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FORT NELSON ELECTRICAL

GENERATION PROJECT

BRITISH COLUMBIA HYDRO AND POWER

AUTHORITY

AND

TRANSALTA ENERGY CORPORATION

FORT NELSON ELECTRICAL

GENERATION PROJECT

Report and Recommendations of the

Fort Nelson Electrical Generation Project Committee

With respect to a Decision on a

Project Approval Certificate

Application

Submitted to:

Executive Director

Environmental Assessment Office

Prepared by:

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September, 1998

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 PURPOSE OF THIS DOCUMENT

2.0 PROJECT DESCRIPTION

3.0 PROJECT JUSTIFICATION AND ALTERNATIVES

3.1 Project Justification 3.2 Project Alternatives

4.0 REVIEW PROCESS

4.1 British Columbia Environmental Assessment Process 4.2 Canadian Environmental Assessment Process

5.0 INFORMATION DISTRIBUTION AND DISSEMINATION

5.1 Public Consultation Measures

5.1.1 Pre-Application

5.1.2 Application Review Stage

5.2 First Nations Consultation Measures

5.2.1 Pre-Application

5.2.2 Application Review Stage

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6.0 CONSIDERATION OF POTENTIAL EFFECTS AND MITIGATION

PLANS

6.1 Project Justification Issues

6.2 Project Design and Construction Issues

6.2.1 Construction Schedule 6.2.2 Land Ownership and Status

6.2.3 Road Access and Oversized Vehicles

6.3 Environmental Effects

6.3.1 Air Quality

6.3.3.1 Nitrogen Dioxide and Carbon Monoxide Emissions 6.3.1.2 Fogging/Icing Effects

6.3.1.3 Greenhouse Gas (GHG) Emissions and Management 6.3.1.4 Construction Impacts on Air Quality

6.3.2 Water Supply

6.3.3 Waste Management 6.3.3.1 Wastewater 6.3.3.2 Solid Wastes 6.3.3.3 Special Wastes

6.3.4 Effects on Terrestrial Ecology and Wildlife 6.3.5 Effects on Aquatic Life

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6.3.7 Environmental Monitoring During Construction 6.4 Socio-Economic Issues 6.4.1 Community Impacts 6.4.2 Employment Impacts 6.4.3 Revenue Impacts 6.4.4 Traffic Impacts

6.5 Cultural and Heritage Issues

6.5.1 Traditional Use Impacts 6.5.2 Archaeological Impacts

6.6 Health Issues

7.0 PROJECT COMMITTEE RECOMMENDATIONS AND REASONS

7.1 Recommendations 7.2 Reasons

APPENDIX A

SCHEDULE A - DOCUMENTATION AND CORRESPONDENCE FOR

THE FORT NELSON ELECTRICAL GENERATION PROJECT

EXECUTIVE SUMMARY

The Fort Nelson Energy Generation Project (FNEGP), proposed by the British Columbia Hydro and Power Authority (BC Hydro) and TransAlta Energy Corporation (TransAlta), involves the design,

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construction, operation, dismantling and abandonment of a 45 MW combustion turbine powerplant approximately 20 kilometres south of Fort Nelson adjacent to Westcoast Energy Inc.’s Fort Nelson Gas Plant.

The FNEGP would provide base load power to the Town of Fort Nelson and replace the interruptable electricity supply currently received from Rainbow Lake, Alberta. Once the FNEGP is operational, BC Hydro’s existing standby diesel powerplant in Fort Nelson would be decommissioned. Surplus power from FNEGP is expected to be sold to the Alberta Power Pool.

On August 10, 1998, BC Hydro and TransAlta’s Application for a Project Approval Certificate for the FNEGP was accepted for review under the Environmental Assessment Act (Act).

The Environmental Assessment Office (EAO) subsequently established the Fort Nelson Electrical Generation Project Committee to steer the review of the proposal. The Project Committee included representatives from provincial government agencies, the Town of Fort Nelson, the Fort Nelson-Liard Regional District, the Fort Nelson Indian Band and the Prophet River Indian Band. Federal government agencies also participated in the review.

Three Project Committee meetings were held during August and September 1998 to review the application, public and agency comments on the Application, and the responses from BC Hydro and TransAlta to these comments. All issues raised were tracked by the Project Committee using an Issue Tracking Matrix. The Project Committee also reviewed the First Nations and public consultation plans to ensure that distribution and notification measures were adequate.

The key issues raised during the review were the FNEGP’s potential impacts on air quality, water supply and waste management. Regarding these issues, the Project Committee concluded, on the

recommendation of Ministry of Environment, Lands and Parks staff, that:

● the project would not have a significant adverse effect on ambient air quality in the Fort Nelson

area;

● the project would not significantly increase the frequency and duration of fog or icing in the

vicinity of the project;

● the project would likely provide greenhouse gas offsets, assuming that it replaces electricity from

the Alberta Power Pool which is primarily derived from coal-fired thermal sources;

● the sourcing of water for the project from the Fort Nelson River is unlikely to cause a significant

adverse effect on fish and fish habitat;

● wastewater discharges from the project can be accommodated by WEI’s wastewater treatment

system; and

● the proposed disposal of solid wastes and handling of special wastes is acceptable.

The Project Committee also concluded that the potential effects on wildlife or wildlife habitat,

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provide modest but positive impacts to the local economy, and offers potential for significant public health benefits, as it would provide a more secure and reliable source of power for the Fort Nelson area. Based on its review of the Application, including all supplementary reports and correspondence on the Application, and in accordance with section 19 of the Act, the Project Committee recommends that the Application be referred to the Ministers of Environment, Lands and Parks and Employment and

Investment for a decision under section 20 of the Act.

The Project Committee recommends that a Project Approval Certificate be issued, subject to the following conditions:

● BC Hydro and TransAlta must design, construct, operate, dismantle and abandon the project and

fulfil all commitments and proposed mitigation measures as documented in the Application (including supplementary documents and correspondence) and discussed in this report;

● BC Hydro and TransAlta must notify the Executive Director of the EAO if, prior to operations, it

wishes to change the design, location, construction or operation of the Project (as described in the documents listed in Appendix A) in a manner that may potentially cause significant adverse effects, and where the Executive Director considers that the proposed change will cause significant adverse effects, the Executive Director will identify a process and timeline for the review of the proposed change before a recommendation is made to Ministers concerning the change; and

● BC Hydro and TransAlta must comply with all applicable orders, directions and conditions, and

obtain and comply with all applicable tenures, licences, regulations, approvals, standards and permits, or other authorities.

The Project Committee notes that these recommendations may not reflect the views of the Fort Nelson Indian Band as they did not sign off on the report and recommendations of the Project Committee. The Project Committee’s reasons for its recommendations are that:

● pursuant to section 19(2)(a) of the Act, specified measures relating to the distribution of

information about the Fort Nelson Electrical Generation Project have been carried out by the proponent;

pursuant to section 19(2)(b) of the Act, the Application (including supplementary information and

correspondence as listed in Appendix A of this report) identifies and adequately describes the potential effects of the Fort Nelson Electrical Generation Project, including all significant adverse potential effects; and

● pursuant to section 19(2)(c), of the Act, the Application (including supplementary information

and correspondence as listed in Appendix A of this report) sets out practical means of preventing or reducing to an acceptable level all significant adverse effects of the Fort Nelson Electrical Generation Project.

