ANNEX XIII.B ASHCROFT RANCH LANDFILL PROJECT PUBLIC CONSULTATION GVRD RESPONSES TO KEY ISSUES

Transcription

1 ANNEX XIII.B ASHCROFT RANCH LANDFILL PROJECT PUBLIC CONSULTATION GVRD RESPONSES TO KEY ISSUES Ashcroft Ranch Landfill Project Public Consultation 1

2 Ashcroft Ranch Landfill Project Application for Environmental Assessment Certificate ANNEX XIII.B Ashcroft Ranch Landfill Project Public Consultation August 3, 2004 Ashcroft Ranch Landfill Project Public Consultation 2

3 ANNEX XIII.B Ashcroft Ranch Landfill Project Public Consultation The purpose of this annex is to meet Ashcroft Ranch Landfill Project Terms of Reference Information Requirement 15c) regarding Public Consultation and Communications, which states that the Application for Environmental Assessment Certificate must include: a stand-alone Public Response Document (cross-referenced to relevant sections of the Application) highlighting the top issues raised during consultation activities carried out in relation to the Project and how these issues are being addressed (including relevant assessment study findings and conclusions and proposed measures for preventing or mitigating impacts). This annex is also intended to provide interested parties with an easy-to-read document that: captures the key Project issues raised during the Public Consultation and Communications Program (pre-application phase); and, demonstrates clearly how these issues are addressed by the Application for Environmental Assessment Certificate. Key Project issues were identified as those issues raised frequently during the Project s public consultation and communications activities. The issues/responses appearing in this document are arranged thematically and the order does not denote importance. The responses address issues related to: 1. Project rationale 2. Public and First Nations consultation 3. Impact assessment approach Potential Impacts 4. Agricultural impacts 5. Archaeological and heritage impacts 6. Groundwater impacts 7. Surface water impacts 8. Vegetation impacts 9. Wildlife impacts 10. Air quality impacts 11. Human health impacts 12. Noise impacts 13. Visual impacts 14. Potential increase in vectors Ashcroft Ranch Landfill Project Public Consultation 3

4 15. Economic impacts 16. Traffic impacts Operational Issues 17. Landfill gas management 18. Monitoring and compliance Each of these key issues will be briefly explained, followed by: regulatory criteria, where applicable; studies undertaken by the Project to address these issues, where applicable; study findings and conclusions, where applicable; measures proposed by the Proponent to address these issues; relevant references to Application for Environmental Assessment Certificate sections. Where possible, responses are provided using verbatim text from Volume 1 of the Application for Environmental Assessment Certificate. In some instances, material is reordered and condensed; and plain language text is used to provide clarity where quoted material would appear without context. Volume 1 section references (e.g ) indicate from where in the Application the information preceding the reference was extracted. Ashcroft Ranch Landfill Project Public Consultation 4

5 ISSUE 1: Project rationale Ashcroft Ranch Landfill Project consultation participants expressed both concern and support regarding the decision to locate a GVRD municipal solid waste landfill in Ashcroft. Concern was also noted, and interest expressed, regarding the relationship between the proposed Landfill and the GVRD s 1995 Solid Waste Management Plan; whether an amendment to the Plan would be required; and the nature of any required amendment. Rationale Since 1989, residual municipal solid waste from the Greater Vancouver Regional District (GVRD), the Thompson-Nicola Regional District (TNRD), and other regional districts has been disposed at the Cache Creek Landfill. The Cache Creek Landfill is estimated to reach capacity and close around Therefore, new disposal capacity will be required by 2007 to ensure that residual municipal solid waste continues to be disposed in an environmentally acceptable manner. The Ashcroft Ranch Landfill Project (Project) is an initiative to site a replacement landfill on the Ranch, which is located in the TNRD and within the Village of Ashcroft. (1.4) GVRD Solid Waste Management Plan (SWMP) The Cache Creek Landfill serves as one of three major disposal facilities for the GVRD, within the context of the GVRD s 1995 Solid Waste Management Plan (SWMP). The SWMP recognized the finite capacity of the Cache Creek Landfill and the need for the GVRD to develop additional landfill capacity. This Project was initiated to fulfill that requirement. Plan amendment Although the SWMP recognized the need for additional disposal capacity, it will need to be amended to allow for the shift in the destination of waste from the Cache Creek Landfill to the new facility, if approved. This amendment process will be initiated with the Application for Environmental Assessment. (1.2) Why Ashcroft Ranch? The following table provides the key event chronology behind the decision to proceed with a replacement municipal solid waste landfill on Ashcroft Ranch. (3.1) Date Event Related Outcome Greater Vancouver Regional Solid Waste Management Plan 1986 GVRD invites private sector tenders for the transfer and disposal of waste need for long-term disposal capacity identified Wastech Services Ltd. successful respondent Ashcroft Ranch Landfill Project Public Consultation 5

