Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 1 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 2 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 3 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 4 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I 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 | Page 5 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 6 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydroelectric Expansion Project: Volume I | Page 7 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Page 8 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I 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 | 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 Page 10 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 property will Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 15 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I 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 | Page 16 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Katherine Znotinas, Lands, Resources and Fisheries Department Lands.mgr@gov.trtfn.com Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I AGENCY Transport Canada, Navigation Protection Program (NPP) AUTHORIZATION/ APPROVAL REQUESTED NPP authorization for Water Control Structure STATUS Submitted Dec. 18, 2020 | 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. Page 17 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 18 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 19 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 20 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 21 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 22 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 23 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 24 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 25 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 26 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 Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 27 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 32 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 33 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. Report No. 2001073.00 Revision: 01 Date: June 11, 2021 Clean Energy Development Plan for the Atlin Hydro Expansion Project: Volume I | Page 34 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