guideline has been misinterpreted. Turbidity needs to be considered in collaboration

with Health Canada’s turbidity guideline which should also be reported here. The purpose of BC

MOE’s water quality guideline for turbidity is to assess where resource activities may impact the

quality of drinking water sources. Turbidity is an important parameter with respect to

microbiological contamination reaching the consumer. Increased or high turbidity levels may result

in the need for improved treatment technology for water systems on surface supplies. Therefore,

please clarify and report the baseline turbidity levels. What are the projected changes and what

receptors may be impacted if any?

33 37Table

33.18878

Is this a consumption advisory that the proponent intends to issue for the impacted area? If so,

please clarify that the proponent consulted with the Northern Health Authority and First Nations

and Inuit Health? Normally these advisories are issued under the Public Health Act by a Medical

Health Officer.

33 37Table

33.18879

Please clarify if the consumption limits considered background Hg levels and the much lower TDI for

children.

33 39 Line 27 880

Please clarify here which water quality parameters are anticipated to change as a result of the

project. Would it not be more appropriate to state that “changes are not anticipated to result in

exceedances of drinking water”

33 40Line 15-

17881

Is this referring specifically to groundwater quality? Although surface water quality is not

anticipated to exceed guidelines, please clarify how the proponent anticipates confirming this once

the project begins. Will a monitoring program be established in indicator areas or with water

suppliers?

33.4.1.0 62 882

Please clarify if the proponent has consulted with local Health Authorities regarding this monitoring

program to ensure that local knowledge about susceptible populations and consumption patterns

are considered. Typically consumption advisories are issued by Medical Health Officers in BC

authorized under the Public Health Act. Please clarify the process and partners being proposed.

Volume 5



EIS Review Comments



34.3.2.3 883Consider referencing the recent Federal Court ruling in Daniel vs. Canada, 2013 and any potential

relevance to this project.

34.3.3 12 37 884Consider removing reference to the Treaty 8 Tribal Association. The association does not hold any

Aboriginal or Treaty Rights. Suggest referencing individual nations.

34.7.1 28 6-25 885Consider addressing the Province’s position on the potential future application of a FN to convert

fee simple land transfers to their Indian Reserve (Additions To Reserve)

App 6 27 886

Please consider including a copy of the "Telling a Story of Change; The Dane-Zaa Way" into the EIS.

Please discuss how this document was considered and incorporated into project planning and

design?

35 887

Several major landslide features are identified in the terrain stability mapping of the project activity

zone. Landslides are not addressed in the public safety plan 35.3.1.2 (e.g., road signage at crossings

of major landslide features - 'no stopping landslide risk zone' or the like, weather related work

stoppage rules, etc.)


and Soils

35 888

Several major landslide features are in the project activity zone. Landslides are not addressed in the

worker safety and health management plan as outlined in WCB regulations Part 26 Forestry

Operations and Similar Activities

26.18 Landslides

In a forestry operation where there may be a risk of a landslide

(a) the risk must be assessed in accordance with a standard acceptable to the Board,

(b) if a risk is found to be present, written safe work procedures must be developed meeting the

requirements of the standard, and

(c) workers must be educated in the safe work procedures.

[Amended by B.C. Reg. 312/2010, effective February 1, 2011.]

It is recommend that a map is made outlining the zones in which these regulations apply and the 3

regulated items be addressed to assess and reduce risks (e.g., signage, landslide magnitude

frequency studies, work safe procedures such as stop work in wet conditions)


and Soils

Section 34 - Asserted or Established Aboriginal and Treaty Rights, Aboriginal Interests, and Information Requirements

Section 35 - Summary of Environmental Management Plans



EIS Review Comments



35.2.1.4 6,7 19, 20 889

"to ensure that traffic is managed in and around the construction sites" It is not entirely clear that

the Traffic Management Plan would address traffic in and around and access to all Project

Components not just the primary construction sites. Please Clarify.

35.2.2.19 35-21 4-36 890

This section outlines the expected content of the soil management site restoration and re-

vegetation plan, and provides a relatively comprehensive discussion of the considerations

necessary for the development of such a plan. Although discussion of post construction end use for

rehabilitated lands is discussed form the agricultural perspective, similar discussions for other end

uses, e.g., forestry, wildlife or special ecological values are not present. This section is also lacking

any discussion of how the results of the reclamation efforts will be monitored, which is essential for

high value areas like agricultural land, forestry or other areas where (for example) ecosystem

restoration techniques have been applied. The final soil reclamation plan should include such topics


and Soils

35.2.2.2,

35.2.2.18

35-39

and 35-

20/21

11-17,

34-36,

and 1-2

891

Monitoring and Reporting – Recommend that the monitors report real time to a database to

increase transparency of issuing air quality advisories.