6 Date Event Related Outcome 1989 Cache Creek Landfill opens co-permitted to Wastech and the Village of Cache Creek Comprehensive review of the GVRD Solid Waste Management Plan 1996 GVRD and Wastech negotiate Comprehensive Agreement Expansion of Cache Creek Landfill investigated by Wastech Alternative sites investigated by Wastech 1998 GVRD reaches 50% waste reduction target 1995 Solid Waste Management Plan approved 50% waste reduction target established need for additional disposal capacity identified the development of additional landfill capacity at the Cache Creek Landfill or the establishment of a replacement landfill part of the Comprehensive Agreement rejected as land in question was Crown Land; Wastech unable to resolve actual or potential First Nations issues 15 sites investigated using search criteria (listed below) based on these criteria. the site that emerged with the best potential was Ashcroft Ranch implementation of material bans in landfills and expansion of curbside recycling proves effective waste reduction measures continue to be implemented 1999 Ashcroft Ranch selected Wastech enters purchase agreement with owners of Ashcroft Ranch; agreement allows Wastech to assign the purchase agreement Preliminary investigations conducted on the Ashcroft Ranch no critical physical or environmental flaws were found during preliminary field investigations for a landfill on Ashcroft Ranch 2000 Ashcroft Ranch purchased GVRD takes assignment of Ashcroft Ranch Ashcroft Ranch Landfill Project Public Consultation 6

7 Critical Siting Issues Wastech examined a number of considerations in assessing landfill site options following the rejection of the expansion of the Cache Creek Landfill as an option, including: Physical Considerations large enough site to accommodate disposal capacity needs for 50 to 100 years large enough site to enable a significant buffer zone to be established around the landfill direct line of sight to the landfill would be limited to significant distances avoidance of proximity to major public or private developments land use and zoning of the property to allow development of a municipal landfill the Agricultural Land Reserve and non-agricultural uses in the Agricultural Land Reserve good highway access from the GVRD and lower Fraser Valley to utilize available backhauls that assist with operation economics availability of other infrastructure (e.g. electricity, water) and access to landfill support services. Environmental Conditions dry climate of the Thompson-Nicola Regional District and parts of the Squamish-Lillooet Regional District were considered suitable a seismically stable area, with good geological and hydrologic conditions were considered as extremely important the presence/absence of any significant archaeological findings, rare or endangered biological flora or fauna, and proximity to a commercial airstrip. Socio-Economic Considerations private ownership in fee simple of the land land free of any access constraints or preconditions involving Crown lands willingness of landowner to sell the property site s location relative to good transportation access proximity of the site to the significant existing investment in infrastructure (large skilled workforce, support services from other firms, Wastech maintenance facility, wood chip plant) waste management knowledge of the politicians in the immediately surrounding area, of those in the regional district, and that of the citizens of the community at large. (1.5.3, 3.1) An amendment to the 1995 Greater Vancouver Regional Solid Waste Management Plan is being initiated, with the Application for Environmental Assessment Certificate, to allow for the shift in the destination of waste from the Cache Creek Landfill to the new facility (if approved). Once the remaining initiatives of the 1995 Plan (including the development of additional landfill capacity on Ashcroft Ranch) are substantially complete, the GVRD will engage in a process to review the Solid Waste Management Plan. Ashcroft Ranch Landfill Project Public Consultation 7

8 ISSUE 2: Public and First Nations consultation Concern and interest were expressed regarding the extent of public and First Nations consultation. In addition, interest was noted regarding issues of particular importance to project area First Nations and how those issues are addressed. Extent of Public Consultation The GVRD s commitment to public consultation is identified in Guidelines for Public Consultation and Advisory Committees, which state that the GVRD will conduct consultations on major projects, planning initiatives and programs. As well, the Project has met, and will continue to fulfill, all consultation and communications requirements applicable under the British Columbia Environmental Assessment Act as specified for the Project in a Section 11 Order issued by the Environmental Assessment Office (EAO) on March 20, The EAO approved the Consultation and Communications Plan submitted by the GVRD for the Project (July 30, 2003). On August 29, 2003, when issuing the approved Application Terms of Reference, the EAO commended the GVRD for establishing and maintaining a high standard of public consultation and involvement. (4.1) The consultation and communications program is focused on the development of the Landfill and related issues. The program addresses interests in the following geographical areas: Local Project area including the Villages of Ashcroft and Cache Creek, the First Nations communities in the area, and the nearby rural areas in the Thompson-Nicola Regional District. Greater Vancouver including GVRD member municipalities and residents. Other Regional Districts elected officials and senior staff of regional districts that are current clients of the Cache Creek landfill and are potential clients of the proposed Landfill. Province including government agencies, non-governmental organizations and business associations with a regional or province-wide focus that have a direct interest in the Ranch site and/or management of GVRD solid waste facilities. (4.2) An integral part of the consultation program is the hosting of public events and communicating with residents in both the Project area and the Lower Mainland. To this end, the GVRD hosted seven open houses between April 2002 and August A key aspect of the program is the dissemination of information material and timely notification to ensure that the public and interested parties are apprised of the Project s status and technical details. Information materials developed between April 2002 and August 2004 included: 10 fact sheets and nine (9) newspaper advertisements including general project information, open house notifications and EAO notification of the formal public comment period on the draft Terms of Reference. As well, display panels to support each open house were developed. Ashcroft Ranch Landfill Project Public Consultation 8

