SITE C CLEAN ENERGY PROJECT
ENVIRONMENTAL ASSESSMENT
ENVIRONMENTAL IMPACT STATEMENT (EIS) COMMENT TABLE
Name of Party Providing the Comments: Kwadacha First Nation
We are writing to provide comments on behalf of the Kwadacha First Nation (“Kwadacha”) with regards to the Environmental
Impact Statement (“EIS”) for the proposed Site C dam and hydroelectric generating station (the “Site C Project”). As stated in our
previous correspondence, Kwadacha has not taken a position in support or opposition of the Site C Project, and continues to
monitor and assess the issues and the potential benefits and impacts associated with it.
The comments presented here supplement Kwadacha’s previous comments provided in response to correspondence and other
documents from BC Hydro and the provincial and federal governments. In previous discussions and correspondence, and most
recently in our letter to Trevor Proverbs, Director of First Nations Engagement for the BC Hydro Site C Project, dated January 31,
2013, Kwadacha has outlined four key issues relating to the potential impacts of the Site C Project:
Issue 1: Effects on water levels and management of the Williston Reservoir;
Issue 2: Effects on regional ungulate and large carnivore populations;
Issue 3: Availability and escalating costs of regional goods and services; and
Issue 4: Cumulative effects and related social and environmental factors arising from the Site C Project in combination with other
anticipated resource development projects.
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Kwadacha continues to have concerns with respect to how these issues have been addressed in the EIS for the Site C Project.
BACKGROUND
The Kwadacha have historically depended on and continue to depend on the lands and natural resources within their area of
traditional use and stewardship for the modern equivalent of sustenance, a moderate livelihood and social, cultural and ceremonial
use. The use and stewardship of these land, waters and resources by the Kwadacha is integral to the Kwadacha governance and
economy.
Kwadacha and BC Hydro concluded a Final Agreement on November 27, 2008 to address the resolution of all past, present and
future issues, grievances and claims of Kwadacha relating directly or indirectly to the impacts of the W.A.C. Bennett Dam, the Peace
Canyon Dam, the Williston Reservoir and any other related and existing works (the “Final Agreement”). Pursuant to this Final
Agreement, BC Hydro is bound to fulfill a number of obligations in the case of any hydro-electric projects that depend on water
within the Williston Reservoir and are within the area of the main stem of the Peace River between Peace Canyon and the Alberta
border. The obligations within the Final Agreement extend to the proposed Site C Project and require BC Hydro to engage Kwadacha
in a process that ensures any potential impacts are identified and efforts are proactively undertaken to address such potential
impacts.
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ISSUE 1: Effects on water levels and management of the Williston Reservoir
Volume 2
Appendix
D, Part 1
(Volume 2,
s 11.1)
7
N/A
(Appendix)
1
Kwadacha remains concerned about the potential effects that
the Site C Project may have on water levels and water
management of the Williston Reservoir. Contrary to the
comments in Trevor Proverbs’ letter dated March 11, 2013,
these concerns are not associated with the historic and ongoing
impacts of the Williston Reservoir on Kwadacha. Rather, these
concerns are associated with changes and other impacts on the
Williston Reservoir that might be caused by the operation of
the Site C Project, particularly in light of the intended use of the
Williston Reservoir for storage purposes and the planned
coordination of the Site C generating system with the operation
of existing upstream facilities.
We have reviewed the EIS and find that despite our previous
comments on the potential adverse upstream effects of the Site
C Project, the primary focus in the EIS Guidelines remains
limited to water levels and management downstream of the
proposed Site C Project. We note that although extensive
downstream flow modelling was conducted for the EIS (Volume
2 Appendix D, Parts 2 and 3), no similar efforts were
undertaken to model upstream impacts associated with using
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the Williston Reservoir for storage purposes. Rather, the EIS
merely provides a description of the existing hydro-electric
projects on the Peace River (Volume 2, section 11.1), without
providing a technical analysis of the impacts that the proposed
Site C Project may have on these existing projects and
associated reservoirs.
We emphasize the importance of an accurate quantification of
potential changes to water levels and the duration and timing
of drawdown and high water periods in Williston Reservoir as a
result of the Site C Project. Kwadacha has an interest in
understanding how water elevations may change in the future
as a result of the Site C Project. We reiterate that this change is
not associated with the ongoing use of Williston Reservoir, but
rather on impacts to this use caused by the Site C Project.
