Construction Phase Activities Construction Phase Activities

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1 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines Version 1 Submitted by BC Hydro on March 30, 2012 Information Table Comment ID# AEW_ltr_ 001 Name/ Organization Alberta Environment 1. Alberta s Interests Attached is a table titled, Alberta s Interests: Site C Clean Energy Project, which presents the full range of Alberta s interests that should be evaluated in this environmental assessment process. Alberta had provided this table to the BCEAO earlier in the environmental assessment process in anticipation that these interests would be clearly identified in the Draft EIS Guidelines. The Draft EIS Guidelines cover an extensive range of topics, however, the wording is very generic and as such it is not clear whether all our specific interests will be considered. Alberta would like to see our interests acknowledged and addressed in the final EIS Guidelines document, and evaluated in the Environmental Impact Statement. n/a Technical analysis and modelling have been conducted to evaluate the impact that a hydro-electric dam at Site C would have on downstream river flows and levels. The preliminary analysis concluded that the operation of a dam at Site C would result in only small changes in flows and levels at the Town of Peace River. On the basis of that preliminary analysis, BC Hydro established the downstream limit of the Technical study area for the analysis of surface water hydrology at Peace Point, Alberta, approximately 740 km downstream of the Town of Peace River, to ensure that any changes to surface water hydrology resulting from the Project would be detected. On this basis, BC Hydro that the downstream extent is more than sufficient for the environmental assessment. The EIS will include detailed technical modelling assessments and analysis of changes in surface water hydrology resulting from the operation of the proposed Project. Please see Topic Summary: Peace Athabasca Delta AEW_ltr_ 002 Alberta Environment 2. Assessment Areas Alberta is concerned that the geographic extents of the assessment areas for the Valued Components presented in the Draft EIS Guidelines do not extend far enough downstream to fully assess the potential impacts in Alberta. Alberta believes that most of the Valued Components should be evaluated downstream to the Northwest Territories border. We understand that technical experts chose the aerial extent of the potential impacts based on some criteria and understanding. However, that information / n/a Please see response to AEW_ltr_001 Please see topic summary: Peace Athabasca Delta Page 1 of 463

2 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 criteria was not shared in the Draft EIS Guidelines document, and therefore there is no means to determine whether the Draft EIS Guidelines adequately address Alberta s interests. AEW_ltr_ 003 Alberta Environment 3. Alberta Communities Communities and municipalities downstream on the Peace River in Alberta were disappointed that the Draft EIS Guidelines had little or no acknowledgement of their existence or concerns. Again, this appears to be a result of the Draft EIS Guidelines being very generic and limited in detail. As written, the Draft EIS Guidelines did not convey an understanding or empathy for communities in Alberta. The Final EIS Guidelines should rectify this lack of understanding and acknowledgement. n/a It is our understanding that the uidelines is a technical document intended to describe required technical studies and assessments to be conducted under the Environmental Assessment Process. Though we are acutely aware of these issues of concern, we submit it is not appropriate to include statements about empathy or concern in a technical document. AEW_tbl _001 AEW_tbl _002 Alberta Environment Alberta Environment After line 34, page 8: INSERT new bullet: Management of silt and sediment entering the Peace River during the construction period After line 14, page 9: INSERT new bullets: Management of the clearing, preparation, and flooding of the reservoir lands related to water quality of the Peace River, and specifically related to raw water supplies for communities in Alberta Management of the filling of the reservoir and impacts of construction on downstream flows in Alberta, Construction Phase Activities Construction Phase Activities This is not an appropriate addition to this section. An annotated outline of the Project Erosion Prevention and Sediment Control Plan will be provided in 21 of the EIS. This is not an appropriate addition to this section. Annotated outlines of the Project Groundwater Protection and Surface Water Quality Protection Plans Plan will be provided in 21 of the EIS. Page 2 of 463

3 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 particularly if it is a dry year during reservoir filling AEW_tbl _003 AEW_tbl _004 AEW_tbl _005 Alberta Environment Alberta Environment Alberta Environment After line 31, page 10: AT END OF SENTENCE:...flows and water levels INSERT: of the Peace River through Alberta, including the Peace Athabasca Delta to the Northwest Territories border. Line 34, page 10: AFTER: estimate of the INSERT: magnitude, Page 16: COMMENT: Include the public meetings and consultation that will take place in Alberta Operations Phase Activities Operations Phase Activities 7. Information Distribution and Consultation Please see response GNWT_004 The EIS Guidelines page 10, line 34 will be revised to include: " the magnitude of potential spillway releases". See 7.1 of the EIS Guidelines for a description of Public Information Distribution and Consultation. BC Hydro expects that the communities in Alberta with an interest in the Project will be notified by the regulatory agencies of the consultation process under the cooperative environmental assessment process. AEW_tbl _006 Alberta Environment After line 20, page 19: INSERT NEW SECTION Emergency Notification The EIS will describe BC Hydro s emergency notification plan and procedures to be employed for people and communities downstream in Alberta during the construction period in the event of an emergency Construction Communicati on See Topic Summary: Dam Safety. The Emergency Preparedness Plan for construction will contain the requested information. Page 3 of 463

