SITE C CLEAN ENERGY PROJECT
Environmental Impact Statement
McLeod Lake Indian Band - April 14, 2013
COMMENTS ON THE SITE C EIS (FISH AND FISH HABITAT – VC-12)
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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COMMENT TABLE
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The proponent has excluded consideration of upstream/prior
(above Peace Canyon Dam) impacts and effects within all
aspects of the effects assessment methogologies associated
with this EIS, but has included (Table 12.21) the criteria “Context” within their effects assessment process (i.e. “This
refers to the extent to which the area within which an effect may
occur has already been adversely affected by human activities;
and is ecologically fragile and has little resilience and resistance
to imposed stresses. The proponent has idendtified their
definitions for applying the Criteria of Context as… Disturbed:
Area has been substantially previously disturbed by human
development or human development is still present.
Undisturbed: Area relatively pristine or not adversely affected by
human activity”). The proponent doesn’t convey how the
definitions applied to the Criteria “Context” for the purposes of
characterizing residual effects is being interpreted or quantified.
If the definition Disturbed is being used to convey a lesserweighting within the effects assessment process, this has the
dual effect of dampening the assessment of Significance of
Residual Effects and the Cummulative Effects Assessment
process. This is particularly problematic in consideration of the
Fish and Fish Habitat VC subcomponents.
Table 8.3 of the EIS Guidelines outlines the Residual Effects
VOLUME 2
10 Effects
Assessment
Methodology
Volume 2; 12.6.1
Characterization of
Residual Effects
(Specific to Section
12 – Fish and Fish
Habitat)
1282
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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Characterization Criteria, including Context “This refers to the
extent to which the area within which an effect may occur; has
already been adversely affected by human activities; and is
ecologically fragile and has little resilience and resistance to
imposed stresses.” It would appear that “Disturbed” should infer
a higher level of importance when characterizing potentially
adverse effects, and it is not clear if this was the manner in
which the proponent applied this criteria. Clarification should be
provided in this regard.
11 Environmental
Background
Volume 2, Section
11.9 (and Appendix
J)
11167
2
A thorough assessment of potential mercury/methylmercury
level fluctuations facilitated by the project is provided. However,
an assessment of baseline and forecast methylmercury levels in
fish tissues is considered across a pool of samples for each
species, averaging-out observations, which are translated to
forecast levels and the HHRA.
Pg 11-167…”The mean mercury concentration value was used
for adult bull trout, not the maximum concentration. Although
smaller fish will have a lower absolute mercury increase and
larger fish may have a higher concentration, use of the mean
better approximates typical exposure to humans. For example,
although the maximum mercury concentration of the 50 bull
trout measured from the Site C technical study area since 2008
was 0.34 mg/kg, the next highest value was 0.17 mg/kg. All
other fish had lower concentrations than 0.17 mg/kg”
A potentially more relevant approach, particularly for MLIB
(relative to their consumptive habits), would be to segment
baseline observations and forecasts by fish size (within species,
particularly bull trout), reflecting selective preferences.
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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The implications of the existence and amplification of “higher
risk fish” should be considered, particularly given consumption
preferences.
It is also evident from the background data compiled that a
regular monitoring program should form part of the proposed
Site C mitigation works.
12 Fish and Fish
Habitat
Volume 2; 12.6.3.2
Conclusion
1294,
95
3
Arctic grayling populations within the previously impounded
(upstream) portions of the Peace watershed had been
designated as Red Listed or Critically Imperilled, due to the
effects of harmful habitat alterations. The proponent recognizes
there’s significant potential for the Arctic grayling population
within the LAA to be negatively affected. A qualified opinion
should be provided as to the implications of a further contraction
of the range within which the species/population is viable – in
relation to viability of Arctic grayling in the Peace watershed.
Arctic grayling are on COSEWIC’s candidate wildlife species
list, and the correspondence referred to above should be
forwarded to the Chair of the COSEWIC Freshwater Fishes
Subcommittee.
Volume 2; 12.3.2.1,
Coldwater Versus
Coolwater Fish
Groups
1225
4
The proponent should provide information to substantiate their
rationale for not considering brook trout, pygmy whitefish, brook
stickleback, finescale dace, northern redbelly dace, peamouth,
and pearl dace – as a component of the LAA fish assemblage
and therefore not extending their consideration of the project’s
effects on fish and fish habitat to include these species – re the
proponent’s “classification” of these species as “transients”.,
particularly given the status of pygmy whitefish in Alberta.
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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Volume 2 (Section
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A comprehensive description of the implications all findings of
adverse effects should be provided with respect to the specific
implications of that finding on any fish species within the LAA
that is classified as Endangered, Threatened or of Special
Concern (BC designation) or “May be at Risk” (Alta.
Designation).