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1.0 PURPOSE OF THIS DOCUMENT

On August 10, 1998, the Environmental Assessment Office (EAO) accepted for review an Application (the “Application”) for a Project Approval Certificate for the Fort Nelson Electrical Generation Project (FNEGP), submitted by British Columbia Hydro and Power Authority (BC Hydro) and TransAlta Energy Corporation (TransAlta), hereafter referred to as the proponent.

The review of the Application was conducted by a Project Committee established in August 1998 in accordance with section 9 of the Environmental Assessment Act (Act). The Project Committee, consisting of federal, provincial and local government agencies and First Nations, reviewed the proponent’s

documentation and comments in the Application, and is satisfied that adequate measures will be taken to address all potentially significant adverse impacts.

The purpose of this document is to:

● provide a brief overview of the project;

● describe the review process, including measures for consultation with the public and First

Nations;

● describe potential effects of the project and proposed mitigation measures; and

● document the Fort Nelson Electrical Generation Project Committee’s recommendations to the

Executive Director of the EAO relevant to a decision under section 20, and the reasons for the recommendations.

2.0 PROJECT DESCRIPTION

The FNEGP involves the design, construction, operation, dismantling and abandonment of a 45 MW combustion turbine powerplant to be located approximately 20 kilometres south of Fort Nelson adjacent to Westcoast Energy Inc.’s Fort Nelson Gas Plant (FNGP). The FNEGP would provide base load power to the Town of Fort Nelson and replace the interruptable electricity supply currently received from

Rainbow Lake, Alberta. Once the FNEGP is operational, BC Hydro’s existing standby diesel powerplant in Fort Nelson would be decommissioned. Surplus power from FNEGP is expected to be sold by the proponents to the Alberta Power Pool.

For the purpose of the Environmental Assessment review, the FNEGP comprises:

● on-site facilities including a General Electric LM-6000 combustion turbine, heat recovery steam

generator, water treatment plant, control room, plant building, substation containing two 25/144 kV transformers, natural gas supply, transmission line tap, parking lot and access road;

● off-site facilities including approximately 800 metres of transmission line to tap into the existing

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Power Inc. and CU Power International Limited), and the extension of pipelines to the adjacent Westcoast Energy Inc. (WEI) gas plant for water and gas supply and to return plant wastewater; and

● road access either directly from the Alaska Highway or by existing public and Westcoast Energy

Inc. roads.

The plant site is approximately two hectares in size and will be purchased from WEI. WEI is also prepared to provide easements to the proponent for gas supply and power transmission lines over its property, and to provide raw water supply and wastewater treatment. WEI has advised the Project Committee that the water supply and treatment requirements can be met within the limits of WEI’s existing water licences and discharge permits for its Fort Nelson Gas Plant.

3.0 PROJECT JUSTIFICATION AND

ALTERNATIVES

3.1 Project Justification

BC Hydro has supplied electricity to Fort Nelson and its surrounding areas since 1960, although the community is not connected directly to the main BC Hydro transmission grid. Since 1991, the primary energy supply for Fort Nelson has come from Alberta via the WESCUP 144 kV transmission line,

pursuant to an Electricity Purchase Agreement with WESCUP. Supply of electricity under the WESCUP agreement has become unreliable in recent years. In 1997, supply to Fort Nelson was interrupted 70 times for a total of 570 hours. According to BC Hydro, the main reason for these interruptions are

weaknesses in the transmission system in northwestern Alberta and energy market pressures originating in the new Alberta Power Pool.

During these supply interruptions, power is supplied to Fort Nelson by BC Hydro’s standby diesel units. BC Hydro’s diesel generators have performed well in mitigating the impacts of outages. However, due to their age and the difficulty of obtaining spare parts, these generating units are now at the end of their operating life.

Recent Hydro planning studies and an analysis of Alberta power supplies in northwestern Alberta estimate that annual load curtailments will continue to occur. Brownouts and/or blackouts are likely to occur this winter in Fort Nelson unless additional generation is brought online. Both industrial customers and the Town of Fort Nelson have expressed concerns regarding the reliability and expense associated with these outages. In addition, municipal officials have expressed concern that the existing supply problem has retarded industrial development in the area.

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BC Hydro has considered several alternatives to the FNEGP to address the problem of supply interruptions to Fort Nelson.

In 1997, WESCUP and Alberta Power agreed to implement market-priced supply (Pool Opportunity Rate) from the Alberta Power Pool as a temporary measure to reduce the frequency of supply

interruptions in Fort Nelson. This allowed BC Hydro to purchase power for Fort Nelson as long as generation was available, however the cost of power from the Alberta Power Pool has frequently been very high and volatile. Furthermore, the Pool Opportunity Rate tariff has not mitigated the impact of northwestern Alberta transmission system problems. Alberta Power has reserved the right to interrupt supply to Fort Nelson for system security reasons. System wide brownouts have occurred three times so far in Alberta in 1998, and with the continued load growth, brownouts are expected in the winter of 1998/99 in various parts of the Alberta system. While the Pool Opportunity Rate has provided short-term relief to supply interruptions at Fort Nelson, BC Hydro (and the community of Fort Nelson) believe a longer-term solution is required.

In 1997, BC Hydro evaluated a proposal from WESCUP for the purchase of power from a proposed 40 MW co-generation plant to be located adjacent to WEI’s Fort Nelson Gas Plant. Negotiations were not successful, and WESCUP has not proceeded further with its proposal.

Another option considered was the extension of BC Hydro’s transmission line from the Peace River region to Fort Nelson, however the cost to build and operate such a transmission line was found to be uneconomical.

Given the lack of viable alternatives, BC Hydro determined in early 1998 that it would need to be at least part owner and operator of any new generation source in Fort Nelson. BC Hydro received proposals from four developers, and eventually chose TransAlta as a joint venture partner for the FNEGP. TransAlta Energy Corporation is a wholly owned subsidiary of TransAlta Utilities Corporation, which is the largest investor-owned utility in Canada, providing electricity to about 1.7 million Albertans across its 212,000 square kilometre service area.

On May 22, 1998, BC Hydro signed a memorandum of understanding with TransAlta to develop the FNEGP on a joint basis reflecting equal participation. BC Hydro will purchase all of the power from the FNEGP and will market excess power into the Alberta Power Pool. The FNEGP will be backed up by the Alberta integrated system.