4 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _007 AEW_tbl _008 Alberta Environment Alberta Environment Line 22, page 31: DELETE: town of Peace Point, Alberta. INSERT: Alberta-Northwest Territories border. COMMENT: This additional, more detailed information on expanded flows and expanding evaluation downstream to the Alberta- Northwest Territories border is required to adequately evaluate the potential impacts and cumulative effects on the valued components downstream in Alberta. Line 24, page 31: SHOULD INCLUDE the following flow information for the longest period of time possible: 1950s-2010 Mean annual naturalized flows Mean annual historic (recorded) flows Mean annual predicted flows with SITE C Mean weekly naturalized flows Mean weekly historic (recorded) flows Mean weekly predicted flows with SITE C Mean daily naturalized flows Mean daily historic (recorded) flows Mean daily predicted flows with SITE C A discussion of the limitation of this daily information may be required Surface Water Regime Surface Water Regime Please see response to AEW_ltr_001. The EIS will include a description of the existing (post-regulation) flow regime of the Peace River and the expected flow regime of the Peace River with Site C. This description will include annual, monthly, daily, and hourly flows and/or water levels and will consider the seasonality of flows where appropriate. Exceedence (duration) curves, hydrographs and other plot-types will be used as appropriate to describe existing conditions. Naturalized flows will not be presented in the EIS since they do not reflect the baseline conditions. Flows on the Peace River are regulated by an upstream reservoir capable of multi-year storage, the historical post-regulation flow regime reflects not only the variability in the Peace River inflows but also the changes over time in BC Hydro s system load, system resources, and external market conditions. For this reason, the historical flow regime is not a good indicator of the expected flows in the absence of the Project. AEW_tbl _009 Alberta Environment Line 25, page 31: DELETE: Peace Point, Alberta, INSERT: Alberta-Northwest Territories border, Surface Water Regime Please see response to AEW_ltr_001 Page 4 of 463

5 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _010 AEW_tbl _011 AEW_tbl _012 Alberta Environment Alberta Environment Alberta Environment ADD NEW TEXT after line 26, page 31: The EIS will describe hourly flows or daily maximum and minimum flows for a few representative times of the year (open water season, low flows, high flows and under ice winter flows) for a few representative years, to provide an understanding of normal operations and of the potential variability for naturalized, historic (recorded) and predicted flows with Site C conditions, downstream to the Alberta- Northwest Territories border. To clarify: THIS IS NOT A REQUEST FOR PRODUCING HOURLY FLOWS FOR THE ENTIRE PERIOD OF RECORD. THEN ADD NEW BULLET: Generate a series of statistics describing the high and low flows for open water and under ice (winter) periods separately as required for naturalized, historic (recorded) and predicted flows with Site C conditions. Line 7, page 32: AT bullet, seasonal flow patterns of post-construction flows AFTER: flow patterns of INSERT : naturalized, historic (recorded) and Line 5, page 33: DELETE: the British Columbia/Alberta border. INSERT: include the County of Northern Lights. COMMENT: The towns of Fairview and Peace River are the first major communities in Alberta that use the Peace River as their raw water supply for drinking water. Residents and Aboriginals in Northern Sunrise County take water from the Shell intake downstream of the Town of Peace River. DMI withdraws raw water from the Peace River in Surface Water Regime Surface Water Regime Water Quality Please see response to AEW_tbl_008. Relevant flow data will be used to characterize baseline conditions and this will include the impact of ice on water levels. Changes to the downstream ice regime and associated changes to water levels with Site C will be described in the EIS as referenced in section and in the EIS Guidelines. Please see response to AEW_tbl_008 Comments noted and text has been revised. See T8TA_tbl_071 Page 5 of 463