9 Using local community post offices, open house notification flyers and fact sheets were mail dropped to over 2,100 residences and businesses in the Ashcroft and Cache Creek area, including portions of the adjacent Thompson-Nicola Regional District Area I. These materials were also mailed directly to more than 100 individuals and organizations in the Project area, Greater Vancouver and elsewhere in British Columbia who are on the Project database. (4.3) Extent of First Nations Consultation The GVRD identified four First Nations with a potential interest in the Project: the Ashcroft, Oregon Jack Creek, Cook s Ferry and Bonaparte Bands. Representatives of the Environmental Assessment Office (EAO) confirmed that these were the Bands who should be involved in consultation (as noted in the Environmental Assessment Act Section 11 order). The four Bands are affiliated with three different Tribal Councils as follows: Ashcroft Indian Band and Oregon Jack Creek Band (affiliated with the Nlaka pamux Nation Tribal Council); Bonaparte Indian Band (affiliated with the Shuswap Nation Tribal Council); and Cook s Ferry Indian Band (affiliated with the Nicola Tribal Association) (5.1) The First Nations consultation program is focused on the development of the Landfill and related issues. The objective of the program is to consult with the First Nations whose interests may be affected by the Project, consistent with the Provincial Policy for Consultation (2002), BC Environmental Assessment Act. (5.2) GVRD activities with Project area First Nations Bands and Tribal Councils have consisted of meetings, telephone conversations and written correspondence. The activities to date have included: holding preliminary meetings and discussions in an effort to engage in dialogue on the environmental assessment process and the Landfill; distributing correspondence from the GVRD and/or their technical consultants at key Project milestones; distributing correspondence from the GVRD and/or their technical consultants in response to issues raised by First Nations; providing access to comprehensive technical information in relation to the Project and the existing Cache Creek Landfill in response to requests from First Nations; responding to correspondence/telephone calls from First Nations expressing process and Projectrelated concerns; responding to submissions made to the EAO from First Nations regarding the draft Terms of Reference; participating in ongoing meetings with First Nations Bands and Tribal Councils to provide Project information and gather input; and documenting and summarizing First Nations input on the Project issues. (5.3) Ashcroft Ranch Landfill Project Public Consultation 9

10 Issues of particular interest to First Nations Archaeology see response to Issue 5 Vegetation see response to Issue 8 and Traditional Land Use below Traditional Land Use the issues identified that are unique to First Nations from the socio-economic impact assessment are traditional land use and access to traditional territory. First Nations have asserted that the Ranch is part of their traditional territory and that the Ranch was used for hunting and gathering. The Project will only impact a small portion of the Ranch and the traditional foods identified are not considered rare and have been located in other areas in the region. As private property, under the Trespass Act, all people require permission from the property owner or operator before entering the Property. This requirement, rather than the Project, is the primary controlling factor for the issues of traditional land use and access to traditional territory, and thus the social impacts to First Nations are considered to be neutral. (10.2.2) Impact Prevention and Mitigation The following Project measures address issues related to public and First Nations consultations; and prevent or mitigate potential impacts on issues of particular importance to First Nations: continue with efforts to meet and discuss issues of interest with local First Nations, with the objective of achieving a mutually satisfactory outcome on these matters during Project development ( ) continue with consultation and communication activities as outlined in Appendix XIII (Public) and Appendix XIV (First Nations) ( ) notification to the surrounding community, including First Nations, about local employment opportunities ( ) provision of the substantial part of the funds for the Village of Ashcroft to establish a Landfill Advisory Committee, which will include an invitation for local First Nations from the surrounding area to be represented on such committee ( ) undertaking a project to support a reclamation goal for the Landfill area to attempt to reinstate native grassland communities, including bitterroot and yellowbell (traditional use plants) (11.1.2, ) First Nation Communities one of the considerations for selecting the location of the Landfill and access road within Ashcroft Ranch was the desire to mitigate potential effects of these facilities on nearby First Nation communities. Factors that mitigate the potential effects of these facilities include: selecting an access road option, with an intersection with Highway 1 that is more than 2.5 km from the nearest First Nation community; the conceptual operations plan that includes measures to control dust, odours, and windblown debris; and sequencing of the development of the Landfill such that waste disposal will occur more than 2.5 km from the nearest First Nation community. (11.1.1) Ashcroft Ranch Landfill Project Public Consultation 10

11 Archaeological resources archaeological sites will be surveyed in detail and artifacts will be collected, catalogued and relocated to an appropriate museum or other suitable facility as approved by the Archaeological Permitting Section of the Minister of Sustainable Resource Management in consultation with First Nations. (11.1.2) Summaries of the interim consultation reports, including First Nations input, are available on the Project web site ( Ashcroft Ranch Landfill Project Public Consultation 11