Two sites were evaluated for the FNEGP, one adjacent to WESCUP’s existing substation south of Fort Nelson and the other near WEI’s Fort Nelson Gas Plant. The site near WESCUP’s substation was

subsequently dropped due in part to concerns from local residents but also because the other site offered better opportunities for sourcing water and gas, and for wastewater treatment

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4.0 REVIEW PROCESS

4.1 British Columbia Environmental Assessment

Process

British Columbia’s environmental assessment process provides for participation by the public, project proponents, First Nations, municipalities, regional districts, provincial and federal agencies, and where appropriate, neighbouring jurisdictions, in the assessment of reviewable projects. Reviews are

administered by the EAO and steered by Project Committees comprised of representatives from federal, provincial and local government agencies and affected First Nations.

Project Committee members are the primary contributors to policy and technical expertise to the review of each project and are expected to:

● assess the potential economic, environmental, social, cultural, heritage and health effects of

projects and the potential to prevent or mitigate adverse effects of projects;

● assess the adequacy of the proponent’s public and First Nations consultation;

● analyze input received from the public, government agencies, and First Nations in response to

invitations to comment at various stages of a project’s review;

● analyze the advice and recommendations of public advisory committees, where established for

project reviews; and

● provide analysis, advice and recommendations to the Executive Director of the EAO, the Minister

of Environment, Lands and Parks, and the Responsible Minister in respect of projects under review.

Working with the EAO, Project Committees have overall responsibility for ensuring that project reviews:

● are comprehensive and technically sound; ● involve all potentially interested parties; and

● are conducted in a timely and efficient manner, and in accordance with the legislated time limits

established for individual reviews under the Environmental Assessment Prescribed Time Limits

Regulation.

Following receipt of the Application for a Project Approval Certificate from BC Hydro and TransAlta Energy on August 10, 1998, the EAO established the Fort Nelson Electrical Generation Project

Committee (the “Project Committee”) to steer the review of the proposal. The Project Committee was chaired by the Environmental Assessment Office and included representatives from the following:

● Ministry of Employment and Investment ● Ministry of Environment, Lands and Parks

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● Ministry of Health ● Town of Fort Nelson

● Fort Nelson-Liard Regional District ● Fort Nelson Indian Band

● Prophet River Indian Band

The Fort Nelson Indian Band, although a full member of the Project Committee, did not participate in the Project Committee meetings and has not signed off on the contents of this Report. For this reason,

statements attributed to the Project Committee throughout the remainder of this report may not represent the views of the Fort Nelson Indian Band.

Several agencies chose not to sit as formal members of the Project Committee, but to participate instead as “reviewing agencies”. Reviewing agencies were not required to approve or sign-off on the Project Committee’s recommendations, but were given the opportunity to comment on project material as the review proceeded. They were also provided with copies of minutes of meetings and general Project Committee correspondence. Reviewing agencies included:

● Ministry of Energy and Mines

● Ministry of Transportation and Highways ● BC Utilities Commission

● Northern Development Commission ● Environment Canada

● Department of Fisheries and Oceans ● Treaty 8 Tribal Association

Three Project Committee meetings were held during the course of the review. The first two meetings were held in Fort Nelson with teleconference capabilities for regional and Victoria staff to participate. The first meeting was held on August 26, 1998 to outline the review process, to evaluate the proponent’s public notification and consultation program, and to provide an opportunity for the Project Committee to hear a brief presentation on the project and to ask questions of the proponent. The Project Committee also approved its operating procedures and agreed to an expedited review schedule.

The second meeting of the Project Committee was held on September 9, 1998 to review agency comments on the Application, develop an issue tracking document and determine which of the issues raised by agencies required a response from the proponent before a decision could be made on their Application.

The third meeting of the Project Committee was held in Victoria by teleconference on September 22, 1998, at which time the Project Committee reviewed public comments on the project, reviewed the proponent’s responses to public and agency comments and developed its recommendations on the Application for a Project Approval Certificate.

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All documents related to the review of the Application, including minutes of all Project Committee meetings, are filed on the EAO Project Registry and the EAO’s website.

Agency comments on the Application were distributed to the proponent and the Project Committee on September 4, 1998 for their review and consideration. Public comments were similarly distributed at the close of the public comment period, which was September 17, 1998.

The proponent’s responses to agency and public comments were received on September 15, 1998 and September 21, 1998, respectively.

1. Canadian Environmental Assessment Process

Early in the review process, the project Application was referred to the Canadian Environmental

Assessment Agency. The project Application was distributed to all interested federal departments and it was determined that the project would not trigger a review under the Canadian Environmental

Assessment Act (CEAA). The Department of Fisheries and Oceans and Environment Canada actively

participated in the EAO review process in order to harmonize their review of the project under their individual federal mandates with the provincial process.

5.0 INFORMATION DISTRIBUTION AND

DISSEMINATION

5.1 Public Consultation Measures

5.1.1 Pre-Application

The Proponents took steps to provide advance notification of the project to a few key stakeholders prior to a general public release of the project announcement on June 16, 1998. This was consistent with past activities to update local elected officials at regular intervals while options for power supply to the

community were being considered, and while negotiations between BC Hydro and potential joint venture partners were underway. Stakeholders included representatives from the following interest groups:

● Local government representatives

● Business organisations and business leaders

● Wildlife Association, Guide-Outfitters, Trappers Associations ● Agricultural Groups

● Environmental Association and environmental advocates ● Property owners and interested individuals

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Meetings were held with the Mayor of the Town of Fort Nelson, who is also the Chair of the Fort Nelson Liard Regional District, the Town Council/Regional District Board and with representatives of the

Slocan Group, Fort Nelson Indian Band and Prophet River Indian Band. In addition, the local MLA, Richard Neufeld was briefed by telephone.

Notification activities were formally initiated with the project announcement on June 16, 1998 in Fort Nelson. A total of 141 community representatives attended a luncheon in Fort Nelson to formerly launch the project. The initial reaction of those attending was reported by BC Hydro to be very positive and supportive of the project. A Question and Answer session was also held where issues such as the licensing process, rate impacts, siting options and contracting arrangements were discussed.

A news release was issued and a three page Project Information Bulletin was provided to each person attending the luncheon. The Project Information Bulletin contained a project overview, reasons for the project, description of the project, local benefits, consultation program, environmental considerations, project schedule, and a map of the two sites under consideration. At the end of the bulletin, the names, phone, fax and e-mail contact information was provided for key project representatives in case

stakeholders wanted to discuss the project directly with them. Following the announcement, copies of the Project Information Bulletin were made available at the municipal office and the local office of BC

Hydro. The project announcement was reported in the Fort Nelson News, the Financial Post and the Vancouver Sun.

Support for this project also materialized in the form of letters from town officials and representatives of major industries.

A community open house was held in Fort Nelson on July 9, 1998 at the Woodlands Inn. A total of 32 people attended the open house. The overall impression of BC Hydro and TransAlta staff at the open house was that the project is well supported in the community, particularly if the project were to be sited adjacent to WEI’s Fort Nelson Gas Plant.

5.1.2 Application Review Stage

Proponent Generated Activities

Following submission of the Application on August 10, 1998, BC Hydro placed notices in the Fort

Nelson News on August 12, 1998 and August 26, 1998 notifying the public of the opportunity to provide comments on the Application until September 17, 1998. Throughout the public comment period, BC Hydro’s local office in Fort Nelson was available to receive and respond to inquiries about the project. As well, Community Relations staff for BC Hydro have kept local media representatives informed about the project.