6 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _013 Alberta Environment the County of Northern Lights downstream of the Town of Peace River. It is important to understand the potential impacts of the project on these communities and municipalities. Line 19, page 34: DELETE: Grimshaw, Alberta INSERT: the Shaftesbury ferry Thermal and Ice Regime The downstream study boundary for water temperature is the Alces River rather than Grimshaw , lines of the EIS Guidelines (Thermal and Ice Regime - Downstream Temperature) will be replaced with the following: " Potential changes to downstream water temperature to the Alces River (approximately 60 km downstream) will be described in the EIS. The analysis will be conducted using a two-dimensional cross-sectionally averaged hydrodynamic and water quality model (CE-QUAL W2). This model is being used primarily for the purpose of examining aquatic productivity. The CE-QUAL W2 model simulates basic eutrophication processes such as temperature-nutrient-algae-dissolved oxygen-organic matter and sediment relationships (Portland State University, 2011). It is expected that changes to water temperature due to Site C will be negligible at the confluence of the Alces River with the Peace River; however, if warranted, the downstream extent of the assessment will be extended to capture the entire extent of Project influence". AEW_tbl _014 AEW_tbl _015 Alberta Environment Alberta Environment Line 29-30, page 34: DELETE: a location approximately 700km downstream near Fort Vermilion, Alberta. INSERT: downstream of the Peace Athabasca Delta, Alberta. COMMENT: The ice regime is an important component influencing the volume and level of water in the Peace Athabasca Delta. It is important to understand the cumulative effect of the ice regime on the Peace Athabasca Delta. Line 2, page 35: AT END OF: information regarding the INSERT: pre-regulation conditions, Thermal and Ice Regime Fluvial Geomorphol ogy and The Technical study area for the analysis of ice conditions extends downstream to Fort Vermilion, Alberta, over 700 km downstream of Site C. Model predictions confirm that the influence of Site C on ice conditions does not extend this far downstream; as such extending the study area further downstream is not warranted. Please see Topic Summary: Cumulative Effects Assessment Page 6 of 463

7 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _016 Alberta Environment COMMENT: This information is required to understand the changes to fluvial geomorphology and sediment transport due to current flow regulation and additional cumulative effects of the Site C project. Line 31-32, page 35: DELETE: within the anticipated extent of from existing information. INSERT: to Peace Point, Alberta. Sediment Transport Fluvial Geomorphol ogy and Sediment Transport 9.2.5, Line 31-32, of the EIS Guidelines will be revised as follows: DELETE: within the anticipated extent of from existing information. INSERT: to Peace Point, Alberta. AEW_tbl _017 AEW_tbl _018 Alberta Environment Alberta Environment Line 34-35, page 35: DELETE: within the anticipated extent from existing information. INSERT: to Peace Point, Alberta. Line 13-14, page 36: DELETE: Many Islands, Alberta (200 km downstream of the W.A.C. Bennett Dam). INSERT: the Alberta- Northwest Territories border Fluvial Geomorphol ogy and Sediment Transport Methylmercu ry 9.2.5, Line 34-35, of the EIS Guidelines will be revised as follows: DELETE: within the anticipated extent from existing information. INSERT: to Peace Point, Alberta. The downstream extent of the Technical study area for methylmercury will be extended to Vermillion Chutes by incorporating data collected for the Dunvegan project , Line 12 of the EIS Guidelines will be revised as follows: ADD:.. and will consider mercury concentrations within and downstream of the Site C reservoir to Vermillion Chutes, Alberta DELETE:... to Many Islands, Alberta (200 km d/s of the WAC Bennett Dam), AEW_tbl _019 Alberta Environment Line 5, page 39: IN Table 10.1, Fish and fish habitat valued component rationale, Column 2 Interaction with Project Components and... AFTER: Construction activities DELETE: and INSERT:, <comma> AFTER: water impoundment, INSERT: and power production flow operations over the life of the project THE RESULTING SENTENCE SHOULD READ: Construction activities, water impoundment, and power production flow Fish and Fish Habitat VC Scoping and Rationale Please see response to DFO_023 Page 7 of 463

8 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _020 Alberta Environment operations over the life of the project IN Table 10.1, Fish and fish habitat valued component rationale, Column 4 Public and Stakeholder issues AFTER: Food fisheries, recreation INSERT: health of the aquatic ecosystem, fish habitat and fish populations. Line 9, page 39: IN Table 10.2, Fish and fish habitat assessment areas, Column 2 Local Assessment Area DELETE: Pine River; INSERT: Smoky River; IN Table 10.2, Column 3 Regional Assessment Area DELETE: Vermilion Chutes, AB, which is a distance of approximately 865 km INSERT: the Alberta- Northwest Territories border Fish and Fish Habitat Spatial Boundaries Please see response to DFO_023 AEW_tbl _021 AEW_tbl _022 AEW_tbl _023 Alberta Environment Alberta Environment Alberta Environment Line 7, page 40: AFTER: biological assemblages, water quality, INSERT: physical wetted habitat, side channel habitat, bed sediment habitat, Line 13, page 40: AFTER: temperature INSERT: bed sedimentation Line 3, page 41: AFTER: changes in nutrients INSERT: physical wetted habitat, side channel habitat, bed sediment habitat; Fish and Fish Habitat Baseline Fish and Fish Habitat Baseline Fish and Fish Habitat - Potential Effects of the Project and Proposed Mitigation See response to DFO_ , page 40, line 14 of the EIS Guidelines will be revised as follows: ADD sediment transport AFTER temperature , page 41, line 4 of the EIS Guidelines will be revised as follows: ADD fish habitat AFTER web Page 8 of 463