12 ISSUE 3: Impact assessment approach Consultation participants expressed interest in, and noted concern over, the extent of impact assessment studies. Some participants also questioned the scientific validity of an environmental impact assessment for a landfill with a proposed 100-year lifespan. The Application for Environmental Assessment Certificate describes the results of an assessment of the potential environmental, economic, social, heritage and health effects (impacts) of the Ashcroft Ranch Landfill Project. A Draft Terms of Reference outlining the approach, information sources and methodologies of the proposed impact assessment studies was prepared. The B.C. Environmental Assessment Office (EAO) invited comment on the Draft Terms of Reference, March 24, 2003 to May 12, 2003, to ensure public issues were identified and addressed as part of the review process. The impact assessment approach used by the Project was approved by the EAO in the final Terms of Reference on August 29, The impact assessment approach was to: characterize the environmental, economic, social, heritage and health setting (baseline); identify issues based on input from regulatory authorities, the professional opinion of consultants retained by the GVRD, and input from consultation activities; describe the Project s environmental protection measures; characterize the environmental, economic, social, heritage and health effects associated with both an operational scenario and a scenario following landfill closure; and identify and describe measures for preventing or mitigating potential environmental, economic, social, heritage and health impacts of the Project. (2.1) Where possible, environmental baseline conditions and predicted impacts were compared to established federal and provincial regulatory criteria. (1.5.2) Geographic extent of study areas The study areas for the impact assessment, for the different disciplines are presented under the specific issue in this document. The study boundaries vary for each discipline because of the varying geographic extent of potential impacts for each discipline. (2.5) Temporal extent of studies The temporal (time-related) boundaries for the impact assessment assume: commencement of landfilling in 2007; a 100-year landfilling period; and, a 25-year period after closure. Ashcroft Ranch Landfill Project Public Consultation 12

13 Existing or baseline conditions were assumed to be those observed during field surveys between 1999 and April 2004 and assume closure of the Cache Creek Landfill in Throughout the life of the Project, construction, operations and closure activities will occur simultaneously in different areas. The potential impacts from Project activities during the following Project phases have been addressed: Operations: landfill operation, ongoing landfill construction activities (including clearing, grubbing, excavation) and progressive closure. A scenario for a specific year of operations was assessed for some of the disciplines (e.g. air quality, groundwater); and Post-closure: the 25-year period after the Landfill is finally closed. (2.5) Several commitments are being made, including provision of an environmental management plan, which provides for monitoring, reporting, assessing and, where necessary, implementing actions to correct or improve conditions during Landfill operations and post-closure phases. Related Project commitments: submission of a detailed operations and closure plan (that includes the components of an environmental management plan) to the Ministry of Water, Land and Air Protection as part of the application for an Operational Certificate ( ) employment of sustainable practices for the design, construction, operation and closure of the Landfill and associated facilities to the extent practical ( , ) provision of the substantial part of the funds for the Village of Ashcroft to establish a Landfill Advisory Committee, which will include an invitation for local First Nations from the surrounding area to be represented on such a committee ( ) monitoring the groundwater at selected monitoring wells on the Ranch as necessary ( ) provision of the substantial part of the funds for the Village of Ashcroft to conduct an annual engineering review of the Landfill operation ( ) all requirements of the applicable federal, provincial and municipal laws and permits, including the Environmental Assessment Certificate and Operational Certificate, will be met ( ) quality control/quality assurance monitoring during installation of the liner and leachate collection system ( ) inspecting all waste loads that arrive at the Landfill in accordance with the prevailing Canadian industry practice for landfills operating under similar conditions ( ) monitoring and controlling rodents at the Landfill, including the use of skilled professionals where required ( ) collection of debris in the surrounding area, as necessary in accordance with the prevailing Canadian industry practice for landfills operating under similar conditions ( ) monitoring for weeds on the Ranch in areas immediately surrounding Project activities at least annually and implementing control measures where warranted ( ) provision of post-closure financial security, as required. ( ) Ashcroft Ranch Landfill Project Public Consultation 13

14 ISSUE 4: Potential agricultural impacts Consultation participants expressed concern regarding potential Project impacts to agricultural land, including the loss of agricultural land and the loss of opportunity to enhance the agricultural capability of Ashcroft Ranch. Applicable Regulatory Criteria The Agricultural Land Commission is the governing entity and the applicable law is the application for non-farm use, to place fill or remove soil under the Agricultural Land Commission Act. (1.6) Impact Assessment Studies The key components that were identified and evaluated in terms of project effects on agricultural land are noted below: socio-economic economic factors (land use) soils agricultural capability and soil quality vegetation quantity of each type of vegetation type. (2.2) Agricultural Setting The Ranch has been used primarily for agriculture, supporting cultivated crops, where soil conditions and water supply for irrigation permit, and cattle ranching. The Project and Ranch are within the Agricultural Land Reserve boundaries. (7.1.5) The baseline assessment for soils consisted of a review of existing information, including relevant provincial terrain and soil maps, on-site soil maps and surficial geology reports. A field investigation was also conducted. Aerial photographs were used in the interpretation of preliminary terrain and soil types and a soil survey was undertaken to confirm the interpretation. More than 100 soil inspection sites were established and soil samples were collected and analyzed for fertility and mineral content. The results of the baseline assessment for soils indicate that the main limitation for agricultural production in the area was the lack of soil moisture due to the arid climate. (7.4.8) The baseline assessment for vegetation consisted of a review of relevant literature, and consultation with local regulators. A spring vegetation and rare plant survey and a summer vegetation and rare plant survey were conducted entailing investigation of 66 plots in the 487-hectare vegetation study area and 16 plots in the 46-hectare aggregate borrow study area. Grassland vegetation types such as Big sage-bluebunch wheatgrass and Big sage-needle-and-thread grass were dominant in the study area, which varied from moderately to lightly grazed. (7.4.9) Ashcroft Ranch Landfill Project Public Consultation 14

