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Atlin Development Plan - Executive Summary

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Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I
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EXECUTIVE SUMMARY
PURPOSE
DEVELOPMENT PLAN PURPOSE
The purpose of this Development Plan is to provide information on the Atlin Hydro Expansion
Project, (“the Project”) to support BC provincial decision-making and Taku River Tlingit First Nation
(TRTFN) decision-making, on Tlingit Homeland Energy Limited’s application for Project approval.
The Project, which has an installed capacity of about 8 MW, is reviewable under the BC Clean
Energy Project (CEP) Development Plan (DP) Process. As described in the CEP DP Information
Requirements (BC, 2011), the Development Plan is intended to address provincial information
requirements for Project assessment and decision making with respect to provincial statutes,
regulations and policies. The Development Plan must be submitted to the BC Ministry of Forests,
Lands, Natural Resource Operations and Rural Development (MFLNRORD) and approved prior to
issuance of a Land Act License of Occupation or a Water Act License for waterpower purposes.
The Project does not trigger review under the BC Environmental Assessment Act (BCEAA) or the
Impact Assessment Act (IAA).
PROJECT PURPOSE
The purpose of the Atlin Hydro Expansion Project is to provide a reliable renewable source of
energy for the Yukon electrical grid to help meet its winter renewable energy shortfall, while
providing social and economic benefits to the Taku River Tlingit First Nation, and the broader
community of Atlin, BC. Tlingit Homeland Energy Limited (THEL) is 100% owned by TRTFN citizen
shareholders. The Project, once connected to the Yukon’s electrical grid, would supply
approximately 46 Gigawatt hours per year (GWh/y) of renewable energy, and provide significant
own-source revenues to the TRTFN. On a national and global scale, the project will provide a clean,
renewable energy source that will help meet Canada’s commitment to reduce greenhouse gas
emissions.
Tlingit Homeland Energy Limited’s vision is to develop TRTFN’s sustainable hydroelectric resource
to generate and retain the economic benefits within the community now and into the future. As well,
THEL has developed the best Project possible by developing resources that accord well with the
Wooshtin woodidaa: Atlin-Taku Land Use Plan and its location in areas of previous disturbance with
values of generally lower sensitivity.
PROJECT OVERVIEW
For clarity, the following description of the Proponent’s company structure is provided, given that all
licenses and financial agreements are entered into by its General Partner.
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Tlingit Homeland Energy Limited Partnership, (the Proponent), is a Limited Partnership composed
of two partners:

The Limited Partner (LP): Tlingit Homeland Energy Limited Partnership (THELP), and

The General Partner (GP): Tlingit Homeland Energy Limited (THEL)
THEL, the general partner, is responsible for the day-to-day management and operation of the
business of the partnership and has unlimited liability for all the debts and obligations of the
partnership. THELP, as the limited partner, does not take part in the management and operation of
the business of the partnership, but may incur indebtedness and borrow money. In that regard,
THEL has the authority to borrow and issue security on the property of the limited partnership,
THELP.
In our case, THELP is the proponent of the Project, but all the agreements including permits,
contribution agreements, consulting contracts and financial agreements, are entered into by THEL,
acting on and doing business on behalf of the Limited Partnership, THELP.
The Atlin Hydro Expansion Project is located near the community of Atlin, BC, in the extreme
northwest of BC. The generation facilities are located within the Atlin Community Improvement
District, approximately 50 km from the Yukon border, while the transmission line is located primarily
within the Atlin Highway RoW extending to the Yukon border. The area is only accessible via the
Atlin Highway from Yukon’s Tagish Road. The Project area is geographically, culturally, and
economically connected with Yukon. The Project area is located entirely within the asserted
traditional territory of the Taku River Tlingit First Nation in both BC and it’s Yukon extent, as well as
the territory of the Carcross Tagish First Nation throughout its Yukon section, and several
kilometers into BC from the Yukon border.
The Project includes two hydroelectric facilities, (an upper and lower powerhouse), that are
proposed to be located on Pine Creek, an east-west flowing watercourse emptying into Atlin Lake
approximately 20 km downstream of its origin at Surprise Lake. The Project is to have overlapping
tenures with its sister company, Xeitl Limited, over much of the Project area, including portions of
the Surprise Lake shoreline, Surprise Lake control structure, the upper penstock, and upper
powerhouse site.
The proposed Project has the following key components:

Increase the water storage on Surprise Lake from 1.1 m to 2.0 m, by raising the water level
elevation up to 0.7 m over the current weir crest height and lowering its level by
approximately 0.20 m.

Construct and operate an upper powerhouse built onto Xeitl Limited’s existing facility, to
house a new Pelton turbine with an installed capacity of 5.7 MW.

Construct and operate a lower powerhouse holding a Francis turbine with an installed
capacity of 2.8 MW, located approximately 300 m from Atlin Lake.

Construct and operate a 25kv powerline – the line would bring power from the Lower
Powerhouse to a substation located adjacent to the Upper Powerhouse. It is proposed that
the line follow the penstock route.
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Construct and operate a 69kV powerline – the line would originate from the substation
adjacent to the Upper Powerhouse and travel north along the Atlin Highway to Jakes Corner
in Yukon Territory. The line will follow the road RoW for the majority of the route. A fiber
optic line would also be strung to network the operational centers of the generation facility
and substations, this provides operational communication between the power provider
(THEL) and the purchaser (YEC). The line requires the construction of a substation at each
of its start and its terminus.
PROJECT FOOTPRINT
The total footprint of the Project is 528 ha, with 400 ha located in British Columbia and 128 ha in
Yukon. The footprint located in British Columbia is comprised of 366 ha of unsurveyed Crown land,
22 ha of surveyed Crown land, and 12 ha of private land.
CONSULTATION AND ENGAGEMENT
ENGAGEMENT WITH TAKU RIVER TLINGIT FIRST NATION
Being a First Nation-owned company, consultation, and engagement efforts in the early stages of
Project planning and development were focused on engagement between the company’s Board
and TRTFN leadership, with leadership demonstrating support for feasibility work on the Project
through mandates to continue to invest in the Project. As well, the company continued to
communicate work and investment in the Project to its shareholders, TRTFN citizens, at the Annual
General Meeting for the Taku Group of Companies. A summary of issues and concerns discussed
with TRTFN is provided in Table 1.
Taku River Tlingit First Nation (TRTFN) Lands Department
In 2017, THEL began meeting with TRTFN Lands Department regarding its plan to develop a Clean
Energy Project proposal for submission to the Province and TRTFN, for the expanded hydro
operations on Pine Creek. Potential valued components were discussed with TRTFN Lands staff,
and a draft Terms of Reference (the Development Plan Template), was provided to TRTFN Lands
for their review and input in April 2018. TRTFN Lands provided input which was then incorporated
into the Terms of Reference; a marked-up version outlining how the comments had been
incorporated was also provided back to the TRTFN Lands Department Manager. TRTFN Land
Guardians were contracted to provide field work support for all other consultants undertaking
baseline studies in connection with the Project.
Engagement with TRTFN Lands has also included:

Discussing the adequacy and methods for consultation with government staff and citizens,

Discussing the Project through meetings with members of the TRTFN Lands Department,

Providing Project-related information to the TRTFN, including work plans, reference
documents, maps and imagery, where possible, and presentations,

