Construction Phase Activities Construction Phase Activities

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Page 1 of 463

Information Response Table

Comment ID#

Name/ Organization

Information Request-Comment EIS-G Section Response AEW_ltr_ 001 Alberta Environment 1. Alberta’s Interests

Attached is a table titled, “Alberta‟s Interests: Site C Clean Energy Project”, which presents the full range of Alberta‟s interests that should be evaluated in this environmental assessment process. Alberta had provided this table to the BCEAO earlier in the environmental

assessment process in anticipation that these interests would be clearly identified in the Draft EIS Guidelines. The Draft EIS Guidelines cover an extensive range of topics, however, the wording is very generic and as such it is not clear whether all our specific interests will be considered. Alberta would like to see our interests acknowledged and addressed in the final EIS Guidelines document, and evaluated in the Environmental Impact Statement.

n/a Technical analysis and modelling have been conducted to evaluate the impact that a hydro-electric dam at Site C would have on downstream river flows and levels. The preliminary analysis

concluded that the operation of a dam at Site C would result in only small changes in flows and levels at the Town of Peace River.

On the basis of that preliminary analysis, BC Hydro established the downstream limit of the Technical study area for the analysis of surface water hydrology at Peace Point, Alberta, approximately 740 km downstream of the Town of Peace River, to ensure that any changes to surface water hydrology resulting from the Project would be detected. On this basis, BC Hydro that the downstream extent is more than sufficient for the environmental assessment.

The EIS will include detailed technical modelling assessments and analysis of changes in surface water hydrology resulting from the operation of the proposed Project.

Please see Topic Summary: Peace Athabasca Delta

AEW_ltr_ 002

Alberta Environment

2. Assessment Areas

Alberta is concerned that the geographic extents of the assessment areas for the Valued Components presented in the Draft EIS

Guidelines do not extend far enough downstream to fully assess the potential impacts in Alberta. Alberta believes that most of the Valued Components should be

evaluated downstream to the Northwest Territories border. We understand that

technical experts chose the aerial extent of the potential impacts based on some criteria and understanding. However, that information /

n/a Please see response to AEW_ltr_001

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Page 2 of 463 criteria was not shared in the Draft EIS

Guidelines document, and therefore there is no means to determine whether the Draft EIS Guidelines adequately address Alberta‟s interests. AEW_ltr_ 003 Alberta Environment 3. Alberta Communities

Communities and municipalities downstream on the Peace River in Alberta were

disappointed that the Draft EIS Guidelines had little or no acknowledgement of their existence or concerns. Again, this appears to be a result of the Draft EIS Guidelines being very generic and limited in detail. As written, the Draft EIS Guidelines did not convey an understanding or empathy for communities in Alberta. The Final EIS Guidelines should rectify this lack of understanding and acknowledgement.

n/a It is our understanding that the EIS-Guidelines is a technical document intended to describe

required technical studies and assessments to be conducted under the Environmental Assessment Process. Though we are acutely aware of these issues of concern, we submit it is not appropriate to include statements about empathy or concern in a technical document.

AEW_tbl _001

Alberta Environment

After line 34, page 8: INSERT new bullet: “Management of silt and sediment entering the Peace River during the construction period”

3.3.9. Construction

Phase Activities

This is not an appropriate addition to this section. An annotated outline of the Project Erosion Prevention and Sediment Control Plan will be provided in Section 21 of the EIS.

AEW_tbl _002

Alberta Environment

After line 14, page 9: INSERT new bullets: •“Management of the clearing, preparation, and flooding of the reservoir lands related to water quality of the

Peace River, and specifically related to raw water supplies for communities in Alberta” • “Management of the filling of the reservoir and impacts of construction on downstream flows in Alberta,

3.3.9. Construction

Phase Activities

This is not an appropriate addition to this section. Annotated outlines of the Project Groundwater Protection and Surface Water Quality Protection Plans Plan will be provided in Section 21 of the EIS.

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Page 3 of 463 particularly if it is a dry year during reservoir

filling”

AEW_tbl _003

Alberta Environment

After line 31, page 10: AT END OF SENTENCE: “ ...flows and water levels” INSERT: “of the Peace River through Alberta, including the Peace Athabasca Delta to the Northwest Territories border.” 3.3.10. Operations Phase Activities

Please see response GNWT_004

AEW_tbl _004

Alberta Environment

Line 34, page 10: AFTER: “estimate of the” INSERT: “magnitude,”

3.3.10. Operations

Phase Activities

The EIS Guidelines page 10, line 34 will be revised to include: " the magnitude of potential spillway releases" .

AEW_tbl _005

Alberta Environment

Page 16: COMMENT: Include the public meetings and consultation that will take place in Alberta. 7. Information Distribution and Consultation

See Section 7.1 of the EIS Guidelines for a description of Public Information Distribution and Consultation.

BC Hydro expects that the communities in Alberta with an interest in the Project will be notified by the regulatory agencies of the consultation process under the cooperative environmental

assessment process.

AEW_tbl _006

Alberta Environment

After line 20, page 19: INSERT NEW

SECTION 7.3.3 “Emergency Notification” “The EIS will describe BC Hydro‟s emergency notification plan and procedures to be employed for people and communities

downstream in Alberta during the construction period in the event of an emergency.”

7.3.2. Construction Communicati

on

See Topic Summary: Dam Safety.

