Unit 11 - 1839 1st Ave.
Prince George, BC V2L 2Y8
Telephone: 250-564-9321
Fax: 250-564-9521
June 17, 2014
Nathan Braun, Project Assessment Manager
British Columbia Environmental Office (BCEAO)
Email: Nathan.braun@gov.bc.ca
Sent by Email
RE: Westcoast Connector Gas Transmission (WCGT) BCEAO Application Review.
Nathan,
The Takla Lake First Nation (TLFN) is providing you feedback on the WCGT Application. In our directions
from the BCEAO we have been asked to: 1. Review and consider the proponent’s application; 2. Reach
conclusions on the potential adverse effects of the proposed project, including cumulative effects in
considerations of mitigation measures and; 3. Recommend any EA Certificate Conditions. In this context,
we have also been asked by the BCEAO to identify issues of top priorities and concern. Although our list
is long (in terms of priorities and concerns), we have done our best to be as specific in our input
regarding the review of potential impacts of this project on our aboriginal rights, title and interests. In
this context we identify concerns with Ecosystem and Community Health and well-being. Notable here is
that much, if not all, of our input related to the project and our concern with the process – although
perhaps heard – lacked tangible action from the BCEAO. This is not to disrespect yours or others efforts
on behalf of the BCEAO or the proponent - as we identify that the root issue stems completely out of the
BCEA process itself. Through working in this process we have identified and continue to identify that it:
1. Ignores fundamental scientific rigor in methodology to determine significance of effect; 2. Reduces
First Nation Traditional Knowledge (TK) to Section C of the assessment that essentially removes TK from
significance of effect determinations and; 3. Removes First Nation decision making power in
determination of the significance of the effect. Simply put, the BCEA process clearly needs to change as
it serves our First Nation poorly in relation to effectively addressing our rights and interests effectively.
In this context, please consider the following feedback for priority:
1. ECOSYSTEM HEALTH
Based on current scientific literature on Ecosystem Health and concern by our Traditional Knowledge
holders, one could clearly deduce that Ecosystem Thresholds for the surrounding region of the WCGT
have been reached and most likely have been well surpassed. This means that biodiversity levels in
these regions are in rapid decline putting the ecosystem at risk in relation to both productivity and
resiliency. The results of Ecosystem Health degradation are becoming more apparent though
TLFN to BCEAO re WCGT Application Page 1 of 3
observation of: 1. known population declines for species of value to the community and; 2. an increase
in forest health issues for the region that surpass historic levels of natural range of variation. For
example, the WCGT BCEAO Application considers little, if any, of the recent impacts of MPB salvage
programs have had (and will have) on pushing ecosystem health thresholds to higher levels of concern by not considering current scientific literature on Natural Range of Variability, Ecosystem Health,
Integrity and Resiliency in the context of past, current and future pressures that have been or will be
realized. The result will be the approval of this project, and another project, and another project (and so
on) without dealing with the fundamental issue of cumulative effects on Ecosystem Health during the
life of this project. This has very serious consequences to the TLFN’s ability to exercise their rights and
interests in their territory. The TLFN have raised this concern in all previous correspondence with the
BCEAO (i.e. VCs, dAIRs, Screening). It would be helpful for the BCEAO and the proponent to determine
how this has been addressed in the application and in particular how consideration of current and
future MPB salvage and Annual Allowable Cut (AAC) levels will interact with this project to impact the
ability to exercise TLFN’s aboriginal rights and interests (i.e. fish, wildlife, and vegetation).