15 Assessment of Potential Project Impacts: Approximately 6.5 % of the Ranch s 4,200 ha will be disturbed by the Project and portions of that will be temporarily unavailable for agriculture. Most of this land is currently used for spring grazing and represents a loss of approximately 90 ha of grassland available for grazing at any one time, which translates into the loss of approximately 10 to 16 cow/calf pairs per year during the operations phase of the Project. The Project is not expected to impede ranching activities at that level of production. The Project will not require removal of any land from the Agriculture Land Reserve however an application will be made to the Agricultural Land Commission for non-farm use of the Landfill and Aggregate Borrow areas. (10.1.5) Disturbances to soils and terrain will affect up to a total of 277 hectares during the operating life of the Project. The actual area of disturbance will be less because the above total includes a 26-hectare buffer around the Landfill, of which only a small portion will actually be disturbed for the perimeter road and ancillary facilities. This disturbance will temporarily reduce soil quality and agricultural capability. Salvaging and replacing topsoil in the disturbed areas following closure can restore the land to its pre-project agricultural capability. There is adequate topsoil to reclaim disturbed areas with a minimum 100 mm thickness of topsoil. Baseline and closure agricultural capability are expected to be similar. (10.4.8) For information on potential impacts to vegetation, refer to the response to Issue 8. Impact Prevention and Mitigation Project measures designed to prevent or mitigate potential impacts to agricultural activity and capability are as follows: fencing the working area of the Landfill to exclude ranch stock (i.e. cattle and horses) (11.1.1) placing a minimum of 1.15 m thickness of final cover soil over permanently placed refuse, which includes 0.1 m thickness or more of topsoil ( ) providing dust control as required in accordance with the prevailing Canadian industry practice for landfills operating under similar circumstances ( ) collection of debris in the surrounding area, as necessary in accordance with the prevailing Canadian industry practice for landfills operating under similar circumstances ( ) phasing the areal extent of the Project operations to ensure the maximum area is available for agricultural use ( ) returning the Landfill and aggregate borrow areas to agricultural use following closure of each active cell ( ) coordination and planning with Ranch management with respect to mitigating disruption to ongoing agricultural operations ( ) revegetating the final surface of the Landfill and aggregate borrow to meet, as a minimum, existing levels of vegetative productivity and agricultural capacity ( ) undertaking a project to support a reclamation goal for the landfill area to attempt to reinstate native grassland communities, including bitterroot and yellow bell (traditional use plants) ( ) Ashcroft Ranch Landfill Project Public Consultation 15

16 monitoring for weeds on the Ranch in areas immediately surrounding Project activities at least annually and implementing control measures where appropriate ( ) providing post-closure financial security, as required. ( ) For additional measures that prevent or mitigate potential impacts to vegetation, refer to the response to Issue 8. Ashcroft Ranch Landfill Project Public Consultation 16

17 ISSUE 5: Potential archaeological and heritage impacts Consultation participants noted concern over the potential impacts of the Project on the archaeology of, and heritage values associated with, Ashcroft Ranch. Applicable Regulatory Criteria The Archaeology and Registry Services Branch of the Ministry of Sustainable Resource Management is the governing entity and the applicable law is the heritage investigation permit and site alteration permit; Heritage Conservation Act. (1.6) Impact Assessment Studies The following were identified and evaluated for potential Project effects: heritage resources archaeological sites that are protected under Section 13 of the Heritage Conservation Act heritage resources designated heritage sites under Section 9 of the Heritage Conservation Act, or on other buildings, structures, or monuments that have heritage value. (2.2) An archaeological impact assessment was carried out and focused on archaeological sites that are protected under Section 13 of the Heritage Conservation Act. The assessment consisted of a review of existing information, a field inventory, and an assessment of potential Project impacts to archaeological sites. A Heritage Inspection Permit was obtained to conduct archaeological field investigations in and around the Landfill and aggregate borrow areas. Three First Nations Bands participated in the investigations. (7.3.3) Baseline information was collected for the entire study area, but the impact evaluation focused on the disturbance areas, with consideration of potential indirect impacts to archaeological sites outside the disturbance areas. (2.5) Prior to undertaking archaeological field work for the Project, there was one archaeological site located within the present archaeology study area in the records of the Registries Department, Archaeology and Registry Services Branch, Ministry of Sustainable Resource Management. The site could not be located during the field assessment. (7.3.3) Archaeological/Heritage Setting The area of the Ashcroft Ranch was settled by the Cornwall brothers in Since then, the Ranch has been used primarily for agriculture, supporting cultivated crops, where soil conditions and water supply for irrigation permit, and cattle ranching. (7.1.5) Ashcroft Ranch Landfill Project Public Consultation 17