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Page 4 of 463 AEW_tbl

_007

Alberta Environment

Line 22, page 31: DELETE: “town of Peace Point, Alberta.” INSERT: “Alberta-Northwest Territories border.”

COMMENT: This additional, more detailed information on expanded flows and expanding evaluation downstream to the

Alberta-Northwest Territories border is required to adequately evaluate the potential impacts and cumulative effects on the valued components downstream in Alberta.

9.2.1. Surface

Water Regime

Please see response to AEW_ltr_001.

AEW_tbl _008

Alberta Environment

Line 24, page 31: Section SHOULD INCLUDE the following flow information for the longest period of time possible: 1950s-2010

• Mean annual naturalized flows

• Mean annual historic (recorded) flows • Mean annual predicted flows with SITE C • Mean weekly naturalized flows

• Mean weekly historic (recorded) flows • Mean weekly predicted flows with SITE C • Mean daily naturalized flows

• Mean daily historic (recorded) flows • Mean daily predicted flows with SITE C A discussion of the limitation of this daily information may be required.

9.2.1. Surface

Water Regime

The EIS will include a description of the existing (post-regulation) flow regime of the Peace River and the expected flow regime of the Peace River with Site C. This description will include annual, monthly, daily, and hourly flows and/or water levels and will consider the seasonality of flows where appropriate. Exceedence (duration) curves, hydrographs and other plot-types will be used as appropriate to describe existing conditions.

Naturalized flows will not be presented in the EIS since they do not reflect the baseline conditions. Flows on the Peace River are regulated by an upstream reservoir capable of multi-year storage, the historical post-regulation flow regime reflects not only the variability in the Peace River inflows but also the changes over time in BC Hydro‟s system load, system resources, and external market conditions. For this reason, the historical flow regime is not a good indicator of the expected flows in the absence of the Project.

AEW_tbl _009

Alberta Environment

Line 25, page 31: DELETE: “Peace Point, Alberta,” INSERT: “Alberta-Northwest Territories border,“

9.2.1. Surface

Water Regime

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_010

Alberta Environment

ADD NEW TEXT after line 26, page 31: “The EIS will describe hourly flows or daily maximum and minimum flows for a few representative times of the year

(open water season, low flows, high flows and under ice winter flows) for a few representative years, to provide an

understanding of normal operations and of the potential variability for naturalized, historic (recorded) and predicted flows with Site C conditions, downstream to the

Alberta-Northwest Territories border.” To clarify: THIS IS NOT A REQUEST FOR PRODUCING HOURLY FLOWS FOR THE ENTIRE PERIOD OF RECORD.

THEN ADD NEW BULLET:

• “Generate a series of statistics describing the high and low flows for open water and under ice (winter) periods

separately as required for naturalized, historic (recorded) and predicted flows with Site C conditions.”

9.2.1. Surface

Water Regime

Please see response to AEW_tbl_008.

Relevant flow data will be used to characterize baseline conditions and this will include the impact of ice on water levels. Changes to the downstream ice regime and associated changes to water levels with Site C will be described in the EIS as referenced in section 9.2.1 and 9.2.4 in the EIS Guidelines.

AEW_tbl _011

Alberta Environment

Line 7, page 32: AT bullet, • “seasonal flow patterns of post-construction flows…” AFTER: “ flow patterns of”

INSERT : “naturalized, historic (recorded) and”

9.2.1. Surface

Water Regime

Please see response to AEW_tbl_008

AEW_tbl _012

Alberta Environment

Line 5, page 33: DELETE: “the British Columbia/Alberta border.” INSERT: “ include the County of Northern Lights.”

COMMENT: The towns of Fairview and Peace River are the first major communities in Alberta that use the Peace River

as their raw water supply for drinking water. Residents and Aboriginals in Northern Sunrise County take water from the Shell intake downstream of the Town of Peace River. DMI withdraws raw water from the Peace River in

9.2.2. Water Quality

Comments noted and text has been revised. See T8TA_tbl_071

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Page 6 of 463 the County of Northern Lights downstream of

the Town of Peace River. It is important to understand the potential impacts of the project on these communities and municipalities. AEW_tbl

_013

Alberta Environment

Line 19, page 34: DELETE: “Grimshaw, Alberta” INSERT: “ the Shaftesbury ferry”

9.2.4. Thermal and

Ice Regime

The downstream study boundary for water temperature is the Alces River rather than Grimshaw. Section 9.2.4, lines 18-24 of the EIS Guidelines (Thermal and Ice Regime - Downstream

Temperature) will be replaced with the following:

" Potential changes to downstream water temperature to the Alces River (approximately 60 km downstream) will be described in the EIS.

The analysis will be conducted using a two-dimensional cross-sectionally averaged hydrodynamic and water quality model (CE-QUAL W2). This model is being used primarily for the purpose of examining aquatic productivity. The CE-QUAL W2 model simulates basic eutrophication processes such as temperature-nutrient-algae-dissolved oxygen-organic matter and sediment relationships (Portland State University, 2011). It is expected that changes to water temperature due to Site C will be negligible at the confluence of the Alces River with the Peace River; however, if warranted, the downstream extent of the assessment will be extended to capture the entire extent of Project influence".