Recommendation for a solution/EA Certificate Conditions to the above issue if the BCEAO recommends
this project to proceed is to: 1. Ensure rigorous independent scientific and traditional knowledge
research that is adequately funded begin immediately to identify current threat to ecosystem health at a
regional scale (big picture, regional); 2. Based on these results, have the independent First Nation and
Scientific panel make recommendations on how to reduce future project developments within the
region of the pipeline, while increasing species populations (big picture, regional); 3. Do not delay on
identifying ways in which this project can contribute to repairing the ecosystem (i.e. through riparian
compensation measures and road deactivation) (project specific); 4. Reduce the projects impacts; For
example, be clear on how access roads will be controlled to reduce impacts in collaboration with First
Nations (project specific); 5. Work with our First Nation to identify mitigation measures that are above
and beyond what would be considered “normal” procedures (project specific). An example of this would
be to allow the re-growth of vegetation to extend as near to the pipeline as possible. This may restrict
the use of helicopters for monitoring purposes but will likely have a positive effect – in terms of reducing
impacts. Of course, there are a great many mitigation measures that will be required to discuss if the
pipeline proceeds. We have discussed this before with the BCEAO and the proponent – which is
essentially, many of the mitigation measures are based on “professional judgement” while the scientific
efficacy of these approaches are undetermined. In this sense, it would be proactive to make a condition
to the permit that the proponent, the First Nation, and the province come to agreeable solutions to
mitigation, compensation, and monitoring measures prior to construction (as it is unlikely that all
mitigation measure will be agreed upon prior to the conclusion of this EA); at this time we do not agree
with the proposed mitigation measures and question their efficacy. Having said this, we will continue to
work on meaningful input on these mitigation (and ideally compensation) items and will submit
recommendations in the coming months. It is here, and in fairness to the proponent, we identify that
they have recently provided “additional baseline study support” on some of our areas of concern (in
relation to some of the above items). Unfortunately, we will unlikely have this baseline information
prepared prior to a determination of this project. Regardless, we recognize the proponent for their
efforts to address some of the items of concern related to further collection of baseline information. We
hope that our findings will further inform this process as well as prepare for further meaningful
discussions with the province and the proponent regarding environmental concerns and appropriate
mitigation and compensation measures.
TLFN to BCEAO re WCGT Application Page 2 of 3
2. COMMUNITY HEALTH AND WELL-BEING
As we identify that ecosystem health and the availability and viability of many of the fish and wildlife
populations that we depend are in decline, we identify here that this negatively impacts our
community’s culture, health, and overall well-being. At the same time, we also identified that there
could be potential positive impacts to our community from the proposed projects if: 1. above ecosystem
health issues are addressed; 2. Meaningful Jobs, training and employment are realized; 3. Contract
opportunities are attainable in which the proponent and province provide meaningful support to ensure
maximum contract benefits; 4. Economic Benefits are identified and agreed upon between both the
province and the proponent and; 5. Our culture, our people and our way of life is understood and
respected by all non-aboriginal workers and contractors who intend to work in our territory. We
encourage you to consider these points and identify EA certificate conditions to meet these requests in
relation to our community’s health and well-being.
To summarize, as outlined in this input regarding WCGT application the TLFN continue to have concerns
in relation to the negative impacts this project may bring to our aboriginal rights and interests in which
the this application has not addressed. These concerns are generally fundamental to root issues related
to the BCEAO process. In addition, we identify that many of the potential positive benefits of this project
are unrealized and/or unknown at this time. In this context, we emphasize here, that it will not be until
the known benefits of this project – from both the proponent and the government – will we determine
if we will grant the approval of this pipeline to dissect our territory. In the meantime we will continue to
work collaboratively with the proponent and the provincial government to find solutions to these issues.
Again, we appreciate your consideration of our input into the Application of the WCGT project. If you
have any questions or require further clarity on this request, do not hesitate in contacting me.
All the best,
Dave Radies. MSc.
TLFN Mining Coordinator
Cc. Anita Williams, TLFN Chief
John Allen French, TLFN Councillor
Murray Browne, Senior Associate Counsel, Woodward & Co.
Terry Teegee, Tribal Chief, CSTC
Jamie Sanchez, Natural Resource Advisor, CSTC
Franca Petrucci, Community Coordinator, Spectra Energy
TLFN to BCEAO re WCGT Application Page 3 of 3