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The EAO established a 30-day public comment period on the FNEGP Application, running from August 18, 1998 to September 17, 1998. Copies of the Application and supporting documents were made

available to the public at the Project Registry of the EAO in Victoria, and at the public library in Fort Nelson. The Application was also available through the EAO website.

During the public comment period, one letter was received regarding the Application. This letter came from the Fort Nelson and District Chamber of Commerce, and was strongly supportive of the project and an early construction start. The letter was forwarded to the proponent and the Project Committee for their consideration.

5.2 First Nations Consultation Measures

The First Nations consultation program was developed separately, but in conjunction with the

consultation program for the broader community of Fort Nelson. Much of the same information as was provided to the public (i.e. information sheets, open house, display materials, etc.) was provided to First Nations during the consultation process. Independent meetings were also held and materials developed to meet the individual needs of First Nation communities.

The objectives of the First Nations consultation program were to:

● identify all First Nations communities with an interest - territorial or otherwise – in the project

and who wish to be consulted,

● notify identified First Nations of the project and provide all pertinent information as early in the

process as possible;

● inform First Nations communities of the project approval process and the obligation of the

proponent to conduct meaningful consultation under the Environmental Assessment Act;

● establish a consultation process in concert with First Nations that meets the needs of each

community by responding to differences in those communities;

● provide an effective forum for two-way communication to scope issues, identify concerns and

respond to those concerns;

● commission studies which clarify issues and meet the needs of First Nations, the proponent and

the regulatory process;

● determine if the project will infringe on First Nation rights; and

● identify ways of maximizing local benefits to First Nations communities.

5.2.1 Pre-Application

The First Nations potentially impacted by the proposed project are the Fort Nelson Indian Band and the Prophet River Indian Band. Chapter 7 of the Application contains a detailed record of pre-Application consultations with both Bands.

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During BC Hydro’s pre-Application consultation activities with the Prophet River Indian Band, no

concerns about or objections to the project were indicated. The Band noted that the proposed site had low or no historical potential, and that it fully supported the development of this project as it would provide them with a more reliable source of power.

BC Hydro held two meetings with representatives of the Fort Nelson Indian Band before submitting its Application. On June 9, 1998, the Band representatives reviewed the proposed sites to determine if there were any aboriginal trapping interests that might be infringed by the project. BC Hydro advises that the Band subsequently determined that there were no First Nations trapping interests related to the proposed project. On July 14, 1998, a second meeting was held with the Fort Nelson Indian Band at which time the archaeology overview and preliminary air emission findings were shared with the Band representative. BC Hydro reports that the Band advised that it had no concerns regarding effects of the project on traditional uses, trapping or wildlife. Further information on air emissions was provided to the Band in late July.

Both Bands expressed interest in the economic opportunities associated with the project’s construction. The proponent is committed to the continuation of the consultation process in order to bring about a satisfactory result for the impacted First Nations.

5.2.2 Application Review Stage

Proponent Consultation Activities

The proponent submitted a summary report of its First Nations consultation results on September 21, 1998. The report noted that copies of the Application were released to both the Fort Nelson Indian Band and the Prophet River Indian Band in early August 1998. During August and September 1998, the

proponent focussed its consultation activities on the Fort Nelson Indian Band as the Prophet River Indian Band had already expressed support for the project. Several attempts were made to meet with the Fort Nelson Indian Band to discuss any concerns, however, the Band indicated that the project was not one of their priorities. The proponent indicates that they continue to be available to meet with the Band Chief and Council.

EAO Consultation Activities

On August 10, 1998, the EAO wrote to both the Fort Nelson Indian Band and the Prophet River Indian Band inviting them to become formal members of the Project Committee and notifying them of the opportunity to provide comments on the project. Both Bands were requested to identify issues with respect to the project’s potential impacts on the exercise of aboriginal and treaty rights and traditional and current activities. The Prophet River Indian Band advised the Project Committee that it had no concerns with respect to traditional use impacts. The Fort Nelson Indian Band did not provide written or verbal comments on the project, despite several requests from the EAO.

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Both Bands accepted the invitation to sit on the Project Committee, however the Fort Nelson Indian Band did not attend any of the Project Committee meetings. The Prophet River Indian Band attended the first two Project Committee meetings, including the site tour on August 26, 1998.

5.3 Adequacy of Public and First Nations

Notification and Consultation Plans

In accordance with section 14 of the Act, the Project Committee evaluated the adequacy of the proponent’s notification and consultation plans. At its meeting on August 26, 1998, the Project Committee concluded that the public and First Nations consultation measures that BC Hydro had undertaken and proposed to undertake during the public comment period were adequate. No additional consultation measures were considered necessary, other than a final report from the proponent

summarizing the results of its consultation activities through to the end of the public comment period. The proponent was informed of the Project Committee’s conclusion on September 1, 1998.

On September 21, 1998, the proponent reported on the measures taken to provide information about the project and to consult with the public and First Nations. The Project Committee reviewed these reports at its meeting on September 22, 1998, and found them to be acceptable.

The Project Committee is satisfied that that the requirements of section 14 of the Act have been adequately addressed.

6.0 CONSIDERATION OF POTENTIAL

EFFECTS AND MITIGATION PLANS

For the purposes of assessing the effects of the FNEGP, relevant documentation and correspondence received from the proponent after the submission of the Application are also considered to form part of the Application. In particular, the proponent’s Responses to the Project Committee’s Issue Tracking Matrix, dated September 15, 1998, provided clarification on a number of potential effects related to the FNEGP. A full listing of the documentation that is considered part of the project Application is found in Appendix A.

The focus of the FNEGP review has been on the identification and prevention of potential adverse

effects, as a key objective of the review process is to prevent, or reduce to an acceptable level, all adverse effects caused by the project. The project’s positive effects have received less attention during the

review, as positive effects do not require mitigation or compensation measures. The Project Committee notes that the project will produce economic and employment benefits to local residents, and resolve local concerns regarding a reliable power source. These positive effects, while important, do not offset or

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cancel the need to prevent or reduce to an acceptable level, the potential adverse effects of the project. The following sections summarize the project’s potential effects, identify the proponent’s proposed mitigation measures, and indicate the Project Committee’s conclusion on whether the proposed measures are acceptable. These conclusions reflect the views of all Project Committee members, except possibly the Fort Nelson Indian Band. The position of the Fort Nelson Indian Band on these issues is not known.

6.1 Project Justification Issues

The Guide to the British Columbia Environmental Assessment Process states that independent power producers must be able to show proof of a market before certification. Electricity markets are under transformation to remove barriers to entry for new non-utility generation through open access to

transmission systems and are now characterised by a mixture of long and medium term contracts as well as spot sales. As such, an energy purchase agreement with a utility is no longer required as evidence of a market for the purposes of the environmental assessment process. Proponents, however, are expected to be able to demonstrate potential markets and the means of accessing them to confirm the rationale for their project.