AEW_tbl _014

Alberta Environment

Line 29-30, page 34: DELETE: “ a location approximately 700km downstream near Fort Vermilion, Alberta.” INSERT: “downstream of the Peace Athabasca Delta, Alberta. “

COMMENT: The ice regime is an important component influencing the volume and level of water in the Peace Athabasca Delta. It is important to understand the cumulative effect of the ice regime on the Peace Athabasca Delta. “

9.2.4. Thermal and

Ice Regime

The Technical study area for the analysis of ice conditions extends downstream to Fort Vermilion, Alberta, over 700 km downstream of Site C. Model predictions confirm that the influence of Site C on ice conditions does not extend this far downstream; as such extending the study area further downstream is not warranted.

AEW_tbl _015

Alberta Environment

Line 2, page 35: AT END OF: ” information regarding the” INSERT: “ pre-regulation conditions,”

9.2.5. Fluvial Geomorphol

ogy and

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Page 7 of 463 COMMENT: This information is required to

understand the changes to fluvial

geomorphology and sediment transport due to current flow regulation and additional

cumulative effects of the Site C project.

Sediment Transport AEW_tbl _016 Alberta Environment

Line 31-32, page 35: DELETE: “within the anticipated extent of …from existing information.” INSERT: “ to Peace Point, Alberta.” 9.2.5. Fluvial Geomorphol ogy and Sediment Transport

Section 9.2.5, Line 31-32, of the EIS Guidelines will be revised as follows:

DELETE: “within the anticipated extent of …from existing information.” INSERT: “ to Peace Point, Alberta.”

AEW_tbl _017

Alberta Environment

Line 34-35, page 35: DELETE: “within the anticipated extent… from existing information.” INSERT: “ to Peace Point, Alberta.”

ogy and Sediment Transport

Section 9.2.5, Line 34-35, of the EIS Guidelines will be revised as follows:

DELETE: “within the anticipated extent… from existing information.” INSERT: “ to Peace Point, Alberta.”

AEW_tbl _018

Alberta Environment

Line 13-14, page 36: DELETE: “ Many Islands, Alberta (200 km downstream of the W.A.C. Bennett Dam).” INSERT: “ the Alberta-Northwest Territories border.”

9.2.6. Methylmercu

ry

The downstream extent of the Technical study area for methylmercury will be extended to Vermillion Chutes by incorporating data collected for the Dunvegan project.

Section 9.2.6, Line 12 of the EIS Guidelines will be revised as follows:

ADD: .. and will consider mercury concentrations within and downstream of the Site C reservoir to Vermillion Chutes, Alberta

DELETE: ... to Many Islands , Alberta (200 km d/s of the WAC Bennett Dam),

AEW_tbl _019

Alberta Environment

Line 5, page 39: IN Table 10.1, Fish and fish habitat valued component rationale, Column 2 “Interaction with Project Components and...” AFTER: “Construction activities” DELETE: “and” INSERT: “,”<comma> AFTER: “water impoundment,” INSERT: “and power

production flow operations over the life of the project” THE RESULTING SENTENCE

SHOULD READ: “Construction activities, water impoundment, and power production flow

10.1. Fish and Fish Habitat VC Scoping and

Rationale

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Page 8 of 463 operations over the life of the project”

IN Table 10.1, Fish and fish habitat valued component rationale, Column 4 “Public and Stakeholder issues”

AFTER: “Food fisheries, recreation” INSERT: “ health of the aquatic ecosystem, fish habitat and fish populations.”

AEW_tbl _020

Alberta Environment

Line 9, page 39: IN Table 10.2, Fish and fish habitat assessment areas, Column 2 “Local Assessment Area” DELETE: “Pine River;” INSERT: “ Smoky River;” IN Table 10.2, Column 3 “Regional Assessment Area” DELETE: “Vermilion Chutes, AB, which is a distance of approximately 865 km” INSERT: “ the Alberta- Northwest Territories border”

10.2.1. Fish and Fish

Habitat Spatial Boundaries

Please see response to DFO_023

AEW_tbl _021

Alberta Environment

Line 7, page 40: AFTER: “biological assemblages, water quality,” INSERT:

“physical wetted habitat, side channel habitat, bed sediment habitat,”

Habitat Baseline

See response to DFO_028

AEW_tbl _022

Alberta Environment

Line 13, page 40: AFTER: “temperature” INSERT: “bed sedimentation”

Habitat Baseline

Section 10.2.3, page 40, line 14 of the EIS Guidelines will be revised as follows: ADD sediment transport AFTER temperature

AEW_tbl _023

Alberta Environment

Line 3, page 41: AFTER: “ changes in nutrients” INSERT: “physical wetted habitat, side channel habitat, bed sediment habitat;”

10.2.4. Fish and Fish Habitat - Potential Effects of the Project and Proposed Mitigation

Section 10.2.3, page 41, line 4 of the EIS Guidelines will be revised as follows: ADD fish habitat AFTER web

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_024

Alberta Environment

Line 5, page 42: IN Table 11.2 Vegetation and plant communities assessment areas, in Column 2 “Local Assessment Area” AFTER: “from Hudson‟s Hope to” DELETE: “ the Alberta border;” INSERT: “Smoky River;”

11.2.1. Vegetation and Plant Communities Spatial Boundaries

Please see Topic Summary: VC Selection and Boundaries

AEW_tbl _025

Alberta Environment

Line 17, page 44: INSERT NEW BULLET AFTER line 17,

• “The area of vegetation/plant community change on the near channel and sand bars, islands and flood plain.”