Without adequate modelling of these impacts, our concerns
remain outstanding.
Outstanding Request:
Conduct thorough modelling of upstream impacts of the
proposed Site C project, in particular with respect to
potential impacts on the Williston Reservoir.
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ISSUE 2: Effects on regional ungulate and large carnivore populations
Volume 2,
s 14
Section in general
2a
As repeatedly mentioned throughout our earlier
correspondence, Kwadacha has significant concerns with the
potential adverse effects of the Site C Project on wildlife
movements, migrations, and populations; in particular
ungulates and large carnivores in the larger region north and
west of the Site C Project. These potential adverse effects could
considerably impact the ability and success of current and
future wildlife harvesting and tourism activities in Kwadacha
traditional territory and adjacent lands traditionally used by
Kwadacha members. To date, these effects have been
inadequately considered as reflected by the lack of field studies
and qualified projections of the extent and significance of
potential impacts on lands to the north and west of the project,
and as the review of baseline for large carnivores is limited to a
desktop data review as opposed to actual field studies.
Outstanding Request:
Complete field studies for ungulates and large carnivores
across the Peace River Regional District, including to the
north and west of the proposed project, and provide
qualified projections of the extent and significance of
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these potential impacts.
Volume 2
14-20
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2b
We remain concerned about the limited scope of the Regional
Assessment Area (“RAA”) for the Wildlife Resources Valued
Component (“VC”). This RAA is restricted to the Peace
Lowlands Ecosection and does not adequately take into account
the potential wider scale impacts of the project on wildlife and
ungulate winter ranges.
The limited scope of the study is reflected in Appendix R, which
states that the study was limited to the Peace River, between
the Peace Canyon dam and the Alberta border (page 122).
Notably, this study also acknowledges the considerable distance
that elk travel over short distances, which reflects the high
likelihood that ungulates will travel across wide areas, that are
much larger than the limited Peace Lowlands Ecosection area
covered by the EIS (page 147). It also notes that “[m]ortalities
due to seasonal flooding are expected to be small since most
ungulates will move away” (page 247); yet, the EIS does not
consider the broader impacts associated with such a “move”.
We note that although several species of wildlife were classified
in the EIS as non-migratory, wildlife displacement across larger
areas may occur as a direct result of disruptive construction
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activities undertaken for the Site C Project. These impacts were
not adequately addressed in the EIS.
Outstanding Request:
Complete an assessment of the Wildlife Resources VC
across the entire Peace River Regional District.
Volume 3, p. 24-47
Volume 2, p. 14-65
Pages in
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2c
The Peace River Regional District, which includes Kwadacha
traditional territory and the present day Kwadacha community
on Fort Ware Reserve #1, would provide a more representative
picture of the displacement of wildlife and the combined
residual effects of the Site C project along with other projects
and activities for consideration in the cumulative effects
assessment. These considerations are particularly important in
evaluating habitat fragmentation and alteration of wildlife
caused by the proposed Site C Project.
Concurrently, Kwadacha is concerned about the unsupported
allegation that there will be no residual effects expected on
hunting opportunities during operations, coupled with the fact
that the proposed mitigation measure for mortality of
ungulates is limited to encouraging temporary workers not to
hunt within the Local Assessment Area (“LAA”). This area is
clearly insufficient for considering the full impacts of the
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proposed project, and should be expanded to cover the entire
Peace River Regional District across which workers are likely to
travel for recreation purposes.
Outstanding Request:
Complete an assessment of impacts on the displacement
of wildlife from the combined residual effects of the Site C
project along with other projects, and the likely travel of
workers for recreational purposes across the entire Peace
River Regional District.
Volume 2
14-81
&
Table
14.5
Pages in
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2d
In Table 14.5, we note the lack of habitat modelling for
ungulates. This is particularly disconcerting in light of the likely
impacts of lost and fragmented habitat, increased human traffic
and other cumulative impacts associated with the Site C Project
on ungulates across the Peace River Regional District.
Concurrently, we are concerned about the unsupported
allegation that the extent of disturbance on ungulates is site
specific and that highways and the reservoir will not form
barriers to movement.
Outstanding Request:
Complete habitat modelling of ungulates across Peace
River Regional District.