The proponent’s project justification for the FNEGP is summarized in Chapter 3. The main issue related to the justification of this project was the proposed size of the powerplant. The proponent is proposing the construction and operation of a 45 MW turbine, whereas the most recent load forecast for the Fort Nelson area predicts that the peak demand for power in Fort Nelson in 20 years will be approximately 34 MW. This load forecast, however, does not include potential new load resulting from the completion of the Alliance pipeline, the BC Government’s plan to double petroleum and natural gas production in

northeastern BC, or from new industries possibly attracted to Fort Nelson because of the improved power supply. The most recent load forecast predicts a peak demand in Fort Nelson of 22.1 MW for the winter of 1998/99.

Although BC Hydro’s official load forecasts only cover 20 years, BC Hydro advises that the peak

demand for power in Fort Nelson will not likely reach 45 MW until 2028/29. BC Hydro notes, however, that the difference in capital cost of a 45 MW gas turbine such as the LM6000 and a 34 MW turbine that would be capable of meeting the 20 year load forecast, is insignificant. It acknowledges that operating costs would be higher, however it expects to maximize revenues by efficiently managing the sale of surplus power into the Alberta Power Pool when the prices are high.

The Project Committee has reviewed the justification for the proposed 45 MW project, and based on the advice of the BC Utilities Commission and the Ministry of Employment and Investment, is satisfied that the project justification requirements of the environmental assessment process have been adequately met for the FNEGP.

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6.2.1 Construction Schedule

In its Application for a Project Approval Certificate, the proponent noted that site preparation for the FNEGP had been scheduled to commence in mid-July 1998 with completion of construction by November 1998. Project commissioning was expected to take place in mid-November 1998. The proponent acknowledged that these dates were no longer applicable, and that a revised construction schedule would be provided as soon as it had a better understanding of a likely approval date. BC Hydro was subsequently advised that the Project Committee was undertaking an expedited review of the

Application, and expected to submit its recommendations to the EAO on September 25, 1998 for referral to the Ministers of Environment, Lands and Parks and Employment and Investment on the same day. On September 15, 1998, the proponent provided an updated construction schedule for the FNEGP (see Appendix A of the September 15, 1998 Response to Issue Tracking Matrix). The revised construction schedule envisages a construction start date of October 1, 1998, with commercial operation likely by early February 1999.

Project Committee representatives from the Town of Fort Nelson, the Fort Nelson-Liard Regional District and the Prophet River Indian Band noted that February is often the coldest month in the winter, and that it was critical that construction proceed as quickly as possible to meet the February 1999 in-service date.

The updated construction schedule was accepted by the Project Committee.

6.2.2 Land Ownership and Status

The proposed site is on industrial land currently owned by WEI and will be subdivided and sold to the FNEGP joint venture. The land parcel will contain the plant site, road access, substation and all ancillary facilities with the exception of a short length of the transmission line tap. The right-of-way for the

transmission line tap will be on private land owned by WEI. The property is currently zone RU1 (Rural and small holding) industrial and is outside of the Agricultural Land Reserve and the Forest Land Reserve. There will be no Crown land purchased for this proposed project.

The proponent was requested to clarify the status of its negotiations with WEI for the purchase of the site. WEI has subsequently confirmed that it is willing to sell the land directly adjacent to its Fort Nelson Gas Plant to BC Hydro and TransAlta for the construction of the powerplant. WEI also has advised that it is prepared to provide easements for gas supply and power transmission lines across its property. The Project Committee does not require further information in order to complete its review, but notes that ownership of the land may be required before permitting can be completed.

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The proposed project can utilize an existing access road from the Alaska Highway, however the

proponent proposes to request permitting for direct access to the site. Based upon the information in the Application, access length is minimal and no adverse effects are expected from a more direct access road to the site. The Project Committee has no concerns with the proposed access road.

The Ministry of Transportation and Highways notes that the proponent will require permits for the direct access to and from the Alaska Highway, and for overweight and oversize loads.

The project’s effects on traffic are discussed in Section 6.4.4 of this report.

6.3 Environmental Effects

The Application reports on the project’s potential to affect air quality, noise, hydrology and surface water quality, vegetation, wildlife and wildlife habitat, aquatic resources, terrain and soils, and proposes

possible mitigation measures to prevent or reduce to an acceptable level, any significant adverse effects. The proponent’s impact assessments of environmental effects were reviewed and commented on by the Ministry of Environment, Lands and Parks and Environment Canada, in accordance with their respective mandates. Both agencies conducted their review of the Application to determine if, on a conceptual level, the project could be constructed, operated and maintained using standard practices and readily available technology required to mitigate and/or reduce environmental impacts to an acceptable level. The

Department of Fisheries and Oceans has a legal obligation to protect fish and fish habitat under the

Fisheries Act for any project that could alter, disrupt or destroy fish habitat, and therefore reviewed the

project’s potential effects on fish and fish habitat.

6.3.1 Air Quality

6.3.3.1 Nitrogen Dioxide and Carbon Monoxide Emissions

The Application assesses the ambient air quality, other emission sources and provides an assessment of the climate and meteorological conditions in the Fort Nelson area. The ISC/3 model has been used to estimate the effect of emission of pollutants from the gas-fired turbine on ambient concentrations of pollutants in the area.

The proposed generation plant would use steam injection technology which will have a NOx emission of 25 ppmv. The emission control system will be designed to meet the Emission Criteria for Gas Turbines (MELP, 1992) guidelines. Air quality modelling indicates that the project could add 14 ug/m3 NOx to ambient ground level concentrations of NOx and 20 ug/m3 of CO to ambient ground level concentrations of CO. The model results indicate that emissions from the proposed turbine will not cause ambient levels of NOx or CO to exceed the most stringent ambient air quality objectives for BC and Canada.

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In the event of a failure, which is expected to occur about once every 6 months, NOx emissions are expected to rise to 250 ppmv over the period of the failure. These excursions are not expected to last longer than 24 hours for each event. Supplementary information submitted by BC Hydro on September 15, 1998 indicated that exit temperatures, exit velocities, NOx emission rates and maximum 1-hour concentration levels all increased during failure events, but that the 1-hour NOx concentration without steam injection was still well below the 1-hour objective of 400 ug/m3.

The Project Committee, on the recommendation of MELP, concludes that NOx and CO emissions from the FNEGP, as proposed, will not have a significant adverse effect on ambient air quality in the Fort Nelson area.

6.3.1.2 Fogging/Icing Effects

The proponent states in its Application that water vapour emissions from the stack could be a concern if they reduce visibility along the adjacent highway by causing fog to form. The water vapour emission rate from the stack is 5,736 g/s.

In order to assess the potential of the stack plume to form fog, the water emissions from the proposed powerplant were modelled with ISC/3. The modelled results were then compared with the moisture deficit, which is defined as the quantity of water required, in addition to the ambient atmospheric water content, to bring the atmosphere to saturation. The results showed that for relative humidities less than 100% and for non-calm conditions, the maximum predicted liquid water content from the powerplant does not equal or exceed the moisture deficit. Hence the plume from the powerplant would not contribute to the formation of fog.