11.2.4. Vegetation and Plant Communities - Potential Effects of the Project and Proposed Mitigation

Please see Topic Summary: Cumulative Effects Assessment

AEW_tbl _026

Alberta Environment

Line 15, page 45: IN Table 12.1, Wildlife

resources valued component rationale, Column 2 “Interactions with Project Components and…” AFTER: “and reservoir creation” ADD: “and downstream flow-related ice regime changes”

12.1. Wildlife Resources Valued Component Scoping and Rationale

Downstream flow-related ice regime changes on the margins of the river downstream will be addressed in the Wildlife Resources effects assessment.

AEW_tbl _027

Alberta Environment

Line 1, page 46: AT: “Hudson‟s Hope to the Alberta border;” DELETE: “ Alberta border;” INSERT: “ Smoky River;”

IN Table 12.2 Wildlife resource assessment areas, Column 3 “Regional Assessment Area” AFTER: Peace Lowlands Ecosection” INSERT: “to the Peace Athabasca Delta”

12.2.1. Wildlife Resources

Spatial Boundaries

The LAA will be defined in consideration of the expected maximum range of the potential for the Project to cause disruption to habitat and wildlife.

BC Hydro believes that the Peace Lowlands Ecosection is an appropriate and conservative boundary for the assessment of potential effects on wildlife that meets the above criterion.

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_028

Alberta Environment

Line 2, page 58: IN Table 15.2 Current use of lands and resources for traditional purposes, Column 3 “Regional Assessment Area”

DELETE: “ to Vermilion Chutes , AB, which is a distance of approximately 865 km” REPLACE with: “and downstream to include the Peace Athabasca Delta.” ALSO, in Column 3 AT: “Peace Lowlands Ecosection” ADD AT THE END: “and the Peace valley, to and including the Peace Athabasca Delta”

15.2.1. Current Use of Lands and Resources for Traditional Purposes Spatial Boundaries

Please see response to AEW_ltr_001

AEW_tbl _029

Alberta Environment

Line 16, page 76: IN Table 16.6 Harvest of fish and wildlife resources assessment areas, Column 2 “Local Assessment Area” DELETE: “the Alberta border” INSERT: “and including the Peace Athabasca Delta”

16.6.1. Harvest of Fish and Wildlife Resources Spatial Boundaries

AEW_tbl _030

Alberta Environment

Line 24, page 70: IN Table 16.8 Navigation assessment areas, for both Column 2 AND Column 3 DELETE: “Shaftesbury ice bridge” INSERT: “LaCrete ice bridge and ferry”

16.8.1. Navigation

Spatial Boundaries

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_031

Alberta Environment

Line 9, page 71: REPLACE: “The ice bridge at Shaftesbury” WITH: “The ice bridges and ferries at Shaftesbury and LaCrete”

16.8.3. Navigation

Baseline

Please see response to TC_013

AEW_tbl _032

Alberta Environment

Line 9, page 83: IN Table 19.2 Human health assessment areas, Column 2 “Local

Assessment Area” AFTER: “water quality” INSERT: “(including raw water quality for drinking water of communities in Alberta downstream to and including the Town of Peace River)” AFTER: “methylmercury”

INSERT: “(including fish consumption along the full length of the Peace River”

19.2.1. Human Health Spatial Boundaries

(A) The water quality reference in Table 19.2 Human Health Assessment Area will follow Health Canada's water quality considerations including drinking and recreational water quality. The Water Quality Technical study area is delineated in EISG Section 9.2.2 Water Quality.

(B) The mercury concentrations in country foods referenced in Table 19.2 will include Health Canada's considerations for accumulations of mercury in country food sources. The methylmercury technical study is delineated in EIS Guidelines, Section 9.2.6.

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Page 12 of 463 BCMFLN RO_ltr_0 01 BC Ministry of Forests Lands and Natural Resource Operations

Our review has identified that additional discussions are required around information and technical requirements for the

management of wildlife resources as well as vegetation and plant communities, including species at risk (section 11 & 12). FLNRO recommends that a Terrestrial Working Group be established to further discuss these values.

n/a BC Hydro welcomes the formation of any working group that the BCEAO and CEA Agency deems appropriate. BCMFLN RO_ltr_0 02 BC Ministry of Forests Lands and Natural Resource Operations

FLNRO would like to request that the data, analysis reports, listing of technical experts and qualifications be made available at the time of release of the Draft Environmental Impact Statement so that FLNRO staff can conduct our own technical reviews of the data and assumptions should we choose to do so to verify the claims and conclusions of the proponent.

8.2. Technical Studies and

Planning

The EIS will include technical data reports and other supporting documents as appendices, including where feasible and permissible the data. Reports will be in final form and will include relevant professional information about the authors and contributors. The EIS sections and appendices will include lists of references and where possible key supporting studies, inventories or other technical documents will be made available. Information or reports subject to confidentiality agreements, privacy considerations or commercial sensitivity will not be provided.

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Page 13 of 463 BCMFLN RO_tbl_0 01 BC Ministry of Forests Lands and Natural Resource Operations

“Project team members and qualifications will be presented.”