Meetings/presentations summarized in CEDP Volume III, Section 7, and

Ongoing follow-up and communications via telephone and written communications.
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THEL has endeavored to ensure that:
-
-
We have participated in preliminary Regional Clean Energy Project Team RCEPT
meetings with TRTFN Lands and have worked collaboratively at these meetings.
Provided financial support to TRTFN Lands to hire a consultant to assist in their review
of the Project.
We have identified TRTFN interests and concerns in the Project area and addressed
them to the greatest extent possible, (Volume III, Section 7), including conducting
additional baseline work, engagement with citizens, and committing to additional
monitoring work as requested by TRTFN Lands Department.
Continued to seek and incorporate TRTFN input related to the scope of issues to be
considered in the Development Plan and to clarify specific consultation requirements
that need to be implemented during the assessment/review process.
Two different reservoir management schemes were considered and investigated, with the first being
2.0 m of storage range, and the second being 2.5 m of storage range. The 2.5 m storage range
would provide power for approximately four months of the year in the winter only, would require
larger turbines (therefore increased costs) and posed higher environmental and socio-economic
risks. In contrast, the 2.0 m storage range would maintain the currently licensed water level of
913.85 m and could produce the same power output but over a six-month period. As well, the 2.0 m
storage range was viewed as having fewer impacts to potential environmental and cultural values
studied. As a result of these factors, THEL decided on a 2.0 m storage range for the Project.
TRTFN Citizens/Shareholders
Engagement with citizens was generally organized by THEL as TRTFN Shareholder Meetings,
which were advertised as meetings separate from those organized for the broader Atlin community.
It was expected/hoped that these meetings could focus on TRTFN interests in the Project area.
Three Shareholder meetings were hosted, with attendance at only one of those meetings. In spring,
2020, TRTFN Lands Department indicated that engagement with citizens should be undertaken in
cooperation with the Lands Department and raised concerns over the adequacy of engagement
with citizens. A meeting was subsequently planned in cooperation with TRTFN Lands but was
subsequently cancelled at the request of TRTFN Lands Department due to a scheduling conflict. In
September 2020, a week-long series of boat tours on Surprise Lake was organized, which was
attended by TRTFN Lands staff and TRTFN citizens. THELP has now turned its focus to future
engagement with citizens during the review process for this CEDP.
Table 1: Summary of issues raised during engagement/consultation with First Nations.
FIRST NATION
CONSULTED
DATES OF
MEETINGS, CALLS,
CORRESPONDENCE
SUMMARY OF ISSUE
RAISED AND
PROPOSED SOLUTIONS
MITIGATIVE MEASURES ADOPTED
TRTFN
Oct. 2, 2019
Archaeological Sites,
particularly at Surprise
Lake Cultural A Sites
THEL will conduct Archaeological
Impact Assessments of Surprise
Lake and Project Area.
THEL will develop a Long-term
Archaeological Monitoring Plan for
Surprise Lake.
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FIRST NATION
CONSULTED
TRTFN
DATES OF
MEETINGS, CALLS,
CORRESPONDENCE
SUMMARY OF ISSUE
RAISED AND
PROPOSED SOLUTIONS
Jun. 6, 2020 and
Jun. 17, 2020
Cultural A Sites at Pine
Cup Creek and Granite
Creek
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MITIGATIVE MEASURES ADOPTED
THEL will manage water levels on
Surprise Lake to limit exceedances
of the 913.85 m elevation to the
greatest extent possible.
Commitments related to long-term
monitoring and adaptive
management for archaeology and
wildlife values.
TRTFN
Oct. 21, 2020
Integrity of Pine Cup
Creek spit from
inundation and erosion
THEL will develop a Long-term
Geomorphology Monitoring Plan that
includes monitoring
geomorphological processes,
including erosion and deposition,
changes to beach formations, and
ice-related impacts.
TRTFN
Aug. 13, 2020
Concerns with
migrating sheep at Pine
Cup Creek and other
wildlife values
THEL will develop a Long-term
Wildlife Monitoring and Adaptive
Management Plan in consultation
with TRTFN.
THEL will ensure that employment
opportunities are provided to TRTFN
citizens in implementation of the
Plan.
TRTFN
Oct. 21, 2020
Integrity of beach
formations at other
identified recreational
beaches
THEL will develop a Long-term
Geomorphology Monitoring Plan that
includes monitoring
geomorphological processes,
including erosion and deposition,
changes to beach formations, and
ice-related impacts.
TRTFN
May 6, 2020
Concordance with the
ATLUP and Tlatsini
Vision
THEL will manage water levels on
Surprise Lake to limit the magnitude,
frequency and duration of
exceedances of the 913.85 m
elevation.
TRTFN
Dec. 2, 2020
Safety/stability of ice on
Surprise Lake from 2.0
m drawdown
THEL will include monitoring of ice
stability as part of the
Geomorphological Monitoring Plan
and will provide information to the
public regarding ice stability,
thickness, and/or safety.
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DATES OF
MEETINGS, CALLS,
CORRESPONDENCE
SUMMARY OF ISSUE
RAISED AND
PROPOSED SOLUTIONS
TRTFN
Nov. 7, 2019;
Apr. 29, 2002 and
Oct. 7, 2020
Grayling spawning
channels on Surprise
Lake
THEL will develop an Aquatic
Resources Monitoring Program in
consultation with TRTFN, which will
include surveys of Grayling
spawning channels on Surprise
Lake.
TRTFN
Nov. 7, 2019; Dec. 5,
2019 and Oct. 7,
2020
Otter Creek
Reclamation for
grayling off-set
THEL will propose habitat off-setting
at Otter Creek in the Fisheries Act
Authorization, in accordance with
TRTFN’s recommendation.
FIRST NATION
CONSULTED
MITIGATIVE MEASURES ADOPTED
ENGAGEMENT WITH CARCROSS TAGISH FIRST NATION (CTFN) AND TESLIN
TLINGIT COUNCIL (TTC)
Funding for the Yukon portion of the transmission line feasibility study was also acquired by the
Yukon Clean Energy Alliance (YCEA), a non-profit comprised of members from TRTFN, CTFN, and
the Teslin Tlingit Council (TTC), whose mission is to explore renewable energy project potential in
the traditional territories of the inland Tlingit nations. However, formal consultation with CTFN and
TTC first occurred in February and March 2018, respectively. Meetings were held between THELP
and the CTFN Land Management Board and THELP and the TTC Lands Department and
Executive Council. Additional meetings were held in spring/summer 2020. No substantive concerns
have been articulated by either CTFN or TTC to date.
ENGAGEMENT WITH THE PUBLIC AND STAKEHOLDERS
Engagement activities began in 2015 during the pre-feasibility phase and have continued
throughout. THELP’s engagement strategy was to meet with the public as work and/or feasibility
studies were completed, or when it was determined there was a need based on public interest for
updates. Engagement was often focused on information-sharing, with public meetings used as a
venue for presenting the project design and baseline studies undertaken, as well as high-level
overviews of Valued Components (VCs) included in the Clean Energy Development Plan (CEDP).
Information on the regulatory review process was provided, as well as contact information for the
Province and TRTFN Lands Department. In total, there have been eight (8) public meetings since
the beginning of the pre-feasibility phase in 2015, two days of boat tours on Surprise Lake that were
open to the public, eight (8) meetings with stakeholders, including private individuals and the Atlin
District Board of Trade, and numerous other formal and information communications with the public
and stakeholders.
Information from the public regarding land use and community values was documented and used to
inform the scope of VCs in the Development Plan, as well as identifying potential effects. THELP
also met with specific agencies, including the Atlin District Board of Trade (ADBOT) and the Atlin
Community Improvement District (ACID), to discuss the proposed project and potential impacts.
Private engagement sessions were also held with residents of the Monarch Mountain area, South
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Pine Drive, and landowners directly adjacent to and overlapping with project infrastructure, as well
as one placer miner with an active mine overlapping the proposed power canal.
A summary of authorizations expected to be needed for the Project is provided in Table 1. Table 2
provides a summary of issues raised by the public, and a summary of TRTFN’s issues is shown in
Table 3. Additional information regarding TRTFN’s concerns and consultation with First Nations is
provided in CEDP Volume III Section 7 and in Appendices 1 and 2. Additional information regarding
engagement with the public is provided in CEDP Volume III Section 6 and in Appendix 3.
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Table 2: Summary of issues raised by the public.
GROUP
CONSULTED &
CONTACT NAMES
Open House,
Presentation
DATES OF
MEETINGS, CALLS,
CORRESPONDENCE
Nov. 19, 2015
SUMMARY OF ISSUES RAISED & PROPOSED SOLUTIONS
MITIGATIVE MEASURES
ADOPTED OR NOT ADOPTED
PROPONENT COMMENT
Process for Engagement
Informed scoping of VCs for CEDP
N/A
Project Purpose and Phase
Informed scoping of VCs for CEDP
N/A
 Questions/concerns about who the power is for and what phase the proposal is in
Conducted a study of Project socioeconomic benefits and presented to
community
 Permit to conduct geotechnical work, i.e., blasting. People upset that blasting occurred without proper
notice. Apology from Peter Kirby and Stuart Simpson and commitment to better engagement going
forward.
~70 people
Socio-economic Concerns
 Question/concerns about potential impacts to wells, recreation, viewscapes, property impacts, and
adherence to the Atlin Land Use Plan in relation to Pine Creek.
 Pine Creek beach, Monarch Mountain trail and properties most significant area of concern.
 Concerns/questions about the benefits of the Project compared to the impacts and the equity of
impacts.
Environmental Concerns