The combined emissions of water vapour from both WEI’s Fort Nelson Gas Plant and the proposed powerplant, when modelled as total emissions from the proposed powerplant, also predicted maximum hourly water vapour concentrations less than the moisture deficit, and therefore the two industrial sources are not expected to contribute to the formation of fog. Although this does not address the situation when the winds are calm, the terrain around the proposed plant is open and the proponent suggests that the volume of water vapour would likely spread out, which would in turn limit the buildup of a heavy fog. The proponent acknowledges that there is a potential for icing to occur when temperatures are just below freezing but not when it is extremely cold. During very cold weather, the prevalence of supercooled droplets drops off as the temperature approaches –40 degrees C. In these conditions the plume is more likely to consist of ice crystals. Icing conditions are most likely when supercooled water droplets impact a cold road surface.

The Project Committee, on the recommendation of MELP, concludes that the FNEGP will not significantly increase the frequency and duration of fog or icing in the vicinity of the project, and therefore no mitigation is required. MELP agrees that modelling of fogging and icing during calm conditions is not required, and concurs with the proponent’s suggestion that a visual monitoring scheme

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would be adequate for monitoring fogging and icing during cold calm conditions.

6.3.1.3 Greenhouse Gas (GHG) Emissions and Management

From a greenhouse gas perspective, the FNEGP appears to be relatively positive. The FNEGP will generate three greenhouse gases: carbon dioxide, methane and nitrous oxide. The project is expected to provide GHG offsets of 63,267 tonnes per year if the project is only used for serving the power needs of Fort Nelson (BC only scenario), and 208,691 tonnes per year if it were operated full time with power being sold into the Alberta market (export scenario). The proposed greenhouse gas offsets are based on the assumption that the project will “back out” electricity from the Alberta Power Pool, which is

primarily derived from coal-fired thermal sources.

When greenhouse gas emissions upstream of the point of power generation are considered (on a full fuel cycle basis), the greenhouse gas offsets are slightly lower as a result of the much greater upstream GHG emissions associated with natural gas versus coal. Under a full fuel cycle emission scenario, the net project offsets would be 53, 683 tonnes per year for a BC only scenario, and 174,503 tonnes per year for the full production and export scenario.

There is no legislation limiting GHG emissions at this time. For the present, government is relying on voluntary actions by industry, other levels of government and the public to reduce GHG emissions and move BC towards the goal of stabilization. The proponent was asked if it was interested in participating in the Greenhouse Gas Emission Reduction Trading pilot project. They have declined at this time.

The proponent was also asked to explain why cogeneration was not a feasible option. BC Hydro advised that WEI has indicated that it is not interested in purchasing steam from this project at this time. The proponent notes that cogeneration may be a possibility in the future.

6.3.1.4 Construction Impacts on Air Quality

Smoke-related air quality impacts during construction will be prevented by prohibiting burning at the site. Neither natural vegetation debris nor construction debris will be burned. All salvageable wood from the clearing of the transmission line will become the property of WEI. Waste wood would either be made available for firewood to local residents or chipped on site using a tub grinder or similar equipment. The proponent has indicated that all construction debris will be removed from the site for disposal. Options for reuse or recycling of these materials will be considered favourably in the debris removal contracts. On the basis of these commitments, the Project Committee, on the recommendation of MELP, concludes that there will not be an adverse effect on air quality caused by construction activities.

6.3.2 Water Supply

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infrastructure. WEI has confirmed that it can accommodate the raw water supply for the FNEGP within the limits of WEI’s existing water licence. The water licence will likely require a minor amendment indicating the additional use of water for steam injection purposes for the FNEGP.

WEI preferentially takes water from the Fort Nelson River and stores it in a reservoir, but in the summer when the sediment load in the Fort Nelson River becomes too heavy, WEI takes water from Burbage Creek. The proponent does not plan to take water during the summer months from Burbage Creek because of potential concerns about fish and fish habitat. Water for the FNEGP during the summer months will be provided from storage in WEI’s existing raw water storage reservoir, or if necessary, through the development of a new storage reservoir on its site. WEI’s existing raw water storage

reservoir should be able to accommodate the water storage needs of the FNEGP, as its capacity exceeds twelve months supply of water for the FNEGP.

The FNEGP will require a maximum of approximately 510 m3/day of makeup water for operations (steam generation). This volume is considered by the proponent to be insignificant compared with the Fort Nelson River volume and therefore they consider it unlikely that there would be a measurable impact on the water resources of the river.

The proponent has also indicated that it may investigate the possibility of using groundwater as a source of water supply. If in the future groundwater is proposed as a source of water supply, the proponent will likely be requested at that time to provide information and data for a hydrogeological impact assessment and to note any potential impacts on surface water, fish or neighbouring wells from the groundwater extraction. If any adverse impacts are identified, then mitigation measures to avoid or minimize the identified impacts would be required.

The Project Committee, on the recommendation of MELP and DFO, concludes that the sourcing of water for the FNEGP from the Fort Nelson River is unlikely to cause a significant adverse effect and therefore no mitigation is required.

6.3.3 Waste Management

6.3.3.1 Wastewater

The main sources of wastewater are sanitary sewer, storm and floor drains, and process wastewater from the reversed osmosis back wash or demineralization system neutralization.

Wastewater from domestic water use will consist of both black water from toilets and grey water from showers and sinks. This water (estimated to be less than 200 L per day) will be combined and routed to a holding tank which will be serviced by a pump truck. The disposal will either be in Fort Nelson or at the WEI plant.

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drainage from any areas where this occurs will be directed to an underground holding tank. This tank will be drained periodically as needed by pumper truck and the waste will be directed to licensed facilities either in Fort Nelson or at WEI.

Where feasible, drainage from undisturbed areas or reclaimed areas will be allowed to seep into the ground and/or enter the nearest creek. Storm water flow from the access road will flow into adjacent ditches and natural drainage channels and from there into a nearby creek.

Boiler feedwater treatment wastewater will be produced from reverse osmosis (RO) backwash. The maximum wastewater production is estimated at 130 m3/day, and the average wastewater production is estimated to be 119 m3/day. The wastewater will be pumped back to WEI’s raw water system for

recycling. RO rejects will mainly be salt laden water. It may be recycled to save water cost in the future. Mixed bed deionizers will be regenerated off site and therefore will generate no waste on site.

WEI has confirmed that it can accommodate the wastewater treatment for the FNEGP within the limits of its existing discharge permits. A minor amendment to the discharge permits may be required to include the FNEGP as an additional source of effluent.

The Project Committee, on the recommendation of MELP, concludes that the wastewater from the FNEGP can be accommodated by WEI’s wastewater treatment system, and therefore no additional mitigation is required.