Recommend that the information provided clearly links project team members to specific work delivered.

Authorship The EIS will present qualifications of team members and related subject matter expertise.

BCMFLN RO_tbl_0 02 BC Ministry of Forests Lands and Natural Resource Operations

Consider basing the estimates of construction and operation on a timeframe starting at the granting of an Environmental Certificate as the start of the scheduling timeframe, not those of the Joint Review Agreement, as those

timeframes are subject to a public process and not entirely within the control of the proponent.

3.1.1. Scheduling

Section 3.1.1 of the EIS Guidelines will be revised as follows:

"An estimated month by month construction schedule based on project planning at the time of preparation of the EIS will be incorporated into the EIS. The schedule will commence on the anticipated date of certification. The EIS will describe the anticipated scheduled maintenance activities and the potential future capital upgrades."

Please provide the following at the time of submission of the EIS

• The most current GIS shapefiles for all project components for analysis purposes at the time of EIS submission.

• A list of the proponents interpretation of the Crown tenures that are conflicting with this project, by project component

See section 3.2., page 4, EIS-G

3.2. Project Location

Information about land status, tenures and Project requirements will be described in Section 9.1.2 (to be revised as below). Potential effects on tenured areas and activities will be assessed in accordance with EIS Guidelines Section 16 (Land and Resource Use). In support of Project permit applications BC Hydro will provide relevant mapping and tenure information, and a summary of communications with tenure holders, to the responsible regulatory agencies.

The EIS Guidelines will be revised as follows:

Delete “tenure, ownership and land management details for lands with the areas of project components” from Section 3.2, page 4.

Add “tenure, ownership and land management with the Project activity zone” to Section 9.1.2. Revise Section 9.1.2 as follows:

9.1.2 Land Status, Tenure and Project Requirements The EIS will:

- Identify land ownership by area of private, BC Hydro owned, and Crown land within the Project activity zones

- Provide a summary of land tenure within the Project activity zones, with potential effects to tenured areas or activities to be assessed in accordance with Section 16 Land and Resource use - Provide maps illustrating the ownership, tenure and land management areas with the Project activity zone

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Page 14 of 463

- Describe the requirements to acquire or obtain new rights over private or government owned property to construct and operate the Project

- Describe the approach for acquiring private property and rights to Crown land

Consider providing information on the area of Crown land being occupied by the reservoir as well as the impact, in area, of the reservoir to the Crown Forest Landbase as well as the Timber Harvesting Landbase, by Forestry Management Unit be described for each of the project component areas.

3.3. Project Components and Activities

Please see response to BCMFLNRO_tbl_003

In accordance with the EIS Guidelines, Section 16.3 Forestry, and the Project Clearing Plan, the EIS will describe the forest area affected by the Project using designated provincial forest land classifications. BCMFLN RO_tbl_0 05 BC Ministry of Forests Lands and Natural Resource Operations

EIS will “describe the permanent and

temporary access routes required for access to the project site” .

Suggest including a description of the temporal aspects of road use (e.g. traffic management plans, expected traffic patterns and volumes for different phases of project development,

deactivation schedules). 3.3.5. Project Overview - Access Roads and Rail

The EIS Guidelines will be revised by adding the following to the end of the first sentence of Section 3.3.5:

"including a description of the temporal aspects of road use (e.g. traffic management plans, expected traffic patterns and volumes for different phases of project development, deactivation schedules)."

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Suggest including a description of alternative highway realignment options and a rationale for the preferred option.

3.3.6. Project Overview - Highway 29 Realignment

The EIS Guidelines will be revised by adding the following to the beginning of Section 3.3.6: "The EIS will describe alternative highway realignment options and a rationale for selection of the preferred options." BCMFLN RO_tbl_0 07 BC Ministry of Forests Lands and Natural Resource Operations

Sources of construction materials will be

described here. Suggest including a description of the mechanism of delivery (e.g. truck, train) and expected traffic volumes during each phase. 3.3.7. Project Overview - Quarried and Excavated Construction Materials

The EIS will describe the mechanism of delivery and expected traffic volumes during each phase.

Consider including the projected impacts and upgrades to infrastructure required to facilitate the transportation of workers and equipment to and from the construction sites, and temporary accommodations on a daily basis in the

discussion of worker accommodation. Suggest including related plans for management of workers (e.g. access management, hunting restrictions) and describing the size and use of the camp projected over different project phases. 3.3.8. Project Overview - Worker Accommodat ion

Transportation is addressed in Section 17.5 Transportation of the EIS Guidelines. Section 3.3.8, line 33 of the EIS Guidelines will be revised as follows:

" The projected size and use of camp facilities will be described, including any related project employment policies or restrictions."

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Access roads to the dam site speaks to traffic management during modifications to existing roads, consider including traffic management in relation to any project component that may affect any road tenured by FLNRO.

3.3.9. Construction

Phase Activities

Traffic management during modification of existing roads will be described in the Traffic Management Plan referenced in Section 21 of the EIS Guidelines.

Consider providing a rationale for the choice of installation of permanent versus temporary crossings over the Peace and Moberly Rivers and the benefits and drawbacks of both.

3.3.9. Construction

Phase Activities

Section 3.3.9 of the EIS Guidelines will be revised by adding the following to the end of the bullet on lines 9 and 10, page 8:

"including a rationale for the choice of installation of temporary rather than permanent crossings over the Peace and Moberly Rivers"

Reservoir prep – removal/treatment of existing structures...