35.3.2 892

There is no provision for long term climate and meteorological monitoring. BC Hydro has installed

stations in the valley. Please clarify if any of these station have been designated as long term

monitoring sites, and if not, please consider doing so.

37 37-9 37 893 Does not consider debris dam and flood. 9.2.1 Geology, Terrain

and Soils

37.1.13.2 37-46 Floods 894Please clarify if the flood discharge effect on downstream infrastructure such as Taylor Bridge and

Clayhurst Bridge been considered?

Section 36 - Compliance Reporting - No Comments

Section 37 - Requirements for the Federal Environmental Assessment



EIS Review Comments



37.1.3.3 37-8 29 895

Please note that the new bridges, culverts and other structures on Highway 29 must be designed to

accommodate the high channel flows from extreme weather events as well as the debris typically

contained in those high flows.

37.1.8.3 37-21 5 896

The 50 year return period indicated in the document is not correct. The design earthquake is

dependent on bridge importance, the type of bridge structure and the seismic risk associated with

the geographic location of the bridge. Please correct.

37.1.9 37-21 12 897

Consider adding additional detail regarding potential effects of wildfire on the construction phase of

the Project. Wildfire could have a disruptive influence (albeit of fairly short duration) on

construction through blocking of access, smoke and visibility problems and perhaps an influence on

the actual work sites including the dam and clearing areas of the reservoir. A review of historical

fires that could affect the construction phase shows the last major event occurred in 1976 when a

wildfire of some 17, 000 ha happened on the south side of the Peace River drainage and if occurring

during the construction phase would have impacted the transmission line and access roads

proposed for this project. Construction on the north side of the Peace River is not expected to be

adversely impacted by wildfire due to the different fuel type and probable direction of fire spread.

37.2.2.2.2

and 37.2.2.3

37-52

to 37-

59

18 898

Please clarify what affect a dam breach would have on the bridge structures over the Peace River at

Taylor and Clayhurst and on the Moose Mouth Bridge over the Alces River near Clayhurst.

Section 39 - Complete Lists of Mitigation and Follow-Up Measures

Section 38 - Summary of Potential Residual Effects of the Project - No Comments



EIS Review Comments



39 899

The NRS agencies take the view that as long as the proposed mitigation is feasible, reasonable or

the proposed technology or approach has been used successfully elsewhere, then we are fine with

the level of information provided at the EIS stage knowing that detailed plans would be required

prior to permitting decisions. However, in some instances, these plans were heavily relied on as

rational for assumptions and findings. To address this, the NRS agencies request BC Hydro include

any developed plans, and specifically those plans that have been used as rationale for findings, into

the amended EIS.

39 900

Green house gas emissions from decay of flooded biomass is not addressed in this section. Loss of

carbon sequestration ability by soils and vegetation in the forests and wetlands in the flooded area

is not addressed. If this is covered in another section it should be cross referenced here.9.2.1 Geology, Terrain

and Soils

39 901Though soil mitigation and reclamation is to be addressed in a management plan, detailed baseline

data is not included.9.2.1 Geology, Terrain

and Soils



EIS Review Comments



39 902


Issue: Vol 5 Table 39.1 Complete List of Mitigation Measures presents proposed mitigation

measures for each potential effect (e.g., for three effects for “wildlife resources”: habitat

alteration/fragmentation; disturbance/displacement; and mortality).

o The next column indicates whether there is, or is not, a potential Residual Effect (Y/N), but there

is no indication as to what exactly are the Residual Effects.

o The last column indicates (Y/N) whether the potential Residual Effect is “Significant” or not.

Concern: Neither the identification of Residual Effects, nor the information on calculation of

Significance, is specific enough to be meaningful to understand what exactly the residual adverse

effects are, and why they are significant or not significant.

Request that the Proponent: Clarify the location in the EIS of details and rationales about the

assessment of Residual Effects and the calculation of Significance. Cross-reference these in other

sections/ volumes so that the reader is able to access this information more easily. If this

information is not currently provided in the EIS, please consider adding it.

Section 40 - Conclusions and Conditions - No Comments