9 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _024 Alberta Environment Line 5, page 42: IN Table 11.2 Vegetation and plant communities assessment areas, in Column 2 Local Assessment Area AFTER: from Hudson s Hope to DELETE: the Alberta border; INSERT: Smoky River; Vegetation and Plant Communities Spatial Boundaries Please see Topic Summary: VC Selection and Boundaries AEW_tbl _025 AEW_tbl _026 AEW_tbl _027 Alberta Environment Alberta Environment Alberta Environment Line 17, page 44: INSERT NEW BULLET AFTER line 17, The area of vegetation/plant community change on the near channel and sand bars, islands and flood plain. Line 15, page 45: IN Table 12.1, Wildlife resources valued component rationale, Column 2 Interactions with Project Components and AFTER: and reservoir creation ADD: and downstream flow-related ice regime changes Line 1, page 46: AT: Hudson s Hope to the Alberta border; DELETE: Alberta border; INSERT: Smoky River; IN Table 12.2 Wildlife resource assessment areas, Column 3 Regional Assessment Area AFTER: Peace Lowlands Ecosection INSERT: to the Peace Athabasca Delta Vegetation and Plant Communities - Potential Effects of the Project and Proposed Mitigation Wildlife Resources Valued Component Scoping and Rationale Wildlife Resources Spatial Boundaries Please see Topic Summary: Cumulative Effects Assessment Downstream flow-related ice regime changes on the margins of the river downstream will be addressed in the Wildlife Resources effects assessment. The LAA will be defined in consideration of the expected maximum range of the potential for the Project to cause disruption to habitat and wildlife. BC Hydro believes that the Peace Lowlands Ecosection is an appropriate and conservative boundary for the assessment of potential effects on wildlife that meets the above criterion. Page 9 of 463

10 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _028 AEW_tbl _029 AEW_tbl _030 Alberta Environment Alberta Environment Alberta Environment Line 2, page 58: IN Table 15.2 Current use of lands and resources for traditional purposes, Column 3 Regional Assessment Area DELETE: to Vermilion Chutes, AB, which is a distance of approximately 865 km REPLACE with: and downstream to include the Peace Athabasca Delta. ALSO, in Column 3 AT: Peace Lowlands Ecosection ADD AT THE END: and the Peace valley, to and including the Peace Athabasca Delta Line 16, page 76: IN Table 16.6 Harvest of fish and wildlife resources assessment areas, Column 2 Local Assessment Area DELETE: the Alberta border INSERT: and including the Peace Athabasca Delta Line 24, page 70: IN Table 16.8 Navigation assessment areas, for both Column 2 AND Column 3 DELETE: Shaftesbury ice bridge INSERT: LaCrete ice bridge and ferry Current Use of Lands and Resources for Traditional Purposes Spatial Boundaries Harvest of Fish and Wildlife Resources Spatial Boundaries Navigation Spatial Boundaries Please see response to AEW_ltr_001 Please see Topic Summary: Peace Athabasca Delta Please see Topic Summary: Peace Athabasca Delta Please see response to TC_013 Page 10 of 463

11 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 AEW_tbl _031 Alberta Environment Line 9, page 71: REPLACE: The ice bridge at Shaftesbury WITH: The ice bridges and ferries at Shaftesbury and LaCrete Navigation Baseline Please see response to TC_013 AEW_tbl _032 Alberta Environment Line 9, page 83: IN Table 19.2 Human health assessment areas, Column 2 Local Assessment Area AFTER: water quality INSERT: (including raw water quality for drinking water of communities in Alberta downstream to and including the Town of Peace River) AFTER: methylmercury INSERT: (including fish consumption along the full length of the Peace River Human Health Spatial Boundaries (A) The water quality reference in Table 19.2 Human Health Assessment Area will follow Health 's water quality considerations including drinking and recreational water quality. The Water Quality Technical study area is delineated in EISG Water Quality. (B) The mercury concentrations in country foods referenced in Table 19.2 will include Health 's considerations for accumulations of mercury in country food sources. The methylmercury technical study is delineated in EIS Guidelines, Page 11 of 463

12 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_ltr_0 01 BC Ministry of Forests Lands and Natural Resource Operations Our review has identified that additional discussions are required around information and technical requirements for the management of wildlife resources as well as vegetation and plant communities, including species at risk (section 11 & 12). FLNRO recommends that a Terrestrial Working Group be established to further discuss these values. n/a BC Hydro welcomes the formation of any working group that the BCEAO and CEA Agency deems appropriate. BCMFLN RO_ltr_0 02 BC Ministry of Forests Lands and Natural Resource Operations FLNRO would like to request that the data, analysis reports, listing of technical experts and qualifications be made available at the time of release of the Draft Environmental Impact Statement so that FLNRO staff can conduct our own technical reviews of the data and assumptions should we choose to do so to verify the claims and conclusions of the proponent Technical Studies and Planning The EIS will include technical data reports and other supporting documents as appendices, including where feasible and permissible the data. Reports will be in final form and will include relevant professional information about the authors and contributors. The EIS sections and appendices will include lists of references and where possible key supporting studies, inventories or other technical documents will be made available. Information or reports subject to confidentiality agreements, privacy considerations or commercial sensitivity will not be provided. Page 12 of 463