Consider including discussion of other hazards that may require removal.

3.3.9. Construction

Phase Activities

Section 3.3.9 of the EIS Guidelines will be revised by adding the following to the end of the bullet on line 12, page 9:

"including any other potential hazard to navigation at the minimum normal reservoir level."

Construction and upgrade of the Access Roads to the Dam is addressed, consider including any major construction or upgrade of access roads to the other major components of the Project

3.3.9. Construction

Phase Activities

Section 3.3.5 of the EIS Guidelines will be revised by the inclusion of the following at the end of the first sentence:

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Traffic management during modification to existing roads –

Consider providing additional information regarding the needs of traffic management during other phases throughout the project

3.3.9. Construction

Phase Activities

Please see response to BCMFLNRO_tbl_009.

BCMFLN RO_tbl_0 14 BC Ministry of Forests Lands and Natural Resource Operations Removal/decommissioning of existing

pavement – Consider providing clarification in the EIS if other materials used in road

construction such as the gravel will be removed as well as the pavement and if not, why? See section 3.3.9., page 9, EIS-G

3.3.9. Construction

Phase Activities

Where practical and economic, asphalt and other materials from the inundated sections of Highway 29 will be reused. BCMFLN RO_tbl_0 15 BC Ministry of Forests Lands and Natural Resource Operations

Connections to existing driveways – Please provide clarification in the EIS if there are any driveways, properties or existing crown tenures that may need entirely new access routes constructed as a result of the highway realignment

See section 3.3.9., page 9, EIS-G

3.3.9. Construction

Phase Activities

Section 3.3.6 of the EIS Guidelines will be revised by adding the following to the end of the section: "The EIS will identify any driveways, properties or existing crown tenures that may need entirely new access routes constructed as a result of the highway realignment."

Please include clarification in the description of temporary construction facilities of which offsite components of the project, which may normally not be considered as part of the asset, are going to be retained and maintained as part of the ongoing maintenance of the project. See section 3.3.11., page 11, EIS-G

3.3.11. Decommissi

oning Activities

The first sentence of Section 3.3.11 of the EIS Guidelines will be revised to the following: “The EIS will describe

- offsite components of the project that are going to be retained and maintained as part of the ongoing maintenance of the project.

- the decommissioning of the temporary construction facilities and any associated reclamation.”

Decommissioning of the Project is not currently contemplated, and there is no surety that heritage resources within the proposed dam site, reservoir, and reservoir adjacent lands would survive impacts that may result from decommissioning that may be proposed in the future. Recommend that the Guidelines be revised so as to recognize that these resources will be rendered permanently inaccessible,

3.3.11. Decommissi

oning Activities

In accordance with the Effects Assessment Methods described in EIS Guidelines section 8.5.2.3, residual adverse effects on heritage resources will be characterized considering the duration of the effects. Project effects that are characterized as being for the life of the project will be considered permanent.

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Page 18 of 463 should the Project proceeds.

As the Call for Power Program is within BC Hydro‟s control, please include a section in the EIS on the estimates of potential or projected power production and the feasibility of

acquiring power from 3rd parties including Wind Generation.

4.2. Alternatives to the Project

The content requested is included in the EIS-Guidelines.

Potential future power acquisitions from 3rd parties (calls) are identified as alternatives in Section 4.2, Alternatives to the Project ("alternative generation sources to the Project") and evaluated as part of the analysis referred to in Section 4.2.2. of the EIS Guidelines.

Consider providing a section of the potential drawbacks of the project and conducting a cost/benefit analysis

5. Project Benefits

Project Benefits (EIS Guidelines Section 5) is intended to summarize the benefits of the project. The potential adverse effects are addressed in the balance of the EIS assessment sections. The content of the Project Benefits section as stated in the EIS Guidelines is aligned with Section 11 of the "Guidelines for the Preparation of an Environmental Impact Statement for the

Comprehensive Study Process Pursuant to the Canadian Environmental Assessment Act" and Section 2.7 of the "BC Application Information Requirements Template".

Please include a detailed description and summary of communications with affected tenure holders by project component.

7.1.1. Public Information Distribution and Consultation - Pre-panel Review Stage

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Where feasible, consider aligning spatial boundaries with the defined boundaries currently utilized by FLNRO and the other agencies, such as Timber Supply Areas, Wildlife Management Units, Landscape Units etc. for ease of analysis and comparison to existing data.

Some clarification here on how the LAA and RAA link to terms used in the Stage 2 reports (e.g. Peace River Corridor, Transmission Line, Inundation Zone, Regional Area) would be helpful in this section.

8.4.1. Spatial Boundaries

Where available and relevant to the land use under consideration, appropriate land use planning areas were used to define spatial boundaries (e.g., Forestry Regional Assessment Area has been defined based on TSAs and TFLs (EIS-Guidelines Section 16.3.1).

The LAA and RAA for each VC are determined based on the characteristics of the VC. The terminology used in Stage 2 reports are not sensibly "linked" to the LAA and RAA boundaries.

Consider identifying those potential mitigation measures that were excluded from

consideration that were not technically or economically feasible.