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6
The SCP reservoir is predicted to consist of 2 distinct zones
reflecting considerably different characteristics…“The reservoir
can be divided into two sections with different temperature
regimes, similar to the temperature regimes in Dinosaur
Reservoir but with a more diffuse transition. In the first 20 to 30
km of the Site C reservoir, velocities would be higher and the
temperature would be vertically homogeneous. This part of the
reservoir would be shallow (less than 20 m deep) and narrow
(about 0.8 km wide), which would result in high velocities,
between 0.2 m/s and 2.0 m/s, and sufficient shear stress to mix
the water.”
The depth and velocity of the upper 20-30km zone of the
reservoir will not possess similar limnetic (temperature profile
and in paticular, residence time) characteristics relative to the
lower more “lake-like” portion of the reservoir. The upper
reservoir section will in essence reflect the chemical and
primary and secondary biological characteristics of the Peace
Canyon Dam outflows. The degree of distinction in the
characteristics of the two portions of the reservoir will vary but
will be permanent (Vol 2, Appendix H Figure 6.3). It appears this
has not been considered in the modelling of primary, secondary
and fish production and/or the areal translation of those
forecasts to the proposed Site C reservoir, and it would change
all such predictions substantially.
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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The proponent recognizes the uncertainty regarding the
behaviour of the lower portion of the proposed reservoir in terms
of stratification, but makes little mention of the implications of
this uncertainty on the biolgocial and fisheries productive
potential of the proposed reservoir. In particular, the short and
longer-term impacts of a year in which stratification is not
achieved and/or maintained, and/or maintained over various
durations and extents – should be considered in relation to
primary, secondary and fish production potential and
forecasting.
A set of modelled scenarios should be provided that depict the
nature (timing, stability/differential, extent, duration, etc.) of the
reservoir’s forecast stratification behaviour based on the range
of inflows and outflows anticipated, across the range of potential
inflow temperatures observed and outflow temperature targets,
and a reasonable range of possible meteorological conditions.
The intent should be provide the ability to evaluate the proposed
reservoir’s range of productivity potential and characteristics
and assign a probability to each range, including a
consideration of the frequency of each range.
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The proposed reservoir’s productivity-probabailities should then
be considered the basis of primary, secondary and fish
productivity forecasts over (suggested 5-10-year) temporal
ranges from baseline, through construction phases, to post
operation periods.
The predictions of the SCP reservoir’s fish fauna (particularly
given predictions of fish production primarily transitioning to lake
whitefish, kokanee and lake trout) are highly dependent on
entrainment of these species via Williston and Dinosaur
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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reservoirs. The species assemblage and abundance of those
species in those reservoirs has been transitioning overtime. The
creation of the proposed SCP reservoir entails a 8-10year
construction period, followed by a lengthy period within which it
would it would take on characteristics that may reflect the
reservoir habitats facilitating a lake whitefish-kokanee-lake trout
dominated sportfish community. Future trends (10-20years) in
the fish populations within Williston and Dinosaur reservoirs,
and possible constraints to entrainment-recruitment to Site C
should be reflected in forecasts of fish biomass production, or
the forecasts should be “qualified” as hypothetical production
potential.
In the absence of entrainment-recruitment adequate to facilitate
the forecast species assemblage and productivity-biomass
potentials, particularly in the absence of key pelagic prey
species such as kokanee or lake whitefish; consideration should
be given to forecasting the species assemblages that may
arise/occur-remain, and the resulting productivity-biomass.
Tables of fish species present within the fisheries LAA (broken
out into the reaches of the LAA including major tributaries) at a
minimum of two annual-seasonal periods beginning at baseline
conditions and as modelled/forecast at incremental periods post
initiation of Site C construction, to perhaps for 40 years post
initiation of operations – should be provided (perhaps in 10-year
increments for the post impoundment period). Parameters such
as total biomass by species should be included. These tables
would be analogous to Table 6.7 (Volume 2 Appendix P Part 3
– pg. 64) but should represent species rather than “Fish
Groups”. The tables should be based on the range of
productivity-probabilities identified. This is fundamental
information to assist in informing an effects assessment of MLIB
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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Treaty 8 Rights/Interests.
The predictions of productivity within the Site C reservoir are
highly dependent on the characteristics (those that influence
primary productivity) of inlfowing water from upstream
reservoirs, particularly Williston Reservoir. The existing water
licence for Williston Reservoir provides for a range of reservoir
management (lower drawdown) that is outside the range of
“norms” through which the reservoir has generally been
managed since its creation.
It is unclear if the extensive modeling (Volume 2 Appendix P)
that has been completed for the purposes of predicting the
primary, secondary and fisheries productive potential of the Site
C reservoir has considered the implications of any alterations
(outside of “norms”) to the management of Williston Reservior,
and the resulting chemical and physical characteristics of
inflows that would occur.
The changes in the timing of releases from Site C (relative to
existing conditions) due to the travel time required for flow
between the facilities is recognized. “Under the existing
conditions at the Site C Dam site, discharge is highest during
hours of darkness (6:00 p.m. to 6:00 a.m.) and lowest during
hours of daylight (6:00 a.m. to 6:00 p.m.). The reverse would
occur with Site C operation.” This reversal has major
implications for habitat use/suitability and fish behaviour and
survivability downstream of the proposed Site C dam location.