6.3.3.2 Solid Wastes

During construction, solid wastes will be generated from concrete forms, equipment and hardware containers, packaging, paint cans, waste metal sheeting, pipe and wire, and landscaping debris. Aside from the concrete forms, between 100 and 150 tonnes of waste would be generated. Additional waste wood will be generated from the clearing of the transmission line tap.

During operations, the only solid waste that will be generated will be from the control room and lunch room areas. A local contract will be issued to arrange for a bin and regular disposal service.

Where possible, reusable wood forms will be used and contractors minimizing waste production will be favoured. Any batteries, used motor oils, empty paint, solvent and adhesive containers will be separated from the waste stream and recycled in accordance with the Waste Management Act. All construction debris will be removed from the site for disposal. Options for reuse or recycling of these materials will be considered favourably in the removal contracts. Burning of materials will not be permitted on site.

The Project Committee, on the recommendation of MELP, concludes that the proposed disposal of solid wastes is acceptable, and no additional mitigation is required.

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The proponent advises that during construction, there will be no storage of hazardous materials on site. Construction vehicles will be serviced off-site and fuel for vehicles will be brought to the site via “tidy tanks”. Paints, solvents and welding gases will be kept in contractors’ mobile storage facilities.

During operations, no significant amounts of fuel will be stored on the project site. Small amounts of lubricating oil and solvents will be stored on site for equipment maintenance purposes. These materials will be kept in approved storage facilities.

The proponent has indicated that any special wastes will be handled, stored and disposed of in a manner conforming to applicable national, provincial and local regulations.

MELP recommends that fuel handling and storage and spill prevention and contingency plans (refer to MELP’s Fuel Handling Guidelines and Guidelines for Industry Emergency Response Contingency

Plans) be developed and followed for the construction and operation phases of the proposed project. In

addition, the Ministry recommends that the design and operation of any proposed fuel handling and storage facilities meet the CCME Codes of Practice for Underground and Above Ground Storage Tank Systems.

The Project Committee, on the recommendation of MELP, is satisfied with the proposed handling of special wastes during construction and operations.

6.3.4 Effects on Terrestrial Ecology and Wildlife

There is only a small amount of habitat that will be disturbed as a result of the proposed project which will affect a small amount of wildlife habitat used by small mammals and song birds. MELP has reviewed the section of the Application dealing with wildlife and habitat and does not anticipate any significant adverse impacts from the FNEGP.

Environment Canada (EC) indicated that due to the small footprint of the project and its location on previously developed land, it is unlikely that this project will result in any significant negative impacts to migratory birds or migratory bird habitat.

The Project Committee concludes that no mitigation measures are required for wildlife and wildlife habitat.

6.3.5 Effects on Aquatic Life

Expected impacts of the proposed project on fish and aquatic organisms will be related to incremental impacts from water supply and wastewater discharges. Initial concerns about the project were related to a proposal for incremental water use from Burbage Creek during the summer months and the potential for

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impacts on fish and fish habitat. That proposal is no longer being considered by the proponent. Freshwater intake from fish bearing watercourses such as the Fort Nelson River must follow DFO’s Freshwater Intake End-of-Pipe Fish Screen Guidelines. WEI uses a caisson and a screened water intake pump. They report that no fish have ever been detected in the caisson or entrained on the intake screens. No measurable aquatic impacts are expected to occur as a result of water extraction from the Fort Nelson River.

The proponent must prevent introduction of deleterious substances into fish-bearing waters and ensure that the requirements of the Fisheries Act are met during construction and operation.

DFO has a legal obligation to protect fish and fish habitat under the Fisheries Act for any project that could alter, disrupt or destroy fish habitats. Based on a review of the Application, DFO has determined that if appropriate mitigation measures are applied to water sourcing and wastewater treatment, a harmful alteration, disruption or destruction of fish habitat is not likely to occur. Thus, an authorization under section 35(2) of the Fisheries Act should not be required.

The Project Committee concludes, on the recommendation of DFO, that the FNEGP will not have an adverse effect on fish or fish habitat.

6.3.6 Spill Contingencies

The proponent has indicated in its Application that an Emergency Response Plan will be prepared. Staff will be trained to handle emergency situations with appropriate procedures as set out in the Emergency Response Plan. While no details as to the types and volumes of hazardous materials used or stored on site were provided, EC and MELP feel that, with proper commitments and plans in place, the possibility of extraordinary emergency issues is minimal.

An emergency response plan consistent with Emergency Planning for Industry (CAN/CSA-Z731-M91) in conjunction with the BC Environment Guidelines for Industry Emergency Response Contingency Plans will be prepared in sufficient time to allow agency review prior to the start of construction. The plan will indicate the names and telephone numbers for people to contact for help and further

information. Attached to the plan will be a summary of the emergency response guidelines, complete with numbers to call for the Provincial Emergency Program and Environment Canada in the event of reportable spills. Where applicable, the CCME Environmental Code of Practice for Underground Storage Tank Systems Containing Petroleum Products (1994), CCME Code of Practice for Underground Storage Tanks Containing Petroleum Products and Allied Petroleum Products (1993) and the BC Fire Code will be applied. The plan will be issued to all contractors and employees frequenting the construction site. There will be few opportunities for spill incidents and there are no significant drainages or water bodies in the immediate vicinity of the plant site. Any small spills could be adequately addressed before moving off-site.

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No significant amounts of fuel will be stored on the project site during operations and tidy tanks will be used for fueling equipment during the construction phase. Small amounts of lubricating oil and solvents will be stored on site for equipment maintenance purposes. These materials will be kept in approved storage facilities. Oil spill kits will be available on site during the construction and operational stages of the project.

The Project Committee, on the recommendation of MELP and EC, is satisfied with the proponent’s proposal for addressing spill contingencies. The Town of Fort Nelson and the Fort Nelson-Liard

Regional District representatives both requested that the proponents provide copies of their emergency response plan to the Town of Fort Nelson’s Emergency Operations Committee.

6.3.7 Environmental Monitoring During Construction

The proponents have stated that an environmental inspector with suitable professional credentials will be provided during the construction and commission of this project. This will include any times when there is work in and around water that could affect fish habitat. The terms of reference for the environmental inspector will be agreed to by all relevant agencies prior to construction of the project. Construction activities will be planned and scheduled to minimize environmental impacts during construction.

The Project Committee, on the recommendation of MELP, EC and DFO, is satisfied with the proponent’s commitment for environmental monitoring during construction.

6.4 Socio-Economic Issues

The socio-economic implications of the project are generally positive, with any negative impacts being minor in nature. The site is 20 kilometers from the town of Fort Nelson and a peak construction

workforce of 50 (over 3 months) and operations workforce of 5 is quite insignificant in an established community with a population of 4,700 people.

6.4.1 Community Impacts

The proponent has agreed to identify Fort Nelson area construction firms for potential contracting opportunities and to consider re-scheduling certain construction activities if accommodation becomes a problem. These actions are expected to mitigate any short-term social stresses brought about by the project.

Both the Town of Fort Nelson and the Fort Nelson –Liard Regional District support the project as a means of improving public health by securing a firm power supply. The Project Committee concluded that the project’s effects on the community were positive, and that the proponent’s commitment to address potential accommodation issues was acceptable.