8.5.2.2. Identification

of Mitigation Measures

The EIS will present analysis of technically and economically feasible mitigation measures where appropriate. BCMFLN RO_tbl_0 23 BC Ministry of Forests Lands and Natural Resource Operations

Table 8.3 – Please provide the criteria by which the probability of the adverse impact occurring will be assessed

8.5.2.3. Characterizin

g Residual Effects

Probability of an adverse effect will be described with the precision appropriate to the level of confidence, and stated in quantitative terms where possible.

Where feasible consider aligning spatial boundaries with existing established administrative and analysis boundaries i.e. Wildlife Management Units, Landscape Units, Timber Supply Areas, etc.

See section 8.5.3.1., page 28, EIS-G

8.5.3.1. Cumulative Effects Assessment - Spatial and Temporal Boundaries

Please see response to BCMFLNRO_tbl_021

Consider expanding the Project Inclusion list to include

• existing Land Act tenures, reserves and notations of interest

• applications for land act tenures that have been “accepted” by FLNRO

8.5.3.2. The Project Inclusion List

Please refer to the Project Inclusion List section of the Topic Summary: Cumulative Effects Assessment.

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Page 20 of 463 • currently approved forestry cutting permits,

timber sale licenses, and other harvesting authorizations

• range tenures and grazing licenses

• Fort St. John Pilot Project Sustainable Forest Management Plan and Forest Operations Schedule

• Information from BC Timber Sales and major forestry licensee Annual Operating Plans where appropriate.

• Traplines and trapline cabins • Guide Outfitter areas

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Request clarification on whether the proponent is modeling landslide displacement waves, or not, and if not please provide a rationale as to why not. Consider providing information as to when, and under what sort of climatic

conditions past landslides occurred.

9.1.1. Geology, Terrain and

Soils

Section 9.1.1 of the EIS-Guidelines will include the following bullet after line 31 page 30:

"physical and numerical modelling of waves that could potentially be generated by landslides into the reservoir".

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Based on best available information on seismicity and seismic hazard, the EIS should quantify the generation and propagation of water waves ("tsunamis") that would be triggered in the reservoir by earthquakes and possibly in tandem with landslides and avalanches potentially triggered by the same earthquake. In addition, the potential impacts due to water waves generated by landslides or avalanches at other times should be

addressed.

9.1.1. Geology, Terrain and

Soils

See Topic Summary: Seismic Considerations Please see response to BCMFLNRO_tbl_026

To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of each model for the applications intended. This should include a description of the calibration and validation/verification of each model and model performance in these tests. This is of particular importance when the model used is proprietary, such as the models

HYSIM, Generalized Optimization Model, and H3D listed in Table 9.1 on p.32.

9.2.1. Surface

Water Regime

The EIS will describe the calibration and validation of models used in the assessment. Section 9.2.1, line 33, of the EIS Guidelines will be revised by adding:

"… the level of confidence".

Please provide flow patterns pre- and post-construction to a sufficient level of detail. In addition to statistical parameters (e.g. percentiles) of the flows, water levels, etc., please provide cumulative exceedance plots that would provide insights to the changes in both the diurnal and seasonal variations of the flow parameters. Alternatively, tables of statistical parameters for each month in the simulation period would provide a level of details that would be needed to understand

9.2.1. Surface

Water Regime

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Page 23 of 463 project impacts.

To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of CRISSP in simulating conditions in the Peace River. This should include a description of model performance in the calibration and verification of the stations of interest along the Peace River.

9.2.4. Thermal and

Ice Regime

Section 9.2.4, after line 33 of the EIS Guidelines will be revised as follows:

"The EIS will describe the calibration, validation, and expected accuracy of the CRISSP ice model".

To establish the credibility of modeling results, the EIS should discuss the reliability (accuracy) of the model(s) used to characterize the

potential changes. This should include a description of model performance in the calibration and validation/verification of the reach simulated in the Peace River.

ogy and Sediment Transport

Section 9.2.5, page 35, Line 25 of the EIS Guidelines will be revised as follows:

"including a discussion of model reliability " after "The EIS will present the results of predictive modelling," BCMFLN RO_tbl_0 32 BC Ministry of Forests Lands and Natural Resource Operations

In addition to the title and publication

information of a reference, the citation should include specific section and page numbers of relevance. For citations not readily or publicly available, a sufficiently detailed description on the supporting information from the citation to the issue(s) addressed in the EIS. These additional details are important and would expedite the review given the limited time available.

9.5. Environment

al Background -

References

The EIS will contain appropriate referencing to publications or technical documents used in the assessment to ensure expedient and transparent review.

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While abundance of fish is mentioned, please ensure that high data quality are collected for real comparisons to reference points based on meso-habitat scale detail. Use of models is of limited utility if there is no correlation with fish abundance or fish community composition shift.

See section 10., page 38, EIS-G

10. Fish and Fish Habitat

Effects Assessment

The potential effect of the Project on fish and fish habitat can be assessed without characterizing each and every element of the meso-habitat.

Similar to Table 12.1 (pp45), biodiversity should be included as a fish and fish habitat valued component in Table 10.1. Biodiversity is identified as a value in local Land and

Resource Management Plans.

Suggested addition to Table 10.1 line 5, pp39. Include “biodiversity” as a valued component. See section 10.1., page 39, EIS-G

10.1. Fish and Fish Habitat VC Scoping and

Rationale

Comments noted and text has been revised.