Pg 12-44 “Under present conditions, habitat availability in the
vicinity of the Site C Dam is greatest during hours of darkness
when fish species require feeding habitats. Availability of
habitats located in shallow water areas (i.e., main channel
margins and side channels) would be most affected by flow
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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changes. A portion of these habitats would not be available
during hours of darkness, depending on Site C operations.”
Further…
The proponent provides extensive consideration of potential
changes to the Peace River’s characteristics downstream of the
proposed Site C dam location, including temperature,
discharges (including timing, daily and hourly fluctuations),
sediment transport/clarity and fluvial geomorphology, flowrating/elevations, productivity and information regarding fish
usage and possible mitigation measures; but it is unclear if a
quantitative assessment of adverse impacts and effects was
completed (that would guide mitigation and compensation
measures) for either the construction or operational phases. At
present, the proponent has captured downstream impacts as a
Potential Residual Effect – change in habitat (Table 12.20), but
deemed them not to be significant.
Volume 2, 12-93; “Operation of the Project will result
in modest changes to fish habitat downstream of the
dam. These changes to habitat have been assessed
to be of low magnitude and limited in the proximal
reach of the Peace River between the Project and
the Pine River confluence. Downstream of the Pine
River, changes diminish as a result of flow
attenuation and tributary inflows. The changes to
habitat would include increases in the range of flow
fluctuations, and limited changes to temperature and
water quality.”
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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It is not possible to determine how the proponent quantified their
effects findings (modest? – relative to what?) with respect to
downstream impacts.
Vol 2, Appendix P,
Part 3
pg vii
12
A 72% decrease in benthic biomass is modelled-predicted
downstream of the proposed SCP dam. Total fish biomass is
modelled to increase 1.2-1.4 fold, primarily related to increases
in the standing crop of mountain whitefish. Vol 2, Appendix P,
Part 3 – pg vii “Despite the reduction in benthic biomass, it was
predicted that there would be enough benthos to support all the
fish species in the downstream model. However, there is
uncertainty regarding the degree to which this predicted decline
in benthic biomass would propagate up the food chain.
Ecotrophic efficiencies in Ecopath suggest that there would still
be sufficient benthos under most scenarios to support the fish
community (except for the low bookend from CE-QUAL-W2).
Benthic organisms from the Pine and Beaton rivers would
continue to contribute to the post-Project benthic biomass
downstream of the dam, and could partly mitigate the predicted
decrease in benthic biomass below Site C Dam. Hence, there is
uncertainty in the consequences arising from the predicted
decline in benthic biomass. “
This is recognized as a modelling anomaly, and what
substantiates the prediction within the model should be
explained (i.e. ecotrophic efficiencies). Is it reasonable to accept
the model’s result indicating diminished benthic biomass, but
improved water clarity – will increase the incorporation of
benthic biomass into fish biomas (in this case mountain
whitefish biomass) to such a degree? Does the modeled
prediction of whitefish biomass, density/standing crop appear
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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Volume 2, pg 12-84
1284
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Volume 2, 12.6.2
Standards or
Thresholds for
Determining
Significance
1286
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Volume 2, 12.6.2
Standards or
Thresholds for
Determining
Significance
1286
15
Volume 2, Section 12
– Table 12.19
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reasonable relative to baseline SCP-Peace River reach or other
measured observations within the proponent’s research? Some
effort should be made to substantiate this forecast as it is
presented and considered as an effect.
The acronyms utilized in Table 12.22 (Residual Environmental
Effect Criteria - component), as outlined within Table 12.21 –
Characterization Criteria – do not align in many instances.
The uncertainty regaridng stratification and productive
properties of the proposed reservoir and the areal calculations
of forecast productive potential for the proposed reservoir effect
forecasts of downstream (of the proposed dam site)
productivity. As outlined above with respect to the proposed
reservoir, temporally segmented productivity-probabilities for the
reservoir should be extended to habitats downstream of the
proposed dam in the same manner.
The proponent has established criterion through which it
assesses the significance of each residual effect (Fish and Fish
Habitat VC), and established Standards or Thresholds for
determining Significance as follows:
a. the loss of an indigenous fish species, sub-species,
populations, or distinct groups or,
b. a reduction in the long-term average standing stock
biomass of the fish community relative to the existing
baseline condition
The degree to which Standard/Threshold ‘a’ and ‘b’ is each
congruent with relevant legal, regulatory and policy framework
should be explained within the document.
Given that the primary findings of significant adverse effects
related to fish and fish habitat in-part relate to the migration
barrier that the proposed dam will pose, a thorough explanation
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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should be provided within Volume 2 as to why passive fish
passage mechanisms are not being proposed as a mitigation
measure.
McLeod Lake Indian Band (MLIB) – Site C EIS Comments (Fish and Fish Habitat VC-12 (April 14, 2013)
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