KNC Review of Jumbo Glacier Resort EAC Commitments Compliance, November, 2014
EAC Commitment
61 “To develop and implement an adequate
groundwater investigation program that will
include, but not be limited to, drilling and
pump testing wells to determine sustainable
groundwater extraction rates. This
investigation must take place prior to
construction of each phase of development
(including the drilling and developing
groundwater wells that will be used to
supply the resort).
BC verbal responses/additional info
1 well drilled along access road a few
hundred meters south of the proposed day
lodge location. 40 US gpm sustained
through 72 hour pump test. Estimated
daily requirement for first phase (only day
lodge, service building, 2 lifts) of 467 imp.
Gallons per day.
72 The proponent has committed to a
biological, physical habitat and continuous
water volume and water quality sampling
program to be implement pre- and postdevelopment. (Similar to commitment 55)
Oct. 9th, 2014 letter from EAO to
proponent includes a warning that the
proponent is not in compliance with this
pre-construction requirement.
NON-COMPLIANT
104 “To monitor the potential direct and
indirect effects of the Project on the Central
Purcell Mountains Grizzly bear population
through genetic testing to predict, detect,
and assess any change (if any) in Grizzly bear
numbers and distribution. The monitoring
program is to include field collection of hair
samples from Grizzly bears within the area
of direct and indirect impacts before
construction, at the end of each phase of
EAO staff have concluded that the 1997
grizzly bear DNA hair sampling survey
undertaken by Michael Proctor for the
proponent/Enkon satisfies the ‘preconstruction’ monitoring requirement
specified in this commitment.
NON-COMPLIANT
Nov. 10, 2014
KNC update Nov. 10, 2014
NON-COMPLIANT
KNC awaiting receipt of QP report and
opportunity to review
EAO is waiting (Sept. 29th) to review
Qualified Professional’s report on
groundwater testing. EAO’s view is that
this is ‘on track to compliance’.
The KNC profoundly and forcefully disagrees with
the conclusion of the EAO with respect to this
commitment.
“The monitoring program is to include field
collection of hair samples….before construction.”
This requirement in no way suggests that the
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KNC Review of Jumbo Glacier Resort EAC Commitments Compliance, November, 2014
construction and at appropriate intervals in
the following 10 years, or until such time as
the Ministry of Water, Land and Air
Protection determines that it is no longer
required.
1997 DNA hair sampling constituted an
acceptable pre-project baseline. It is highly likely
that the central Purcell GBPU population size has
changed since 1997 (a 17 year period), given
changes to hunting quotas and in adjacent
GBPUs. Thus, the 1997 study results provide NO
baseline for assessment of project impacts,
completely nullifying the value of this
commitment.
118 To conduct additional bird surveys prior
to construction and to implement a
monitoring and adaptive management
program for birds, appropriate with the type
and size of the Project, during construction
and operations.
EAO notes that GRL/Enkon environmental
monitors are undertaking bird surveys
during the construction period.
NON-COMPLIANT
119 To implement and fund ongoing
threatened and endangered wildlife
monitoring, including the Least chipmunk, in
the preconstruction/construction phase of
the Project.
EAO has determined that they are satisfied
with the current approach, involving a
construction worker ‘wildlife observation
checklist’ which is not even a checklist…it is
a blank table where construction workers
can insert wildlife observations.
NON-COMPLIANT
The proponent’s approach does not come near to
meeting the commitment to ongoing threatened
and endangered wildlife monitoring. NO preconstruction threatened and endangered wildlife
surveys have been conducted in the preconstruction period. Relying on completely
inexperienced and uninformed construction
workers to understand when they may be in
critical habitat for threatened and endangered
Nov. 10, 2014
An incidental bird observation program
undertaken by environmental monitors is
completely inconsistent with this requirement. It
has not been done ‘prior to construction’ as
required, is not being done in the appropriate
bird breeding survey period and using
appropriate survey techniques, as described by
Resources Inventory Committee standards for
different guilds of birds (e.g. call-playback
surveys, point count surveys, riparian surveys,
etc.).
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KNC Review of Jumbo Glacier Resort EAC Commitments Compliance, November, 2014
wildlife and to identify threatened or endangered
wildlife is completely unrealistic. No mention is
even made in the contractors’ handbook of
training in this regard. The rare and endangered
species likely to be found in the project area have
specific periods of activity/inactivity when they
are most likely to be detected. Least and redtailed chipmunks are nocturnal, and burrow
underground in snowy months, so unless trained
biologists are out at night doing trapping surveys
in snow-free months, they would never have an
opportunity to ever detect them. A similar lack of
opportunity to detect rare and endangered
species would be encountered for other species,
if not surveyed during the appropriate timing
window (e.g., American badger, Swainson’s
hawk, Peregrine falcon, western toad, etc.).
146 To monitor, at its own cost,
unsupervised public recreational use
(including use by resort construction and
operations employees, resort visitors and
resort residents) and other use of roads
which link to Highway #95 at Invermere.
This monitoring will be undertaken before
construction, during initial construction (i.e.,
prior to commercial scale resort operations)
and during commercial scale operations.
Monitoring results will be reported to the
Ministry of Water, Land and Air Protection
Regional Manager (Environmental
Stewardship).
Oct. 9th, 2014 letter from EAO to
proponent includes a warning that the
proponent is not in compliance with this
pre-construction requirement.
NON-COMPLIANT
74 That only native vegetation will be used
EAO advises that EPD has approved
NON-COMPLIANT
Nov. 10, 2014
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KNC Review of Jumbo Glacier Resort EAC Commitments Compliance, November, 2014
for landscaping in the resort base. No
noxious weeds will be used and no nonnative plants capable of becoming weeds
will be permitted.
Vegetation Management Plan including
revegetation seed mix.
Proponent’s Construction Environmental
Management Plan contains a ‘Vegetation
Management Plan’ component. This plan
indicates use of a “mix of indigenous grass
species” but the proposed seed mix contains 8
species, of which 7, comprising 80% of the seed
mix, are non-native. This revegetation effort will
nullify the value of any indigenous species
landscaping requirement.
11 To hire an independent expert to
monitor road construction for
archaeological impact in areas of moderate
to high archaeological potential.
KNC unaware of EAO perspective on
compliance with this requirement
NON-COMPLIANT
See attached memo from KNC archaeologist
Nicole Kapell
195 To monitoring of land altering activities
by a qualified archaeologist in areas of
moderate to high archaeological potential
prior to development taking place (see also
commitment 11).
KNC unaware of EAO perspective on
compliance with this requirement.
NON-COMPLIANT
See attached memo from KNC archaeologist
Nicole Kapell
Nov. 10, 2014
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