18 The Ranch lies within the asserted traditional territories of the Ashcroft, Oregon Jack Creek, and Cook s Ferry Indian Bands of the Nlaka pamux Nation, and the Bonaparte Indian Band of the Secwepemc Nation. Archaeologically, the study area lies within the Canadian Plateau cultural subarea, and more specifically the Thompson River region. A high density of archaeological sites is known to exist in the Ashcroft region. Most of the larger sites are located near the Thompson River or on the lower reaches of its tributaries. With some exceptions, sites at higher elevations are typically smaller and of lower frequency. This site distribution reflects the locations of seasonal activities that characterized the traditional economy of First Nations in the region. (7.3.3) Eighty-four archaeological sites that are protected under the Heritage Conservation Act were documented in the study area, encompassing a total area of approximately 130 hectares. This is a very high density of archaeological sites. Based on the archaeological impact assessment results, the sites are interpreted to be the remains of First Nations hunting, plant collecting and processing, and camping activities over a period of several thousand years. All, except two sites in the Landfill area, were lithic scatters (stone tools and associated waste material). Of the two exceptions, one site had root roasting pits and the other site had possible habitation depressions. (7.3.3) There are no provincially designated heritage sites (under Section 9 of the Heritage Conservation Act) or other non-archaeological heritage sites in the study area that will be physically impacted by the Project. The nearest structures or locations that are regionally designated or have heritage value are: Cornwall Cemetery (heritage designation from the Thompson-Nicola Regional District and protection under either Section 13(2)(b) of the Heritage Conservation Act or the Cemetery and Funeral Services Act, or both) and the Ashcroft Manor (no formal designation but was established in 1862). Both sites are located more than 1.5 km from the Landfill and outside the Heritage Resources study area. (7.3.1, ) Assessment of Potential Project Impacts Out of the 84 archaeological sites identified, the Project is expected to affect at least a portion of 58 sites, of which, 38 would be completely impacted and 6 more would be impacted to a high degree during the operations phase of the Project. Lower magnitude impacts are expected at 14 sites. This is considered to be an overall high magnitude of impact to archaeological sites. (10.3.3) The impacts would occur at various times throughout the operations phase, depending on the schedule for physical alterations to the ground, and all direct impacts are expected to be restricted to the Project area. This is assessed as a moderate duration and a local extent of impacts. All direct adverse impacts are expected to be severe and irreversible. (10.3.3) Twenty-six archaeological sites were recorded outside the disturbance allowance zone, but within the heritage resources study area. Indirect impacts to these sites (e.g., artifact collecting) could occur if development of the Landfill results in increased use of these surrounding areas by the public or by landfill staff. Unauthorized collection would be a contravention of the Heritage Conservation Act. (10.3.3) Ashcroft Ranch Landfill Project Public Consultation 18

19 The heritage significance of the identified archaeological sites varies from high to low. No archaeological sites have been identified for which mitigation is not technically feasible. (10.3.3) Impact Prevention and Mitigation Specific mitigation requirements for individual archaeological sites ultimately are determined by the Archaeological Permitting Section of the Ministry of Sustainable Resource Management, and are not available at this time. However, subject to approval by the Archaeological Permitting Section, the following general approaches to mitigation are available: shovel testing, surface collection of artifacts, and detailed site mapping. The actual mitigation measure selected will vary depending on the particular site. Following mitigation, and prior to construction, one or more Site Alteration Permit(s) will be obtained from the Archaeological Permitting Section. The permit(s) will authorize the alteration of archaeological sites that have been appropriately mitigated. (10.3.3) Project measures designed to prevent or mitigate potential impacts to archaeological resources are as follows: an archaeological data recovery program is planned subject to the Archaeological Permitting Section of the Ministry of Sustainable Resource Management. Local First Nations will be invited to participate in the program. The performance-based specification for archaeology resource protection will be: within disturbed areas data recovery to the extent required by the Archaeological Permitting Section of the Ministry of Sustainable Resource Management outside of disturbed areas compliance with the Heritage Conservation Act (11.1.2, 12.) compliance with the archaeological mitigation measures that the Archaeology Permitting Section of the Ministry of Sustainable Resource Management ultimately specifies, ( ) Ashcroft Ranch Landfill Project Public Consultation 19

20 ISSUE 6: Potential groundwater impacts Consultation participants raised concerns regarding the potential impacts of the Project on the quality and quantity of area groundwater (often referred to as the aquifer). Concern was also expressed regarding the extent and adequacy of proposed mitigation measures, in particular, the management of leachate and possible use of synthetic or soil landfill liners. Applicable Regulatory Criteria The comparison of existing conditions and predicted impacts regarding water quality involved the assessment of local tap water with respect to Canadian Drinking Water Guidelines. Irrigation (IW) and livestock (LW) generic numerical water standards of the Contaminated Sites Regulation of the Waste Management Amendment Act ss.35 and 35.1 and Waste Management Amendment Act, 1993, s.15 were used. For parameters that do not have a Canadian Drinking Water Guideline, the drinking water provisions of the Contaminated Site Regulation were used. (1.5.2) Impact Assessment Studies The groundwater impact assessment: characterized the groundwater setting (baseline); described the Project s groundwater protection measures; characterized the effects associated with both an operational scenario and a scenario following landfill closure; and identified and described measures for preventing or mitigating potential impacts of the Project. (2.1) The following were identified and evaluated for potential Project effects: groundwater quantity; groundwater levels; and groundwater quality. (2.2) The groundwater (hydrogeology) study area encompasses an area approximately 10 km long and up to 8 km wide, and is coincident with the Ranch boundaries everywhere except along the eastern edge, where it extends to the Thompson River. The focus of the groundwater assessment was on the Landfill area. The aggregate borrow is not considered to have the potential to affect the groundwater since the excavation of aggregate would be above the regional groundwater table. (2.5, 7.4.5) The groundwater setting was assessed by a review of available information, water well logs available from the Ministry of Water, Land and Air Protection website, carrying out a field investigation and modelling the existing groundwater flow system. (7.4.5) Ashcroft Ranch Landfill Project Public Consultation 20