13 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 01 BC Ministry of Forests Lands and Natural Resource Operations Project team members and qualifications will be presented. Recommend that the information provided clearly links project team members to specific work delivered. Authorship The EIS will present qualifications of team members and related subject matter expertise. BCMFLN RO_tbl_0 02 BC Ministry of Forests Lands and Natural Resource Operations Consider basing the estimates of construction and operation on a timeframe starting at the granting of an Environmental Certificate as the start of the scheduling timeframe, not those of the Joint Review Agreement, as those timeframes are subject to a public process and not entirely within the control of the proponent Scheduling of the EIS Guidelines will be revised as follows: "An estimated month by month construction schedule based on project planning at the time of preparation of the EIS will be incorporated into the EIS. The schedule will commence on the anticipated date of certification. The EIS will describe the anticipated scheduled maintenance activities and the potential future capital upgrades." BCMFLN RO_tbl_0 03 BC Ministry of Forests Lands and Natural Resource Operations Please provide the following at the time of submission of the EIS The most current GIS shapefiles for all project components for analysis purposes at the time of EIS submission. A list of the proponents interpretation of the Crown tenures that are conflicting with this project, by project component See section 3.2., page 4, 3.2. Project Location Information about land status, tenures and Project requirements will be described in (to be revised as below). Potential effects on tenured areas and activities will be assessed in accordance with EIS Guidelines 16 (Land and Resource Use). In support of Project permit applications BC Hydro will provide relevant mapping and tenure information, and a summary of communications with tenure holders, to the responsible regulatory agencies. The EIS Guidelines will be revised as follows: Delete tenure, ownership and land management details for lands with the areas of project components from 3.2, page 4. Add tenure, ownership and land management with the Project activity zone to Revise as follows: Land Status, Tenure and Project Requirements The EIS will: - Identify land ownership by area of private, BC Hydro owned, and Crown land within the Project activity zones - Provide a summary of land tenure within the Project activity zones, with potential effects to tenured areas or activities to be assessed in accordance with 16 Land and Resource use - Provide maps illustrating the ownership, tenure and land management areas with the Project activity zone Page 13 of 463

14 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, Describe the requirements to acquire or obtain new rights over private or government owned property to construct and operate the Project - Describe the approach for acquiring private property and rights to Crown land BCMFLN RO_tbl_0 04 BC Ministry of Forests Lands and Natural Resource Operations Consider providing information on the area of Crown land being occupied by the reservoir as well as the impact, in area, of the reservoir to the Crown Forest Landbase as well as the Timber Harvesting Landbase, by Forestry Management Unit be described for each of the project component areas Project Components and Activities Please see response to BCMFLNRO_tbl_003 In accordance with the EIS Guidelines, 16.3 Forestry, and the Project Clearing Plan, the EIS will describe the forest area affected by the Project using designated provincial forest land classifications. BCMFLN RO_tbl_0 05 BC Ministry of Forests Lands and Natural Resource Operations EIS will describe the permanent and temporary access routes required for access to the project site. Suggest including a description of the temporal aspects of road use (e.g. traffic management plans, expected traffic patterns and volumes for different phases of project development, deactivation schedules) Project Overview - Access Roads and Rail The EIS Guidelines will be revised by adding the following to the end of the first sentence of 3.3.5: "including a description of the temporal aspects of road use (e.g. traffic management plans, expected traffic patterns and volumes for different phases of project development, deactivation schedules)." Page 14 of 463

15 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 06 BC Ministry of Forests Lands and Natural Resource Operations Suggest including a description of alternative highway realignment options and a rationale for the preferred option Project Overview - Highway 29 Realignment The EIS Guidelines will be revised by adding the following to the beginning of 3.3.6: "The EIS will describe alternative highway realignment options and a rationale for selection of the preferred options." BCMFLN RO_tbl_0 07 BC Ministry of Forests Lands and Natural Resource Operations Sources of construction materials will be described here. Suggest including a description of the mechanism of delivery (e.g. truck, train) and expected traffic volumes during each phase Project Overview - Quarried and Excavated Construction Materials The EIS will describe the mechanism of delivery and expected traffic volumes during each phase. BCMFLN RO_tbl_0 08 BC Ministry of Forests Lands and Natural Resource Operations Consider including the projected impacts and upgrades to infrastructure required to facilitate the transportation of workers and equipment to and from the construction sites, and temporary accommodations on a daily basis in the discussion of worker accommodation. Suggest including related plans for management of workers (e.g. access management, hunting restrictions) and describing the size and use of the camp projected over different project phases Project Overview - Worker Accommodat ion Transportation is addressed in 17.5 Transportation of the EIS Guidelines , line 33 of the EIS Guidelines will be revised as follows: " The projected size and use of camp facilities will be described, including any related project employment policies or restrictions." Page 15 of 463