 Effect of water withdrawals on Pine Creek on ecology, fishing values, and beach.
Changes to Surprise Lake ecology.
 Reiterated that no project has been confirmed yet. Commitment to transparent public engagement.
Meeting with
Atlin Community
Improvement
District (ACID)
Dec. 2, 2015
 Unexpected blasting for geotechnical work was cause for concern.
Atlin Land Use Plan
 Discussed the intent of the LUP and sections pertaining to Pine Creek. Those present indicated that a
powerhouse was not an appropriate land use in their view.
 View that recreation areas should be run/driven by public interest, not private, and LUP language should
reflect that.
Community Consultation and Process for Engagement
 ACID requested that FLNRO speak to ACID directly.
 ACID wants representation in development process and planning.
 Discussion about whether ACID needs a representative going forward; questions about being
premature since no project has been formally proposed/designed yet; concerned that non-TRTFN
voices will be ignored.
Economic Development
 Would like the community needs to be considered foremost in project development before project
feasibility/viability.
 Questions about project economic benefits.
 Support for First Nation to increase revenues and for a project that is good for the larger community as
well.
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GROUP
CONSULTED &
CONTACT NAMES
DATES OF
MEETINGS, CALLS,
CORRESPONDENCE
Atlin Community
Meeting – open
to all residents
re: draft
Transmission
Line Feasibility
Study
Feb. 21, 2018
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MITIGATIVE MEASURES
ADOPTED OR NOT ADOPTED
SUMMARY OF ISSUES RAISED & PROPOSED SOLUTIONS
Purpose
 Overview of the draft feasibility study of the transmission line, including alignment, design, aesthetic.
Solicited feedback on design and alignment, and potential impacts to values and/or stakeholders.
Discussion
 Maps of the alignment were laid out on a long table following a short presentation, and residents were
asked to identify anything of concern on the maps. Notes were also taken on large sheets of values
and/or noted concerns and sites of interest after presentation as a group. No major concerns identified –
primary comments around mitigation in construction, hiring locally, possibility of a lineman position.
Values identified related to trails, aesthetics, and moose habitat in alkali flats area.
~ 25 residents
present
Planning to hire locally to the greatest
extent possible.
Will investigate the potential for a local
lineman in operation of the transmission
line.
Alignment on east side of Atlin Highway to
minimize impacts to aesthetics
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PROPONENT COMMENT
THEL will ensure adequate capacity to deal with
emergencies affecting the highway RoW, through
such measure including, but not limited to:
Provision of a lineman and crew that is able to
respond to emergencies in a timely manner, as
determined/required by MoTI;
Provision of line maintenance and inspection in
accordance with, at a minimum, standards
employed by BC Hydro;
Provision of any other measures required by MoTI
to ensure the safe and effective management of
the transmission line located in the RoW.
(
Ltd.)
Atlin Community
Meeting re:
updates on the
feasibility
studies
Mar. 21, 2018
 Discussed with
the project concept and the overlap of the currently proposed canal route with his
placer mining property.
was generally cooperative and supportive and indicated that he would like
to walk the canal route with us and discuss further when we are ready to do additional reconnaissance
in May. He will do some drilling to determine the need to mine near the canal route.
N/A
Hire
Nov. 26, 2018
Purpose
N/A
N/A
Purpose
All concerns addressed in CEDP.
THEL will construct walkway over tailrace
 To provide project updates and get feedback from residents regarding components of the lower
powerhouse, such as tailrace, location of the powerhouse, and penstock alignment.
Substation will remain at upper
powerhouse as it is most economically
and more energy-capture efficient to do
so.
THEL to create recreational trails and opportunities
in Pine Creek flats area, and will ensure consistent
visual aesthetics, as described in CEDP Volume III,
Section 5.3.
No changes to project design are being
investigated further.
The Proponent will ensure that noise from the
powerhouse is within an acceptable decibel range
(dBA and dBC) that is based on the existing
ambient noise at residences.
 To provide updates on the completed transmission line feasibility study and the progress of the
generation facility feasibility study and baseline program.
Discussion
 Feedback on the project concept to date and information shared was not actively solicited. The main
purpose of the meeting was to convey what work was being done/had been done, to keep the
community informed of where we are in the process. Changes to the lower powerhouse design made
since meetings in 2016 and based on community concerns were shared. Commitment to future
updates/meetings in summer on main project design.
~14 in
attendance
Meeting with
for test pits on his mine site.
Jun. 21, 2019
,
residents on
Monarch
Mountain and
Pine Creek
Discussion
 THEL presented the most recent project concept/design and updates for the upper and lower
powerhouses and infrastructure. Comments/discussion included:
- Why not move substation to ATELP area at Como
- Impacts to beach at Pine Creek still biggest concern, including from tailrace, fish habitat (lake trout),
and community use (noise, visibility, trails).
- Powerline/penstock biggest issue for
-
.
suggested other location for powerhouse on Spruce Creek.
- No suggestions for ulterior tailrace location but would like walkway over to access creek.
- Support upper powerhouse project but not lower powerhouse.
Noise abatement measures will be designed and
implemented in accordance with the advice and
recommendations of an acoustic engineer and may
include post-construction monitoring to confirm the
effectiveness of noise abatement strategies.
Fish habitat being developed in lower tailrace.
Penstock RoW adjacent to
not overlap.
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ENGAGEMENT WITH REGULATORS
Engagement with FLNRORD staff regarding the Project began in December 2017 with a meeting in
Smithers to provide a Project overview and discuss the regulatory process. This was followed by
numerous emails and telephone calls. Two FLNRORD staff toured the Project sites on July 22,
2019.
Engagement with BC MoTI began in November 2019 with a phone call between THEL and MoTI
staff. There has been ongoing engagement since that time.
A phone meeting in August 2020 initiated engagement with Fisheries and Oceans Canada.
A full summary of engagement with regulators is shown in Appendix 4. Table 3 lists approvals and
authorizations required and their statuses as of April 2021.
Table 3: Summary of agency approvals required.
AGENCY
FLNRORD
AUTHORIZATION/
APPROVAL
REQUESTED
Change
Notification
STATUS
To be
submitted
COMMENTS
CONTACT
Andrea Scarth, Senior
Project Manager
Andrea.Scarth@gov.bc.ca
FLNRORD
Water License
Application
submitted
Andrea Scarth, Senior
Project Manager
Andrea.Scarth@gov.bc.ca
FLNRORD
FLNRORD
FLNRORD
Permit Over
Crown Land
To be
reviewed
after
submission
of
developmen
t plan
Andrea Scarth, Senior
Project Manager
General Area
License of
Occupation
Pending
Andrea Scarth, Senior
Project Manager
Occupant
License to Cut
To be
Submitted
Andrea.Scarth@gov.bc.ca
Andrea.Scarth@gov.bc.ca
Andrea Scarth, Senior
Project Manager
Andrea.Scarth@gov.bc.ca
FLNRORD
Recreation Site
Authorization
To be
Submitted
Andrea Scarth, Senior
Project Manager
Andrea.Scarth@gov.bc.ca
MoTI
Utility Permit
To be
Submitted
Daena Bilodeau Cooper,
Senior Development
Officer
Daena.BilodeauCooper@
gov.bc.ca
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AGENCY
AUTHORIZATION/
APPROVAL
REQUESTED
BC Ministry
of Energy,
Mines, and
Low Carbon
Innovation
Quarry License
MoTI
Permission to
Construct within
Crown Land
STATUS
COMMENTS
To be
Submitted
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CONTACT
Andrea Ross, Senior
Inspector of Mines
Permitting
Andrea.Ross@gov.bc.ca
To be
Submitted
Daena Bilodeau Cooper,
Senior Development
Officer
Daena.BilodeauCooper@
gov.bc.ca
MoTI
MoTI
Permission to
construct, use
and maintain
access to a
highway
To be
Submitted
Permission to
construct works
on a highway
To be
Submitted
Daena Bilodeau Cooper,
Senior Development
Officer
Daena.BilodeauCooper@
gov.bc.ca
Daena Bilodeau Cooper,
Senior Development
Officer
Daena.BilodeauCooper@
gov.bc.ca
Fisheries
and Oceans
Canada
Taku River
Tlingit First
Nation
Fisheries Act
Authorization
(FAA) for a
HADD (Section
35 Fisheries Act)
To be
Submitted
Project Approval
Ongoing
engagement
FAA is currently in
development. The
Proponent met with
Katherine Znotinas and
Dan Sneep, DFO, on Aug.
7, 2020, to discuss
application and were
advised to apply directly
for the FAA rather than
requesting a review.
Biologist, Fish and Fish
Habitat Protection
Program
Katherine.Znotinas@dfompo.gc.ca
Charmaine Thom
Lands Manager
TRTFN is part of the Clean
Energy Development Plan
review and comment
process.
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Katherine Znotinas,
Lands, Resources and
Fisheries Department
Lands.mgr@gov.trtfn.com
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AGENCY
Transport
Canada,
Navigation
Protection
Program
(NPP)
AUTHORIZATION/
APPROVAL
REQUESTED
NPP
authorization for
Water Control
Structure
STATUS
Submitted
Dec. 18,
2020
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COMMENTS
CONTACT
File No. 2020-503488 has
been assigned.
Lawrence Kuan
A letter dated Dec. 23,
2020 identified additional
information for the
submission (top/plan and
side/profile drawings with
dimensions). Revised
content was sent on
Jan. 15, 2021.
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Navigation Protection
Program
Programs Group
Transport Canada, Pacific
Region
lawrence.kuan@tc.gc.ca
KEY PROJECT EFFECTS AND PROPOSED MITIGATION
ASSESSMENT APPROACH
Assessments of the Projects potential environmental, economic, social, heritage and human health
effects were conducted based on the following framework:

Identification of Valued Components (VCs) and potential interactions with the applicable
baseline conditions, the latter described based on site studies and other forms of information
gathering;

Assessment of potential Project effects on VCs in the absence of mitigation measures;

Identification of mitigation measures that avoid and/or minimize potential Project effects; and

Determination of whether or not there are residual Project effects (i.e., effects after
application of the identified mitigation measures), and characterization of their significance.
AQUATIC ENVIRONMENT
Valued components considered included Fish and Fish Habitat, Amphibians and Water Quality.
Pine Creek is approximately 21 km long with mean annual discharge of 5.1 m3/s, originating at
Surprise Lake and flowing westward to its outflow at Atlin Lake. The Creek supports Arctic grayling
and Slimy sculpin, while other species may use the lower reaches at Atlin Lake on occasion.
However, Pine Creek has two notable natural hydraulic fish barriers, (bedrock canyon waterfalls),
which prevent fish passage to the upper reaches of Pine Creek. Fish habitat and use assessments
completed for the system over the past decade and in conjunction with this Project indicate that the
most significant fish habitat is located in Upper Pine Creek from the outlet of Surprise Lake
downstream to the proposed Upper Pine Creek control structure, with good habitat located in the
Upper Bypass reach to Birch Bridge. Spring Creek, a tributary located in Upper Pine Creek, was the
only tributary with confirmed spawning activity.
Surprise Lake is a large oligotrophic lake approximately 24 km in length and a maximum width of 2
km. Like Pine Creek, Surprise Lake supports Arctic grayling and Slimy sculpin. There are several
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important spawning tributaries on Surprise Lake, of which the most significant was observed to be
at the outflow of Pine Cup Creek. Groups of adults migrate from Surprise Lake to Pine Creek during
the spring spawning, and from Pine Creek to Surprise Lake in late summer/early fall. At present,
fish may use the existing fish ladder, the outflow gated culvert, and/or the overflow rock weir when/if
there is adequate flow.
In the absence of mitigation during construction, in-stream works would impact fish habitat in Pine
Creek and at the outflow of Surprise Lake. These include the construction of three control structures
(Surprise Lake, Upper Pine Creek, Lower Pine Creek); the diversion of Spruce Creek; excavation of
sediments at Surprise Lake outflow and Upper Pine Creek; and construction of a tailrace into Atlin
Lake. These in-stream works could cause direct harm to fish and fish habitat, particularly during
spawning season, including via in-stream sedimentation, and the release of contaminants (e.g.,
hydrocarbons). Mitigation measures to address these potential effects include the use of timing
windows, fish salvage, sediment control and equipment maintenance and monitoring, along with a
range of specific mitigation in the environmental management plan designed to protect water
quality. With mitigation, no significant adverse effects to the VCs during construction have been
identified.
In terms of operations, the main project effect is the permanent alteration and/or loss of fish habitat
due to reductions in flow in Pine Creek, as well as diverting the lower 120 m of Spruce Creek. The
lowest proposed flows on Pine Creek are about 10% of the Mean Annual Discharge (MAD), which
is approximately 0.5 m3/s. While the low flow volumes are still protective of the productivity of fish in
Pine Creek, it will result in loss of habitat due to an average 20% decline in the wetted width and
off-channel habitat. However, in Upper Pine Creek flows will be much higher (minimum of 1.6 m3/s)
since flows must be high enough to supply the existing plant downstream, as well as to maintain a
minimum flow in lower Pine Creek, and both fish habitat and productivity will not be adversely
affected there. To mitigate effects from flow diversions, the project design includes measures to
ensure that habitat features are maintained and/or replaced, including in Upper Pine Creek and the
Spruce Creek diversion. As well, the proposed lower tailrace into Atlin Lake will be designed to
include fish habitat features. Other habitat compensation measures will be applied to Otter Creek, a
tributary of Surprise Lake, at the request of TRTFN.
The operation of the reservoir on Surprise Lake will result in a 2.0 m drawdown from high water in
the late fall to low water in the early spring. Geomorphological and fisheries assessments
concluded that spawning tributaries and grayling spawning activities would not be impacted by the
0.5 m increase to high water above baseline conditions, and the 0.2 m decrease to low water. In
terms of water quality, it is not expected to be impacted during operations. For example, water
quality on Pine Creek is expected to improve due to the capture of sediments in a settling pond
above the Spruce Creek diversion.
Although the project will create about 20,000 m2 of pool type habitat, which is important for Arctic
grayling, the Project is likely to cause a significant adverse effect to Arctic grayling habitat due to
changes in flow in Pine Creek. Details of the compensation required for this effect will be defined in
the Fisheries Act Authorization that the proponent is seeking from Fisheries and Oceans Canada.
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ATMOSPHERIC ENVIRONMENT
The Project involves the use of heavy equipment for clearing, pole installation, and site preparation
for infrastructure, in addition to excavation of diversion channels, the power canal and penstocks.
As well, construction activities will require the extraction, screening, crushing, stockpiling, and
transport of aggregate materials. With the implementation of standard mitigation measures, the
residual effect on air quality is expected to be not significant.
The Project will provide renewable energy to the Yukon’s isolated electrical system. This electricity
will displace some of the diesel and natural-gas-fired electricity that is currently generated by Yukon
Energy Corporation. Total greenhouse gas (GHG) reductions from 2024 to 2035 will be on the order
of 354,000 tonnes CO2e, or up to 29,500 tonnes CO2e/year. The long term GHG emission
reductions will result in a significant beneficial effect to the atmospheric environment.
GEOPHYSICAL ENVIRONMENT
Valued components selected for this component included Surface Hydrology, Geomorphology,
Geotechnical/Slope Stability, and Geology.
Surface Hydrology
Details of changes to surface hydrology are provided in the CEDP. However, it is not considered a
valued component in and of itself. Rather, it affects other components such as fish and fish habitat.
Factors considered included stream flow and hydraulics, lake levels and storage range
management, and ice management. The surface hydrology will be altered by the following activities:

Increasing the storage range on Surprise Lake from 1.1 m to 2.0 m. The current high water
will be reached about two weeks later than presently occurs, in the second week of July,
and will continue to increase to about the end of August, when the full supply level is
expected to be reached.

Flows in Pine Creek will be reduced due to diversions into the upper and lower penstocks,
with the lowest flows being in the middle by-pass reach (0.5 m3/s) and the highest low-flow
scenarios being in Upper Pine Creek (1.6 m3/s). The changes in flow will reduce the wetted
width of Pine Creek.

The re-development of an 8 km long power canal with flows of approximately 4.7 m3/s in
winter, and the development of a 600 m power canal at the lower penstock. The use of
power canals will require the rapid development and maintenance of an ice cap.

Development of a 500 m long tailrace into Atlin Lake.
The effects of these activities and their management implications are described in the CEDP,
including monthly flow releases from Surprise Lake; potential seepage along the power canal; and
management of Surprise lake water levels. As well, expected trends due to climate change are also
considered, in terms of the long-term sustainability of the Project. Hydrology monitoring and climate
trends indicate that the Project can be operated within the proposed parameters now and into the
future.
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Construction of the control structures, intake structures/diversion works, rock-fill weirs, water
conveyance system, powerhouses, and tailraces will require temporary diversions of Pine Creek to
allow a dry working environment, wherever possible. Diversions are expected to be short duration
and will only affect hydraulics in the vicinity of the construction area. Instream work will be timed
during low flow seasons, but outside the Arctic grayling spawning timing window wherever
necessary. Excavations of Surprise Lake outflow and Upper Pine Creek will not be able to be done
in the dry but will occur in low flow conditions. Various mitigations have been identified for
construction methodology, which are generally outlined in the Construction Environmental
Management Plan.
During Project commissioning, diversion of flow from the intakes to the tailraces of the upper and
lower powerhouse infrastructure will reduce the stream flows within the diversion reaches. Due to
the existing hydro facility on Pine Creek, there will be three diversion reaches: Upper Bypass
Reach; Middle Bypass Reach; and Lower Bypass Reach. During normal Project operation, water
flow depth and velocity in the diversion reaches of Pine Creek will be less than baseline levels due
to water being diverted to the powerhouses. Downstream of the upper powerhouse and proposed
upper powerhouse, all the flows will be diverted into the lower powerhouse intake, as well as flows
from Spruce Creek. In addition to water diversions, hydraulic changes to Pine Creek are expected
throughout the system due to management of the Surprise Lake reservoir. Since water will be
controlled from entering Pine Creek from May to October, summer flows will be less than baseline
conditions.
Instream Flow Requirements (IFRs) are set for projects withdrawing water from a stream to ensure
the protection of fish and fish habitat and channel morphological process. Based on the site
conditions for the Project, an IFR of 0.5 m3/s is proposed for the lower bypass reach. The
assessment concluded that with implementation of the design and operational mitigation measures,
the Project will not have significant adverse effects on hydrology VCs.
Geomorphology
Geomorphology is characterized for both Pine Creek and Surprise Lake but was also not
considered a valued component in and of itself. The CEDP includes descriptions of the primary
geomorphological processes influences the landforms and morphological features of these
waterbodies. On Pine Creek, the extensive history of placer mining has played a critical role in
shaping its channel morphology, including the large alluvial delta at its outflow at Atlin Lake.
Surprise Lake is also influenced by placer mined creeks and an historic control structure that raised
its water level to 914.0 m, resulting in potential sources of sediments and erosion-prone areas.
Surprise Lake is characterized by steep-sided slopes, with low-lying areas coinciding with creek
outflows, limiting the spatial extent of inundation. There are two notable barrier beaches with
backwater lagoons, one at Hemlock Creek and one at Pine Cup Creek, in addition to several other
sandy beaches with high berms. The increased inundation is predicted to increase the areas of
erosion in the medium term before reaching an equilibrium, which will continue to add sediments to
the downwind beach area located in depositional zones. It is expected, therefore, that these
landforms and notable features will persist over time on Surprise Lake. Although the
geomorphology of Surprise Lake is not expected to be notably affected and/or altered, THEL has
committed to monitoring of geomorphological processes and changes, due to the relative
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importance of its influence on other valued components, including wildlife habitat, recreational
beaches, and Cultural Sites.
Pine Creek morphology will also be affected by the reduced flow. At present, Pine Creek exhibits
relatively stable channel characteristics. Given the lack of large floods in the watershed, opportunity
for re-mobilization and sediment flushing is limited. Generally, Pine Creek does not have the
capacity to adequately carry its sediment load, which usually end up travelling only short distances
downstream when flood events occur. This, combined with no further significant deposition of
sediment from mining activities, should result in the lower reaches of Pine Creek recovering from
past disturbance and becoming progressively more stable over time.
Geomorphological processes along the transmission line route were also considered. Given the
location of the transmission line within the existing RoW; the soils in the region; the limited clearing
proposed; and the limited permafrost potential, and predominantly southwest facing slopes;
geomorphological impacts from the 5 to 7 m of additional clearing along the RoW, such as erosion,
permafrost thawing, and/or slumping, were determined to be unlikely.
Geotechnical/Slope Stability
Geotechnical and slope stability are described both in terms of their ability to support various project
infrastructure, as well as the potential short-term and long-term impacts from construction activities.
The primary effects identified included changes in slope stability related to various project
infrastructure (e.g., power canals, penstocks, powerhouses, and transmission line alignment),
erosion, and winter flooding and channel avulsion at the lower tailrace.
Detailed geotechnical studies were completed for the power canal infrastructure and components of
the lower penstock and lower powerhouse, with other areas having already known conditions (e.g.,
upper powerhouse site and upper penstock), and/or having lower risk (e.g., placement of powerline
poles). The project design, including the transmission line alignment, considered geotechnical
information, and mitigation were included and outlined (e.g., geotextile liner in the power canals;
slope requirements on various structures, etc.). In terms of construction activities, additional
mitigation are included in the environmental management plan to manage surface erosion and to
ensure the stability of structures. With the application of mitigation and the project design measures,
no significant adverse residual effects were identified.
Geology
The Project requires the use of fill material, cobbles and rip rap for the construction of various
structures. An analysis of the potential sources and volumes of rip rap and cobbles was provided,
including their geology and Acid Rock Drainage/Metal Leaching (ARD/ML) potential. An effort was
made to identify existing source material, including placer mining rock dumps, to minimize new
disturbance required for Project construction. The materials identified do not present a risk of
ARD/ML, and therefore, no significant adverse residual effects are anticipated.
TERRESTRIAL ENVIRONMENT
Valued components considered for this component included wildlife and wildlife habitat, rare plants
and ecosystems at risk, and forest and range considerations.
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Wildlife and Wildlife Habitat
Wildlife VCs selected for the Project are waterfowl and shorebirds (particularly Arctic terns), raptors
and other birds, ungulates, large mammals & furbearers, and other species at risk wildlife. Potential
effects to species listed under the Species at Risk Act were considered under species at risk, as
well as during the selection of indicator species including but not limited to raptors, at risk bird
species and caribou.
Project physical works have potential to interact with or affect wildlife VCs in the following ways:

Habitat Loss: direct footprint disturbances that permanently or temporarily remove habitat.

Habitat Avoidance: abandonment (herein referred to as avoidance) of habitat when wildlife
is subjected to visual or auditory stimuli that elicit a response.

Habitat Fragmentation: loss of formerly continuous habitat by dividing large habitat patches
into smaller patches and/or restricting movement between these patches.

Mortality: includes the potential for vehicle collisions with wildlife and the possible need for
control of habituated problem wildlife.
The Project has been designed to avoid and reduce effects on wildlife through minimizing the
development footprint and siting facilities in areas of existing disturbance, including along existing
access routes, the existing placer mining ditch for the power canal, the upper penstock route, and
the RoW of Warm Bay Road and the Atlin Highway. Additionally, mitigation measures have been
proposed to implement best management practices, including avoiding clearing during the bird
nesting window, minimizing wildlife interactions, and reclaiming temporary construction sites. The
assessment concludes that with the application of mitigation measures, there will be no significant
residual Project effects on the wildlife VCs.
In terms of Surprise Lake, inundation will result in the seasonal and potential long-term reduction of
low-lying habitats for part of the year, particularly wetland areas. This habitat loss is not expected to
affect nesting birds, including Arctic terns, since high-water levels will typically be delayed from
existing conditions, allowing additional time for birds to complete nesting activities. Inundation will
result in only a small amount of overall habitat loss, but where/if it affects wildlife movements, (e.g.,
mountain goats at Pine Cup Creek), it can have a disproportionate impact on wildlife. As such,
although no significant residual effects to wildlife are anticipated, THEL has committed to
undertaking long-term wildlife monitoring in response to concerns from TRTFN, and to better
validate our predictions.
Rare Plants and Ecosystems, Forest and Range Considerations
Considerations for these components include the presence of rare plants and ecosystems, forest
health, and invasive species management. Generally, effects to these components may occur from
clearing and grubbing activities, creation of linear corridors with the potential for blow down, and the
creation of vectors for invasive species to spread. Pre-construction surveys and regular surveys
during vegetation maintenance activities are recommended for identifying rare plants and invasive
species, along with a suite of other best management practices for preventing the introduction of
invasive species. An invasive species management plan will be developed as part of the permitting
process.
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REGIONAL ECONOMY
The assessment of this component considers the increase in employment opportunities during
construction and operations, as well as the impact of a dividend benefit that will be reinvested in the
Atlin community. The benefits accrued to the TRTFN were also considered more explicitly, such as
own-source revenues and capacity development, as well as intangible benefits such as pride. Since
the Project is locally owned, its benefits to the local and regional economy are significant. In order
to mitigate the potential short-term effects to other economic activities, such as tourism, mitigation
was identified primarily relating to adequate notification to the public and effective traffic
management measures. However, improvements to recreational resources have also been
identified, including the Atlin Campground and several trails, which is expected to add value to local
and visitor experience. The Project is, therefore, expected to result in a net benefit to the regional
economy.
LAND USE AND TENURE
Land use and tenure are considered in terms of potential construction and operation effects to
residential users in the vicinity of project infrastructure, particularly the lower powerhouse and
penstock, and other land and mineral tenures.
Key project infrastructure is located in the vicinity of residences, including on Surprise Lake Road
and along Warm Bay Road, where the lower powerhouse and lower penstock will be located. There
will be temporary access and disturbance on Upper Pine Creek on private property (Ackerman
Farm)1. During construction, project activities could affect residential use by creating noise and
traffic delays, which can affect the use and quiet enjoyment of personal property. Mitigation to
reduce the impact of construction activities includes design solutions to avoid overlap with private
property, as well as development of a traffic management plan and adequate notification to
residents regarding the timing of planned construction activities. These impacts can be managed
with best practices for construction, and given the generally short-term nature of construction
activities, are not expected to result in significant adverse residual effects.
In addition to construction, the operation of the Project was identified as impacting residential use
along Warm Bay Road without mitigation. For example, a primary concern from residents was the
creation of noise from operation of the lower powerhouse, as well as impacts to visual aesthetics.
However, the lower powerhouse will be designed with sound dampening measures based on
recommendations from an acoustic engineer. With the location of the powerhouse below a hill and
approximately200 m from the nearest residence, significant residual effects from noise are not
anticipated. Visual aesthetics are proposed to be managed by incorporating aesthetics into the
building design, and adequate and timely revegetation of disturbance.
The temporary construction access through the Ackerman Farm property accounts for the private land
identified for the project footprint.
1
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PUBLIC OUTDOOR RECREATION
Many of the values in the project area were included under the scope of Public Outdoor Recreation.
These included potential impacts to official Recreation Sites and Trails, informal local trails and
community use areas, recreational beaches on Surprise Lake, and visual aesthetics within the
community and on the Atlin Highway, including Pine Creek Falls. Many areas are identified in the
Atlin – Taku Land Use Plan as having recreational importance to the community, which was used
as a context for evaluating impacts to this valued component.
Impacts from construction were generally short-term and mitigated in the same way as for
residential use, by best practices including providing adequate, timely and visible notification to the
public of construction activities, including traffic delays, such that expectations are managed.
In terms of operations, the lower powerhouse site, flow reductions in Pine Creek, and inundation on
Surprise Lake, had the greatest impact on this valued component. For the lower powerhouse, there
was public concern regarding the potential incompatibility of the lower powerhouse within a land
use designation for the Use, Recreation and Enjoyment of the Public (UREP), and in relative
proximity to the Pine Creek beach, a popular destination for locals and tourists. Although this UREP
designation was removed from the area in June 2020, the assessment still considered the values of
the designation relevant to the site. However, through the use of noise mitigation, and given that
the powerhouse is generally not expected to operate from May to October, negligible effects were
anticipated. However, the proposed tailrace will change the visual aesthetics of the Pine Creek
beach, as it will require a large berm that will function as a service road and would otherwise not be
passable by foot traffic.
To mitigate these effects and provide a net benefit for recreational use values at this location THEL
has committed to developing a publicly accessible trail that is accessible to those with mobility
issues along the tailrace service road, and which will contain a pedestrian overpass over the
tailrace. This trail may include interpretive signs and benches, and locations from which to fish.
Further, THEL plans to work with the community to design and plan a recreational trail network in
the Pine Creek beach and flats area that could connect Pine Creek beach with other areas,