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2e
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During winter months, when the new reservoir is partly frozen,
ungulates will likely attempt to cross it. The EIS itself admits
that the frozen reservoir will likely facilitate more winter
movements. Concurrently, this increases the risk of drowning
mortalities as animals get trapped by weak ice or by ice shelves.
Inadequate mitigation measures are provided in the EIS to
address this risk.
Outstanding Request:
Provide adequate mitigation measures to address the risk
of drowning mortalities by ungulates seeking to cross the
reservoir during winter months.
Volume 2
14-56
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2f
With further regards to the proposed mitigation measures for
ungulates, we note that the EIS states that BC Hydro will
consider using feeding programs during severe winters. We
question the effectiveness and unintended consequences on
migration patterns associated with such a program and remain
concerned that these proposed mitigation measures are
insufficient. We requests that BC Hydro reconsider what
mitigation measures are adequate to address the likely impacts
of the project on ungulates. Nevertheless, if the feeding
program is deemed necessary, we recommend that local First
Nations be involved in implementing such feeding programs
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and other mitigation measures.
Outstanding Request:
Expand planned mitigation measures to address likely
impacts of the Site C project on ungulates.
Volume 2
14-101
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2g
Finally, we note the lack of follow-up plan for ungulates in the
EIS. This is a significant omission, particularly in light of the lack
of mitigation measures and inadequate spatial consideration of
the impacts of the Site C Project on ungulates discussed above.
Outstanding Request:
Complete wider scale monitoring and prepare a follow-up
plan for ungulates across the Peace River Regional
District.
Grant Kwadacha and other area First Nations preference
for carrying out mitigation activities in the areas upstream
of the proposed Site C Project.
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ISSUE 3: Availability and escalating costs of regional goods and services
Volume 4,
section 30
34
30-7
1- to 21
Although the LAA for Community Infrastructure and Services
encompasses the Peace River Regional District, which includes
Kwadacha Traditional Territory, there is no discussion of the
impact on community infrastructure and services, and
associated costs of regional goods and services for Kwadacha in
Fort Ware.
There is also no indication of projected effects on the
availability and escalating costs of labour, trades and other
services and construction materials as a result of the Site C
Project both alone and combined with other existing and
reasonably foreseeable projects in the Peace River Regional
District.
Outstanding Request:
Complete literature reviews and interviews on
community baseline information for Kwadacha and Fort
Ware.
Assess impacts of the project alone and cumulatively with
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other existing and projected projects on availability and
escalating costs of labour, trades and other services and
construction materials.
ISSUE 4: Cumulative effects and related social and environmental factors arising from the Site C Project in
combination with other anticipated resource development projects
Volume 3,
section 24
34
24-56 to
24-58
4
Kwadacha is concerned about the cumulative effects
assessment of the Site C project and other anticipated resource
development projects on wildlife resources. As we have
suggested on several occasions, it is likely that these impacts
will be long-term and extend across large areas due to increases
in hunting and other recreational traffic associated with the
influx of Site C workers, which will displace wildlife populations
and change land use and predatory patterns. Notably, this is
acknowledged in the EIS, which states that: “During project
construction, hunting would be displaced from the LAA to other
parts of the RAA. The same effect is expected to occur with the
above identified RAA projects. Therefore, access to public
hunting areas would be expected to decrease overall, resulting
in a cumulative residual adverse effect.” (page 24-56).
Insufficient support is provided for the subsequent conclusion
that “the effect is not considered significant” (page 24-58),
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particularly in light of the lack of lack of evidence that the effect
will be reversible (page 24-57). Kwadacha notes that a longterm construction project, which entails several years of
disruption, can irreversibly disturb some key local species,
including ungulates.
In addition, Kwadacha is concerned about the impacts that
shortages in labour, trades and other services and construction
materials will have on the already stressed housing market in
Fort Ware. The EIS does not consider these impacts associated
with the construction of the Site C project both alone and
cumulatively with other existing and projected projects within
the Peace River Regional District.
Outstanding Request:
Complete cumulative adverse effects assessment on
reductions in wildlife resources and associated impacts on
Kwadacha hunting opportunities caused by the combined
effect of the Site C Project and other reasonably
foreseeable resource development projects.
Complete cumulative adverse effects assessment on the
impacts on the housing market in Fort Ware caused by
shortages in labour, trades and other services and
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construction materials from the construction of the Site C
project both alone and cumulatively with other existing
and projected projects within the Peace River Regional
District.
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