16 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 09 BC Ministry of Forests Lands and Natural Resource Operations Access roads to the dam site speaks to traffic management during modifications to existing roads, consider including traffic management in relation to any project component that may affect any road tenured by FLNRO Construction Phase Activities Traffic management during modification of existing roads will be described in the Traffic Management Plan referenced in 21 of the EIS Guidelines. BCMFLN RO_tbl_0 10 BC Ministry of Forests Lands and Natural Resource Operations Consider providing a rationale for the choice of installation of permanent versus temporary crossings over the Peace and Moberly Rivers and the benefits and drawbacks of both Construction Phase Activities of the EIS Guidelines will be revised by adding the following to the end of the bullet on lines 9 and 10, page 8: "including a rationale for the choice of installation of temporary rather than permanent crossings over the Peace and Moberly Rivers" BCMFLN RO_tbl_0 11 BC Ministry of Forests Lands and Natural Resource Operations Reservoir prep removal/treatment of existing structures... Consider including discussion of other hazards that may require removal Construction Phase Activities of the EIS Guidelines will be revised by adding the following to the end of the bullet on line 12, page 9: "including any other potential hazard to navigation at the minimum normal reservoir level." BCMFLN RO_tbl_0 12 BC Ministry of Forests Lands and Natural Resource Operations Construction and upgrade of the Access Roads to the Dam is addressed, consider including any major construction or upgrade of access roads to the other major components of the Project Construction Phase Activities of the EIS Guidelines will be revised by the inclusion of the following at the end of the first sentence: "and other project components." Page 16 of 463

17 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 13 BCMFLN RO_tbl_0 14 BCMFLN RO_tbl_0 15 BCMFLN RO_tbl_0 16 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations Traffic management during modification to existing roads Consider providing additional information regarding the needs of traffic management during other phases throughout the project Removal/decommissioning of existing pavement Consider providing clarification in the EIS if other materials used in road construction such as the gravel will be removed as well as the pavement and if not, why? See section , page 9, Connections to existing driveways Please provide clarification in the EIS if there are any driveways, properties or existing crown tenures that may need entirely new access routes constructed as a result of the highway realignment See section , page 9, Please include clarification in the description of temporary construction facilities of which offsite components of the project, which may normally not be considered as part of the asset, are going to be retained and maintained as part of the ongoing maintenance of the project. See section , page 11, Construction Phase Activities Construction Phase Activities Construction Phase Activities Decommissi oning Activities Please see response to BCMFLNRO_tbl_009. Where practical and economic, asphalt and other materials from the inundated sections of Highway 29 will be reused of the EIS Guidelines will be revised by adding the following to the end of the section: "The EIS will identify any driveways, properties or existing crown tenures that may need entirely new access routes constructed as a result of the highway realignment." The first sentence of of the EIS Guidelines will be revised to the following: The EIS will describe - offsite components of the project that are going to be retained and maintained as part of the ongoing maintenance of the project. - the decommissioning of the temporary construction facilities and any associated reclamation. BCMFLN RO_tbl_0 17 BC Ministry of Forests Lands and Natural Resource Operations Decommissioning of the Project is not currently contemplated, and there is no surety that heritage resources within the proposed dam site, reservoir, and reservoir adjacent lands would survive impacts that may result from decommissioning that may be proposed in the future. Recommend that the Guidelines be revised so as to recognize that these resources will be rendered permanently inaccessible, Decommissi oning Activities In accordance with the Effects Assessment Methods described in EIS Guidelines section , residual adverse effects on heritage resources will be characterized considering the duration of the effects. Project effects that are characterized as being for the life of the project will be considered permanent. Page 17 of 463