including the campground, which would be maintained by THEL.
Higher water levels on Surprise Lake were also identified as affecting some beach areas. A total of
eight beach areas were identified as having particular recreational values, including the Surprise
Lake Recreation Site. Some of these areas have low-lying wetlands that would become inundated
from mid-July onward. However, most of the areas contain berm beaches formed by depositional
processes and high-water/high-wind events and are expected to persist over time. While inundation
will occur, beaches and campsites will remain largely accessible. Even low-lying areas such as at
Cracker Creek and Ruby Creek generally contain camp sites that are located on higher ground,
which will remain accessible. The assessment concluded that these effects are not expected to be
significant.
Finally, the impact to the visual quality of Pine Creek Falls was considered. Although visual quality
is subjective, the change in flow over the falls from greater than 6.0 m3/s to potentially as low as 0.5
m3/s will be noticeable. Qualifying the change to the visual quality of the falls is more challenging,
and photos have been provided of other waterfalls with similar low flows. Although this effect is
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highly subjective, THEL recognizes that, as a landmark, this change will be concerning for some
community members and may affect their sense of place.
The residual effects to Public Outdoor Recreation are determined to be not significant, since they
are primarily short-term and related to construction, and THEL has committed to improving
recreational opportunities wherever possible.
NAVIGATION, TRANSPORTATION AND ACCESS
The Project is located along and/or directly adjacent to numerous access roads and trails, with
several project components crossing public roads, including road crossings of the transmission line;
lower penstock; the upper penstock; the upper power canal across Surprise Lake Road; the lower
headpond; and the Surprise Lake control structure dam requiring upgrades to the road
embankment. Consequently, access and transportation are expected to be affected, primarily
during construction. The use of public roads by construction equipment was also considered, as
well as general work within the RoW. The impacts of these activities include traffic delays and
increased risk to public users, including in the event of an emergency. However, these effects will
be mitigated through applying best practices and adhering to applicable legislation. The
requirement for a traffic management plan that accords with the provincial traffic management
manual is also included in the Construction Environmental Management Plan. With the application
of various mitigation, no significant residual effects are anticipated.
In terms of navigation, the Project does require a permit to construct works in a Navigable Water.
However, given the existing navigation barriers on Pine Creek, its limited use, and the mitigation,
(e.g., warning signs; navigation booms, etc.), no significant residual effects are anticipated.
HEALTH AND SAFETY
The indicators for the VC of Human Health & Safety are wildfire and fire risk; traffic and road safety;
geohazards and infrastructure failure; and emergency response capacity and management. Within
the Project area, there are several region-specific emergency concerns that had to be considered,
including the risk of wildfire, dam failure, downed transmission lines, extreme weather events and
limited egress options for the community of Atlin. Much of the potential for impacts to health and
safety will be mitigated through design, particularly with respect to geohazards and infrastructure
failure. Regulatory requirements also serve to control the potential for significant impacts, including
the Dam Safety Regulation and Occupational Health and Safety Regulation.
Effects to Health and Safety will be further mitigated via the application of traffic management
requirements, and the development of numerous operation and procedural plans (e.g., Emergency
Response Plan, Occupational Health and Safety Standards, Dam Safety Monitoring and
Management, Fire and Wildfire Prevention Plan, etc.). The effects assessment concluded that the
application of various mitigation, the development of required plans, and adherence to applicable
legislation, will mitigate potential residual effects to health and safety so they will not be significant.
ARCHAEOLOGICAL RESOURCES
Archaeological Impact Assessments (AIAs) and Archaeological Overview Assessments (AOAs)
were completed for the Project area, including the transmission line to the BC-Yukon border. For
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those areas with AIAs, there was no overlap with archaeological resources and proposed project
infrastructure, which covered the majority of those areas associated with the generation facilities.
AOAs were completed for Surprise Lake and the transmission line route. These areas are generally
lower risk due to 1) the small increase in high water on Surprise Lake and its location within active
geomorphological zones; and 2) the location of the transmission line within an existing disturbance,
and the ability to adjust the alignment and/or span found archaeological resources associated with
the transmission line.
Although not expected, residual effects could occur in the event that a resource is uncovered during
construction, and along Surprise Lake in the event that shoreline erosion results in slumping of an
area containing an archaeological resource. For that reason, long-term annual monitoring of erosion
and archaeological potential, as well as an AIA for high potential sites along Surprise Lake, has
been proposed. With the application of the mitigation and proposed monitoring, significant residual
effects are not anticipated.
FIRST NATIONS INTERESTS
First Nations interests considered largely relate to those of TRTFN. These interests include
traditional and contemporary land use, economic interests, and accordance with TRTFN land
management objectives. The assessment identified potential effects to:

The integrity of cultural sites as identified in the Atlin – Taku Land Use Plan, particularly on
Surprise Lake

Hunting and trapping success

Wildlife and wildlife habitat

Camping sites and associated harvest areas on Surprise Lake

Ice travel on Surprise Lake, and

Fishing success.
In general, the assessment concluded that the Project will not result in significant adverse effects to
TRTFN interests based on the conclusion that wildlife and wildlife habitat will not be significantly
affected, as previously described. However, THELP committed to undertaking a long-term wildlife
monitoring program in recognition of the First Nation concerns and interest for wildlife management
in the area. Similarly, although the storage range was not expected to affect ice stability, given the
importance of the Lake to traditional winter use, THELP committed to monitoring ice stability and
notifying the public of ice conditions and/or safety concerns.
It is the Proponent’s view that the proposed Project aligns with the vision for conservation and
sustainability within the TRTFN traditional territory, as captured in the document Our Home is Our
Future: Taku River Tlingit First Nation Vision and Management Direction for Lands and Resources
(2003) and within the Atlin Taku Land Use Plan (ATLUP).
Impacts to the integrity of Cultural Sites were also considered, with Pine Cup Creek and Granite
Creek being the areas of greatest concern to TRTFN. Additional geomorphological studies were
undertaken to confirm that the depositional landforms and features on Surprise Lake, including Pine
Cup Creek’s noteworthy sand bar and backwater lagoon formation, would persist. THELP also
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committed to maintaining a high-water level consistent with the existing Permit Over Crown Land,
which allows for a high-water elevation of 913.85 m. Based on the conclusions of the wildlife,
geomorphology, and archaeology studies and assessments, and the various mitigation and
monitoring programs committed to, it was concluded that the Project will not result in significant
adverse residual effects to First Nations interests.
ENVIRONMENTAL MANAGEMENT AND COMPLIANCE REPORTING
A Construction and Environmental Management Plan is provided in Appendix 5 and includes the
following components:















Construction Environmental Monitoring
Human Health and Safety
Surface Water Quality Management
Fish and Fish Habitat Monitoring and Protection
Air Quality and Dust Control
Erosion and Sediment Management
Noise Management
Waste Management
Wildlife and Wildlife Habitat Mitigation
Vegetation and Invasive Species
Reclamation and Revegetation of Temporary Work Areas
Storage and Handling of Fuels and Hazardous Materials
Blasting
Spill Prevention and Emergency Response
Traffic Management
MAPS
A regional overview and watershed boundaries are provided in Map 2-1
Map Series 2-2 shows the project overview and the location of project infrastructure.
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LABOUR FORCE
It is estimated that about 25,100 person-days will be required to complete the civil construction of
the generation facilities, transmission lines and substations. This does not include the technical
trades required to install the turbine, generator and balance of plant and electrical equipment inside
the two powerhouses.
Work schedules during construction are typically 10-hour workdays. Therefore, the above labour
requirement can be translated to 251,000 person-hours of employment. At an average of 2080
hours per year as a Full Time Equivalent (FTE), this would equal 120 FTE.
During operations and maintenance, it is estimated that approximately four full-time jobs will be
created, including the requirement to have an operator on call 24/7, 365 days a year. Operators will
typically be hired from the local work force. The objective will be to provide training and capacity
building to local and indigenous trainees or previously experience workers to fill these roles.
Additionally, the scale and complexity will require additional oversight and maintenance. It is
estimated that up to four full-time positions will be required in the following general areas/duties:

Management of hydro operations (records, health and safety, permit compliance, finance,
etc.)

Environmental monitoring and reporting

Maintenance of infrastructure (access roads; frazil ice removal; regular observational duties
and reporting, etc.)

Finances

Potential for resident lineman for transmission line maintenance
The labour force during deconstruction is not applicable given the
CAPITAL COST
Based on an economic benefits study conducted in 2017, the construction costs for the Project is
estimated to be approximately $120 M.
PROJECT BENEFITS
OVERALL PROJECT BENEFITS
The Project will increase hydro power production for Yukon, while ensuring that the long-term
renewable energy needs of Atlin continue to be met. Presently, the projected energy demands for
Yukon Energy Corporation are greater than the demonstrated capacity without supplementing
power through additional future renewable energy projects or thermal-based (diesel and/or natural
gas) electrical generation (Yukon Energy Corporation, 2017). As of February 2020, the Atlin Hydro
Expansion Project is also one of only three key projects identified in Yukon Energy Corporation’s
10-year energy plan to help Yukon meet its energy demands through renewables. The Project will
result in the offsetting of an estimated 27,500 tonnes/ annually of greenhouse gasses.
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In addition to its environmental contribution, the Project will create sources of revenue for TRTFN,
creating wealth for the First Nation to invest how they wish, without government limitations,
constraints, or onerous reporting requirements. The benefits of own-source revenues are welldocumented, ranging from tangible economic benefits, to intangible social benefits such as pride,
and increased measures of community well-being. The Project will build capacity of TRTFN
citizens at all employment levels, enabling them to engage in the future employment opportunities
that will be required to operate the First Nation and all their businesses, including being a regionally
important energy provider.
Based on the success of the existing hydro project by Xeitl Limited, including the development of
the Skills Training and Employment Program (STEP) that provides education and training for
TRTFN citizens that lead directly to employment opportunities, it is expected that THEL’s new
Project will also serve to advance the economic development goals and interests of the TRTFN in
future years and for future generations. Dividends created by the Project will allow for significant
reinvestment in the community, including via economic development initiatives, health and social
programs, and education and training, without compromising the environmental and cultural
integrity of the region.
At present, the Atlin area has limited economic development, of which placer mining is an important
contributor. Placer mining involves the substantive disruption of the stream bed and riparian areas
in search of gold, and the release of a high volume of sediments into local waterbodies. As a nonrenewable resource, gold mining and the ensuing long-term reclamation period are not considered
by TRTFN to be a sustainable development of resources. In contrast, this Hydro Expansion Project
improves the utilization of the hydrological resource on Pine Creek and is a renewable resource that
reduces the carbon footprint of northerners. Given these factors in the context of the economic
development strategy, the hydro expansion project is the highest priority for economic development
and revenue generation for TRTFN’s Taku Group of Companies.
The construction phase is expected to create ~80-100 full time equivalent positions over the course
of 2-3 years of construction, and ~6 part-time and full-time positions during operations. The latter
includes ~4 – 6 plant operators and maintenance workers during operations, a plant manager, an
Environmental and Safety Monitor, and potentially a resident lineman. As well, the various
monitoring and maintenance plans will require work to be undertaken annually on the land, which
will create employment for TRTFN and other contractors. A Human Resources Plan will be
developed in consideration of the various operations and maintenance plans and requirements,
monitoring plan, and reporting requirements. Finally, the Project will result in significant dividend
benefits that will increase over time, and which will be reinvested in the community. While the
Energy Purchase Agreement and lender agreements are not finalized at present, cost estimates
have not been finalized. Early estimates at the feasibility level suggested a potential dividend
benefit of ~ $1.3 Million/year. The benefits from sustained economic injections to the Atlin
community include: an annual increase to the GDP, employment opportunities, labour income flowthrough in the local economy, and tax revenues. Some of these revenues go directly to the Atlin
Community Improvement District for its annual operations, as is the case with the current facility.
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PROJECT BENEFITS TO THE TAKU RIVER TLINGIT FIRST NATION
As a 100% First Nation-owned company, economic benefits will accrue to the TRTFN. The benefit
of a long-term revenue source for First Nations includes but is not limited to: control over
investments and government programming; stability in plans and programs that would otherwise be
subject to funding availability; and stable, increases to employment, education, and capacity over
time. Although future investments will be the decision of the company’s Board, accountable to the
TRTFN shareholders, investments are expected to continue to value increasing capacity and
education, local business development and investment, governance, and community projects and
infrastructure.
Additionally, the Project itself will provide training and employment opportunities, including
opportunities for advancement. Monitoring programs will also utilize TRTFN citizens to the greatest
extent possible and may include professional development training to facilitate TRTFN involvement
in long-term monitoring programs. These monitoring programs will also enable citizens to find
gainful employment on the land, while participating in the management of their resources.
The Project will be only the second hydro project in Canada to be 100% owned and operated by a
First Nation, with the only other facility also being owned by TRTFN (i.e., the existing hydro facility).
This represents continued capacity development opportunities that extend beyond employment
economic development to issues of social well-being and pride, which are likely to increase the
economic well-being of the community over time.
CONCLUSIONS OF QUALIFIED PROFESSIONALS
Although the project will create about 20,000 m2 of pool type habitat, which is important for Arctic
grayling, the qualified professionals’ conclusion from the effects assessment is that, with
implementation of proposed avoidance and mitigation measures, the Project is likely to cause a
significant adverse effect to Arctic grayling habitat due to changes in flow in Pine Creek. Details of
the compensation required for this effect will be defined in the Fisheries Act Authorization that the
proponent is seeking from Fisheries and Oceans Canada.
The long term GHG emission reduction of 29,500 tonnes CO2e/year will result in a significant
beneficial effect to the atmospheric environment.
The Project will create sources of revenue for TRTFN, creating wealth for the First Nation to invest
how they wish. The benefits of own-source revenues are well-documented, ranging from tangible
economic benefits, to intangible social benefits such as pride, and increased measures of
community well-being. The Project will build capacity of TRTFN citizens at all employment levels,
enabling them to engage in the future employment opportunities that will be required to operate the
First Nation and all their businesses, including being a regionally important energy provider.
Report No. 2001073.00
Revision: 01
Date: June 11, 2021
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