21 Field investigations included: conducting 10.5 km of geophysical survey: installing 20 groundwater monitoring wells at 10 locations to augment existing wells; assessment of 33 monitoring wells and 14 water wells in and around Ashcroft Ranch; collecting groundwater samples, measuring groundwater level, assessing groundwater flow and quality; assessing shallow soil conditions with four auger holes; and drilling three inclined cored boreholes to assess bedrock conditions. Groundwater Setting Within the study area, there is one main aquifer, the Aquifer, located to the west of the Thompson River and within the valley in which Highway 1 is located. The Aquifer generally consists of sand and has an average saturated thickness of 50 m. It is the source of water for existing groundwater wells on the Ranch, Ashcroft Manor, and Ashcroft IR#4 and IR#2. (2.5, 8.1) Existing Groundwater Levels 5.5 m below existing ground surface in western portion of the Landfill 30 m below existing ground surface in eastern portion of the Landfill 6 m below average elevation at the aggregate borrow south side road 30 m below existing ground surface at monitoring well near Ashcroft Manor. (7.4.5) Existing Groundwater Flow Conditions To assess groundwater flow conditions, a model of the hydrogeology was created and inputs were based on the results of the site investigation. (7.4.5) Groundwater in the higher elevations generally flows east through till and fractured bedrock into the Aquifer at an average velocity on the order of 100 to 200 m/yr. Based on the model, the average flux of groundwater beneath the Landfill is estimated to be on the order of 3,000 m 3 /day. In general, the groundwater gradient in the higher elevations is downward, indicating that recharge to the groundwater occurs. (7.4.5) In the Aquifer, groundwater gradients are upwards in the area of Ashcroft Manor and downwards in the area east and south of the Landfill. The model indicates that the: northward flow in the Aquifer is on the order of 30 to 100 m/yr. southward flow in the Aquifer is on the order of 50 to 200 m/yr. southward groundwater flux in the Aquifer is estimated to be on the order of 7,000 m 3 /day. (7.4.5) Recharge to the Aquifer is estimated to be approximately 84% from inflow from the higher elevations and 16% from precipitation. (7.4.5) Ashcroft Ranch Landfill Project Public Consultation 21

22 The model predicts the Aquifer flows northward from a point north of Well O-1 (located between the main Ashcroft Ranch entrance and the Ashcroft Manor). Between Well O-1 and the ranch entrance, the groundwater flows southward and then eastward toward Cheetsum s Farm IR #1. In the south end of the Ranch, groundwater is interpreted to flow north then east, discharging into the Thompson River at Cheetsum s Farm. (7.4.5) Existing Groundwater Quality The ph of the groundwater is typically near-neutral, ranging from 6.7 to 8.2. The existing groundwater is mineralized, with several exceedances of regulatory criteria. (7.4.5) Assessment of Potential Project Impacts To assess the impact of the Landfill on the groundwater flow regime and groundwater quality (including on active domestic wells), the groundwater model constructed for the baseline assessment was applied to a scenario of an engineered landfill with a single geomembrane liner. The Project will not affect groundwater at Basque Ranch because of the hydrogeological conditions and distance (more than 5 km from the Landfill). There are no off-ranch irrigation wells within the groundwater study area. (10.4.5) The groundwater model predicts the following potential impacts to water level and groundwater quantity (10.4.5): Well Location Water Level Groundwater Quantity (well-yield) Ashcroft Manor m - 0.7% Ashcroft Indian Band m - 0.4% A Project water well located in the area of the aggregate borrow and Cheetsum Creek was predicted to contribute only a minor amount of this decrease. This is considered to be a low magnitude impact. (10.4.5) No significant changes to the groundwater flow directions were predicted. This is considered to be a negligible to low magnitude impact. The continuous source of Cheetsum Creek is a spring. Flows from the spring were predicted to decrease by 1.1% as a result of the Project. (10.4.5) No impacts to groundwater quality at Ashcroft Manor or the Ashcroft Indian Band were predicted because groundwater from beneath the Landfill was not predicted to flow in a northerly direction towards these locations. (10.4.5) The model predicts a low impact to groundwater quality at the Ranch property line at Highway 1 by the Landfill. (10.4.5) Ashcroft Ranch Landfill Project Public Consultation 22

23 Impact Prevention and Mitigation Project measures designed to prevent or mitigate potential impacts to groundwater are as follows: the Landfill is sited in a relatively dry climate with precipitation averaging about 236 mm/yr and high evapotranspiration potential, minimizing leachate generation due to precipitation infiltration (8.5) installation of a permanently placed geomembrane liner and leachate collection system beneath the entire area where refuse will be placed, and installation of a composite liner in sump areas of the leachate collection system ( ) leachate collection will be integral to the Landfill design. The leachate collection system, on top of the liner, will direct leachate to the sumps, pumped and applied to the surface of the Landfill to allow it to evaporate (11.1.1) additional groundwater monitoring wells will be installed downgradient of the landfill, and a groundwater monitoring program will be implemented to provide early warning of changes to groundwater quality and to enable changes to the operations and environmental management plans should they be warranted (11.1.1) an Environmental Management Plan, including monitoring programs, will be included as a component of the Operational Certificate application ( ) quality control/quality assurance monitoring during installation of the liner and leachate collection system ( ). if leachate is detected in monitoring wells downgradient of the Landfill, the following steps would be taken as necessary: resample monitoring wells, install additional monitoring wells to assess the extent of groundwater changes, and carry out a risk assessment of potential impacts of the affected groundwater. If the risks to human health and the environment are determined to be unacceptable, then one of a number of remediation techniques could be implemented, depending on the parameters that require control. (12) Ashcroft Ranch Landfill Project Public Consultation 23