18 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 should the Project proceeds. BCMFLN RO_tbl_0 18 BCMFLN RO_tbl_0 19 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations As the Call for Power Program is within BC Hydro s control, please include a section in the EIS on the estimates of potential or projected power production and the feasibility of acquiring power from 3rd parties including Wind Generation. Consider providing a section of the potential drawbacks of the project and conducting a cost/benefit analysis 4.2. Alternatives to the Project 5. Project Benefits The content requested is included in the uidelines. Potential future power acquisitions from 3rd parties (calls) are identified as alternatives in 4.2, Alternatives to the Project ("alternative generation sources to the Project") and evaluated as part of the analysis referred to in of the EIS Guidelines. Project Benefits (EIS Guidelines 5) is intended to summarize the benefits of the project. The potential adverse effects are addressed in the balance of the EIS assessment sections. The content of the Project Benefits section as stated in the EIS Guidelines is aligned with 11 of the "Guidelines for the Preparation of an Environmental Impact Statement for the Comprehensive Study Process Pursuant to the Canadian Environmental Assessment Act" and 2.7 of the "BC Application Information Requirements Template". BCMFLN RO_tbl_0 20 BC Ministry of Forests Lands and Natural Resource Operations Please include a detailed description and summary of communications with affected tenure holders by project component Public Information Distribution and Consultation - Pre-panel Review Stage Please see response to BCMFLNRO_tbl_003 Page 18 of 463

19 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 21 BCMFLN RO_tbl_0 22 BCMFLN RO_tbl_0 23 BCMFLN RO_tbl_0 24 BCMFLN RO_tbl_0 25 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations Where feasible, consider aligning spatial boundaries with the defined boundaries currently utilized by FLNRO and the other agencies, such as Timber Supply Areas, Wildlife Management Units, Landscape Units etc. for ease of analysis and comparison to existing data. Some clarification here on how the LAA and RAA link to terms used in the Stage 2 reports (e.g. Peace River Corridor, Transmission Line, Inundation Zone, Regional Area) would be helpful in this section. Consider identifying those potential mitigation measures that were excluded from consideration that were not technically or economically feasible. Table 8.3 Please provide the criteria by which the probability of the adverse impact occurring will be assessed Where feasible consider aligning spatial boundaries with existing established administrative and analysis boundaries i.e. Wildlife Management Units, Landscape Units, Timber Supply Areas, etc. See section , page 28, Consider expanding the Project Inclusion list to include existing Land Act tenures, reserves and notations of interest applications for land act tenures that have been accepted by FLNRO Spatial Boundaries Identification of Mitigation Measures Characterizin g Residual Effects Cumulative Effects Assessment - Spatial and Temporal Boundaries The Project Inclusion List Where available and relevant to the land use under consideration, appropriate land use planning areas were used to define spatial boundaries (e.g., Forestry Regional Assessment Area has been defined based on TSAs and TFLs (uidelines ). The LAA and RAA for each VC are determined based on the characteristics of the VC. The terminology used in Stage 2 reports are not sensibly "linked" to the LAA and RAA boundaries. The EIS will present analysis of technically and economically feasible mitigation measures where appropriate. Probability of an adverse effect will be described with the precision appropriate to the level of confidence, and stated in quantitative terms where possible. Please see response to BCMFLNRO_tbl_021 Please refer to the Project Inclusion List section of the Topic Summary: Cumulative Effects Assessment. Page 19 of 463

20 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 currently approved forestry cutting permits, timber sale licenses, and other harvesting authorizations range tenures and grazing licenses Fort St. John Pilot Project Sustainable Forest Management Plan and Forest Operations Schedule Information from BC Timber Sales and major forestry licensee Annual Operating Plans where appropriate. Traplines and trapline cabins Guide Outfitter areas Page 20 of 463

21 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 26 BC Ministry of Forests Lands and Natural Resource Operations Request clarification on whether the proponent is modeling landslide displacement waves, or not, and if not please provide a rationale as to why not. Consider providing information as to when, and under what sort of climatic conditions past landslides occurred Geology, Terrain and Soils of the uidelines will include the following bullet after line 31 page 30: "physical and numerical modelling of waves that could potentially be generated by landslides into the reservoir". Please see response to NRCan_008. Page 21 of 463

22 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 27 BC Ministry of Forests Lands and Natural Resource Operations Based on best available information on seismicity and seismic hazard, the EIS should quantify the generation and propagation of water waves ("tsunamis") that would be triggered in the reservoir by earthquakes and possibly in tandem with landslides and avalanches potentially triggered by the same earthquake. In addition, the potential impacts due to water waves generated by landslides or avalanches at other times should be addressed. See section , page 30, Geology, Terrain and Soils See Topic Summary: Seismic Considerations Please see response to BCMFLNRO_tbl_026 BCMFLN RO_tbl_0 28 BCMFLN RO_tbl_0 29 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of each model for the applications intended. This should include a description of the calibration and validation/verification of each model and model performance in these tests. This is of particular importance when the model used is proprietary, such as the models HYSIM, Generalized Optimization Model, and H3D listed in Table 9.1 on p.32. See section , page 31, Please provide flow patterns pre- and postconstruction to a sufficient level of detail. In addition to statistical parameters (e.g. percentiles) of the flows, water levels, etc., please provide cumulative exceedance plots that would provide insights to the changes in both the diurnal and seasonal variations of the flow parameters. Alternatively, tables of statistical parameters for each month in the simulation period would provide a level of details that would be needed to understand Surface Water Regime Surface Water Regime The EIS will describe the calibration and validation of models used in the assessment , line 33, of the EIS Guidelines will be revised by adding: " the level of confidence". Please see response to AEW_tbl_008 Page 22 of 463