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6.4.2 Employment Impacts

The project will provide approximately 70 person-months of construction employment (approximately 30 persons over a 2 ½ month construction period). About 60 percent of the construction jobs are

expected to be awarded to BC residents. Once operational, the FNEGP will have a permanent staff of 5 persons.

The 4 persons displaced by the decommissioning of the diesel generators will have opportunities within BC Hydro under their Collective Agreement. BC Hydro has agreed to provide preference to the displaced employees for jobs at the new plant, provided they meet the qualifications.

Local contractors, including First Nations, will have opportunities to bid for various construction

contracts, while local residents will have opportunities in working for contractors and subcontractors on the project construction. The proponents expect local contractors and residents to have an advantage in bidding/applying for contracts or employment because of the BC content policy adopted by the

proponents in tendering work for this project, and the high travel and living expenses required by workers brought in from outside Fort Nelson.

There are several contracting companies owned and operated by the Prophet River Indian Band, the Fort Nelson Indian Band or their members. The Bands have made available to the Proponents capability statements of these contracting companies. The Proponents will monitor the contracting and employment opportunities and will identify these opportunities to the Bands through the Aboriginal Relation

Department of BC Hydro.

6.4.3 Revenue Impacts

The Proponents estimate:

● federal revenue impacts to be neutral,

● an increase in provincial revenues of approximately $ 5.77 million, comprising $1.65 million in

provincial sales tax on construction purchases and $4.12 million in present value terms on fuel taxes for operations, and

● an increase of $1.96 million (present value) or $200,000 per year in property taxes.

In addition, BC Hydro will receive a return based on 50% of the cash flows of the project. This return will contribute to the dividends payable to the Province of British Columbia.

6.4.4 Traffic Impacts

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transported along the highway. Construction workers will add another 50 vehicles /day at the peak of construction. During operations, there will be 5 vehicles/day. The Project Committee does not expect these volumes to have a significant impact on traffic in the Fort Nelson area.

6.5 Cultural and Heritage Issues

6.5.1 Traditional Use Impacts

The FNEGP, including the transmission line, lies entirely on private land owned by WEI. Most of the site is on disturbed land and inside the fence of the WEI Fort Nelson Gas Plant. BC Hydro reports that the Fort Nelson Indian Band raised no concerns over impacts of the project on wildlife or traditional uses. The Fort Nelson Indian Band has not confirmed or denied BC Hydro’s statement concerning traditional use effects.

The Prophet River Indian Band has indicated that the project also lies within their traditional use area. In a letter dated July 15, 1998 to the Honourable Michael Farnworth, the Band indicated that the site has been examined for archaeological potential and has been found to have low or no historical potential. The Band supports the project as it would provide them with a much more reliable source of power. The Project Committee concludes that the project is unlikely to have a significant adverse effect on traditional uses and therefore no mitigation measures are required.

6.5.2 Archaeological Impacts

Points West Archaeological Consultants on page 7 of its report (see Appendix 7.2 of the Application) states that "if the turbine is situated ... on the south or east sides of the Westcoast plant site,

archaeological potential is judged to be low and no further archaeological ground assessment would likely be required". As the turbine will be situated on the southeast corner, the conclusions of Points West Archaeological Consultants have been accepted by the Ministry of Small Business, Tourism and Culture, Archaeology Branch.

The Project Committee, on the recommendation of the Archaeology Branch, concludes that the project is unlikely to have a significant adverse effect on archaeological resources, and therefore no mitigation measures are required.

6.6 Health Issues

The Ministry of Health and Ministry Responsible for Seniors noted that power failures in a climate such as Fort Nelson’s are a potential threat to public health. A more secure power supply may be expected to prevent sickness and cases of premature death. The Ministry is of the opinion that the project would

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improve air quality for most Fort Nelson citizens, as well as in the surrounding airshed, as a result of:

● cleaner burning technology

● emissions distributed throughout the year rather than concentrated in the winter months ● the new facility is 20 km from a population centre whereas the old facility is adjacent to the

population centre

● short term standby measures will no longer be required

● a reliable source of surplus power will enable independent users with unregulated generators to

draw electricity from the power grid, potentially eliminating these emission sources.

The Project Committee, on the recommendation of the Ministry of Health, concludes that the project is unlikely to have a significant adverse effect on health, and furthermore, offers potential for significant health benefits Therefore, no mitigation measures are required.

7.0 PROJECT COMMITTEE

RECOMMENDATIONS AND REASONS

Pursuant to section 19(3) of the Act, the Project Committee established for the review of the FNEGP has completed the overall review of the Application, including all supplementary reports and correspondence on the Application, and hereby makes recommendations and provides the reasons for those

recommendations. It should be noted that these recommendations may not reflect the views of the Fort Nelson Indian Band which, although a member of the Project Committee, did not sign off on these recommendations.

7.1 Recommendations

The Project Committee recommends that the Application be referred to the Minister of Environment, Lands and Parks and the Minister of Employment and Investment for a decision to issue a Project Approval Certificate, in accordance with section 20 (b)(i) of the Act.

The Project Committee recommends that the Project Approval Certificate be subject to the following conditions:

● BC Hydro and TransAlta must design, construct, operate, dismantle and abandon the project and

fulfil all commitments and proposed mitigation measures as documented in the Application (including supplementary documents and correspondence) and discussed in this report;

● BC Hydro and TransAlta must notify the Executive Director of the EAO if, prior to operations, it

wishes to change the design, location, construction or operation of the Project (as described in the documents listed in Appendix A) in a manner that may potentially cause significant adverse

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effects, and where the Executive Director considers that the proposed change will cause significant adverse effects, the Executive Director will identify a process and timeline for the review of the proposed change before a recommendation is made to Ministers concerning the change; and

● BC Hydro and TransAlta must comply with all applicable orders, directions and conditions, and

obtain and comply with all applicable tenures, licences, regulations, approvals, standards and permits, or other authorities.

7.2 Reasons

The Project Committee recommends that a Project Approval Certificate be issued for the following reasons:

● pursuant to section 19(2)(a) of the Act, specified measures relating to the distribution of

information about the Fort Nelson Electrical Generation Project have been carried out by the proponent;

pursuant to section 19(2)(b) of the Act, the Application (including supplementary information and

correspondence as listed in Appendix A of this report) identifies and adequately describes the potential effects of the Fort Nelson Electrical Generation Project, including all significant adverse potential effects; and

● pursuant to section 19(2)(c), of the Act, the Application (including supplementary information

and correspondence as listed in Appendix A of this report) sets out practical means of preventing or reducing to an acceptable level all significant adverse effects of the Fort Nelson Electrical Generation Project.

APPENDIX A

DOCUMENTATION AND CORRESPONDENCE FOR

THE

FORT NELSON ELECTRICAL GENERATION

PROJECT

Application for a Project Approval Certificate - Fort Nelson Electrical Generation Project, prepared by British Columbia Hydro and Power Authority and TransAlta Energy

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