24 ISSUE 7: Potential surface water impacts Consultation participants expressed concern over the potential Project impacts on existing area watercourses. Applicable Regulatory Criteria The comparison of existing conditions and predicted impacts regarding water quality involved the assessment of local tap water with respect to Canadian Drinking Water Guidelines. Irrigation (IW) and livestock (LW) generic numerical water standards of the Contaminated Sites Regulation of the Waste Management Amendment Act ss.35 and 35.1 and Waste Management Amendment Act, 1993, s.15 were used. For parameters that do not have a Canadian Drinking Water Guideline, the drinking water provisions of the Contaminated Site Regulation were used. (1.5.2) Impact Assessment Studies The following were identified and evaluated for potential Project effects: water flows in nearby watercourses (effects on long-term seasonal and average annual flows, peak flows and potential diversion scenarios upstream and downstream of the Project) water quality in nearby surface watercourses (2.2) The surface water study area includes: Lone Tree Creek, Cheetsum Creek and Minaberriet Creek, as well as their associated tributaries all the precipitation catchment area that could reasonably be affected by the Project. (2.5) Surface Water Setting The region has a relatively dry climate with precipitation averaging about 236 mm/yr and high evapotranspiration potential. (8.5) Precipitation tends to increase with increasing elevation, with approximately one third of the annual precipitation falling as snow. There tends to be two relatively wet periods, December to January and June to September. The most significant precipitation results from short duration storm events that occur during the summer months. (7.4.6) The baseline assessment included a review of provincial map sheets, aerial photographs, Environment Canada climate and hydrometric data, Land and Water BC water licensing information and a site reconnaissance in July A model of daily peak flows was carried out using software from Environment Canada and historical stream flow data from seven nearby regional gauging stations. (7.4.6) Water rights mapping shows five named watercourses within the surface water study area: Lone Tree Creek, 102 Gulch Creek, Kloochville Creek, Minaberriet Creek and Cheetsum Creek. Of these, Lone Tree Creek has the most flow, although this flow is seasonal. The source of the constant flow in Cheetsum Creek is a spring, which drains into a cattle watering hole. The other three named watercourses are ephemeral (active only over a very short period of time). (7.4.6) Ashcroft Ranch Landfill Project Public Consultation 24

25 There are four water licenses held by the Greater Vancouver Sewerage and Drainage District, for withdrawal from Lone Tree Creek and one water license held by the Ashcroft Indian Band for withdrawal from Cheetsum Creek. (7.4.6) Water is currently diverted from Lone Tree Creek via the diversion to the reservoir, and subsequently piped to the Ranch irrigation system. The diversion is a water work used for Ranch operations that was constructed prior to (7.4.6) Assessment of Potential Project Impacts The watersheds that will receive surface water runoff from the Project area are Lone Tree Creek, Minaberriet Creek, Cheetsum Creek, Kloochville Creek and 102 Gulch Creek. These are small watersheds that form a larger overall watershed. Surface water quality is not an issue because of the groundwater protection measures in the Project description, the prediction that surface water near the Landfill will infiltrate into the ground before it can reach the nearest fish-bearing water body (Thompson River), and the lack of fish or fish habitat in the water courses adjacent to the Landfill. (10.4.6) The interception of runoff from upslope of the Landfill and routing of this intercepted water to Lone Tree Creek will increase the catchment area of Lone Tree Creek above the start of the diversion. The re-routing of water from upslope of the Landfill to the Lone Tree Creek system is expected to have negligible impact on the operation of the diversion and the reservoir. The Project is expected to have no impact on other existing or potential diversion works in the Lone Tree Creek system other than to the diversion. (10.4.6) Water management within operating cells of the Landfill and leachate management during operations and post-closure will be controlled. Water that has contacted the active area of the Landfill (where waste is unloaded and compacted) will be contained within the Landfill and there will be no discharge of leachate to surface watercourses. Water that has not contacted the active area will be diverted to the drainage systems around the landfill. (10.4.6) Impact Prevention and Mitigation Project measures designed to prevent or mitigate potential surface water impacts are as follows: the Landfill is located in a relatively dry climate with precipitation averaging about 236 mm/yr and high evapotranspiration potential (8.5) surface water will be diverted around the upstream (west) side of the Landfill by an interception ditch. The interception ditch will be designed to limit channel erosion and therefore a separate sediment control structure is not anticipated. Temporary ditches will be used, if required, to divert surface water away from the active Landfill area. Surface water from the south side of the Landfill would drain into an existing drainage channel. Due to the topography, no major surface water diversion works are required on the north and east sides of the Landfill (8.10) no surface water diversion works are considered to be necessary for the aggregate borrow, since any surface water that enters the aggregate borrow would infiltrate through the granular soils to the groundwater (8.10) Ashcroft Ranch Landfill Project Public Consultation 25