23 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 project impacts. See section , page 31, BCMFLN RO_tbl_0 30 BCMFLN RO_tbl_0 31 BCMFLN RO_tbl_0 32 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of CRISSP in simulating conditions in the Peace River. This should include a description of model performance in the calibration and verification of the stations of interest along the Peace River. See section , page 34, To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of the model(s) used to characterize the potential changes. This should include a description of model performance in the calibration and validation/verification of the reach simulated in the Peace River. See section , page 35, In addition to the title and publication information of a reference, the citation should include specific section and page numbers of relevance. For citations not readily or publicly available, a sufficiently detailed description on the supporting information from the citation to the issue(s) addressed in the EIS. These additional details are important and would expedite the review given the limited time available. See section 9.5., page 38, Thermal and Ice Regime Fluvial Geomorphol ogy and Sediment Transport 9.5. Environment al Background - References 9.2.4, after line 33 of the EIS Guidelines will be revised as follows: "The EIS will describe the calibration, validation, and expected accuracy of the CRISSP ice model" , page 35, Line 25 of the EIS Guidelines will be revised as follows: "including a discussion of model reliability " after "The EIS will present the results of predictive modelling," The EIS will contain appropriate referencing to publications or technical documents used in the assessment to ensure expedient and transparent review. Page 23 of 463

24 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 33 BCMFLN RO_tbl_0 34 BCMFLN RO_tbl_0 35 BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations BC Ministry of Forests Lands and Natural Resource Operations While abundance of fish is mentioned, please ensure that high data quality are collected for real comparisons to reference points based on meso-habitat scale detail. Use of models is of limited utility if there is no correlation with fish abundance or fish community composition shift. See section 10., page 38, Similar to Table 12.1 (pp45), biodiversity should be included as a fish and fish habitat valued component in Table Biodiversity is identified as a value in local Land and Resource Management Plans. Suggested addition to Table 10.1 line 5, pp39. Include biodiversity as a valued component. See section 10.1., page 39, The downstream boundary of the local assessment area where potential adverse effects will be considered is to the Pine River. Potential changes to downstream water conditions (flows, turbidity and temperatures) in the Peace River are likely to extend beyond the Pine River and may have effects to species such as goldeye, walleye and flathead chub. In addition effects to fish species such as bull trout and arctic grayling originating from the Pine River that utilize the Peace River upstream of the proposed Site C dam need to be assessed. Suggested change to Table 10.2 (p.39 line 9): Local Assessment Area The Peace River sufficiently downstream to capture anticipated effects of the project to fish and fish habitat See section 10.2., page 39, 10. Fish and Fish Habitat Effects Assessment Fish and Fish Habitat VC Scoping and Rationale Fish and Fish Habitat Spatial Boundaries The potential effect of the Project on fish and fish habitat can be assessed without characterizing each and every element of the meso-habitat. Comments noted and text has been revised. Change text, page 39, table 10.1; add biodiversity to column 4 Please see response to DFO_023 Page 24 of 463

25 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 36 BC Ministry of Forests Lands and Natural Resource Operations Fish species stock structure (size at age) maybe affected by the project and should be included for as a key indicator. Suggested change to p.40 line 11: fish species, stock structure, community, abundance, distribution, movement and life history See section , page 40, Fish and Fish Habitat Baseline Comments noted and text has been revised. Change text, page 40, Line 11, bullet 1; ADD stock structure BCMFLN RO_tbl_0 37 BC Ministry of Forests Lands and Natural Resource Operations The BC Conservation Framework as another tool to identify species of interest. Suggested change to p.40 line 18: Provincial Red and Blue Lists (BCMOE 2010b) and advice from the BC Conservation Framework. See section , page 40, Fish and Fish Habitat Baseline , page 40, line 18 of EIS Guidelines will be revised as follows: ADD BC Conservation Framework AFTER ) Page 25 of 463

26 Site C Clean Energy Project to Advisory Working Group Comments on Draft Environmental Impact Statement Guidelines, Version 1 March 30, 2012 BCMFLN RO_tbl_0 38 BC Ministry of Forests Lands and Natural Resource Operations In addition to radio telemetry studies, microchemistry/genetic assessment to determine tributary origin and movements should be reported on. Suggested change to p.40 line 21: Peace River radio telemetry and microchemistry/genetic studies See section , page 40, Fish and Fish Habitat Baseline Comments noted and the text has been revised. Change text, , page 40, line 21: ADD and microchemistry/genetics studies AFTER studies Page 26 of 463