Change text, page 39, table 10.1; add biodiversity to column 4

The downstream boundary of the local assessment area where potential adverse effects will be considered is “to the Pine River”. Potential changes to downstream water

conditions (flows, turbidity and temperatures) in the Peace River are likely to extend beyond the Pine River and may have effects to species such as goldeye, walleye and flathead chub. In addition effects to fish species such as bull trout and arctic grayling originating from the Pine River that utilize the Peace River

upstream of the proposed Site C dam need to be assessed.

Suggested change to Table 10.2 (p.39 line 9): Local Assessment Area “The Peace River sufficiently downstream to capture anticipated effects of the project to fish and fish habitat” See section 10.2., page 39, EIS-G

Habitat Spatial Boundaries

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Fish species stock structure (size at age) maybe affected by the project and should be included for as a key indicator.

Suggested change to p.40 line 11:

“fish species, stock structure, community, abundance, distribution, movement and life history”

Habitat Baseline

Comments noted and text has been revised.

Change text, page 40, Line 11, bullet 1; ADD stock structure

The BC Conservation Framework as another tool to identify species of interest.

Suggested change to p.40 line 18: “Provincial Red and Blue Lists (BCMOE 2010b) and advice from the BC Conservation Framework.” See section 10.2.3., page 40, EIS-G

Habitat Baseline

Section 10.2.3, page 40, line 18 of EIS Guidelines will be revised as follows: ADD BC Conservation Framework AFTER )

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In addition to radio telemetry studies, microchemistry/genetic assessment to determine tributary origin and movements should be reported on. Suggested change to p.40 line 21:

“Peace River radio telemetry and microchemistry/genetic studies” See section 10.2.3., page 40, EIS-G

Habitat Baseline

Comments noted and the text has been revised.

Change text, Section 10.2.3, page 40, line 21: ADD and microchemistry/genetics studies AFTER studies

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Peace River baseline aquatic productivity studies

Please include clarification on if and how the following factors will be measured or not and if not please provide a rationale as to why • measuring and modeling fish production (not just biomass),

• production of the invertebrate prey trophic level, and

• primary production.

Habitat Baseline

The requested information will be described in the EIS and in the Fisheries Technical Data Reports in the EIS Appendix

Changes in key aspects of Fish and Fish Habitat should include an assessment of changes to temperature, turbidity, connectivity and physical habitat structure (river to

reservoir). Reservoirs are well documented in the literature as high risk location for the introduction of aquatic invasive species (Johnston et al 2008). They represented an altered habitat and enhanced access to recreational boaters, both facilitating the accidental or intentional introduction and establishment of non-native species. In particular the introduction of zebra or quagga mussels from eastern Canada would not only have significant impacts on the ecosystems but

10.2.4. Potential Effects of the Project and Proposed Mitigation

Comments noted and text has been revised. The new text does not specifically include risk of aquatic invasive species as a specific section topic in Section 10.2.4, however invasive species will be considered during the effects assessment and construction management planning, where necessary.

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Page 28 of 463 also dam operations. Johnson PTJ, Olden JD,

Vander Zanden MJ (2008) Dam invaders: impoundments facilitate biological invasions into freshwaters. Frontiers in Ecology and the Environment 6, 357-363.

Suggested change to p.41 line 3-4: “Fish Habitat: changes to nutrients, temperature, turbidity, physical habitat structure, abundance or composition of the lower trophic components of the food web and risk of aquatic invasive species.”

See section 10.2.4., page 41, EIS-G BCMFLN RO_tbl_0 41 BC Ministry of Forests Lands and Natural Resource Operations Suggested change:

All occurrences of “plant communities” should be replaced with the correct terminology of “ecological communities” as defined by the Conservation Data Center.

See section 11., page 41-45, EIS-G

11. Vegetation and Plant Communities Effects Assessment

All occurrences of “plant communities” will be replaced with “ecological communities” in Section 11 of the EIS-Guidelines. BCMFLN RO_tbl_0 42 BC Ministry of Forests Lands and Natural Resource Operations

RE: “Technical data will inform the vegetation and plant communities effects assessment.” To accurately analyzing and describing current baseline and future conditions the field

methods, project scale, rare data information and all appropriate data summaries by Biogeoclimatic (BEC) units need to be available for review.

Suggested addition to pp41, line 19:

Technical data will inform the vegetation and plant communities‟ effects assessment and be made available for review.

See section 11., page 41, EIS-G

11. Vegetation and Plant Communities Effects Assessment

The technical data used to inform the effects assessment will be made available for review upon request, unless the data are confidential.

Similar to Table 12.1 (pp45), biodiversity should be included as a vegetation and plant communities valued component in Table 11.1. Biodiversity is identified as a value in Local Land and Resource Management Plans. Suggested addition to Table 11.1 line 1, pp42.

11.1. Vegetation and Plant Communities VC Scoping and

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Page 29 of 463 Include “biodiversity” as a valued component.

Rationale BCMFLN RO_tbl_0 44 BC Ministry of Forests Lands and Natural Resource Operations

Reference to the specifics of temporal

boundaries is vague (e.g. RE: “8.4.2” Temporal Boundaries: The EIS will present the rationale for the temporal boundaries to be used to assess potential adverse effects of the Project relevant to each VC.). Please provide more detail.

Suggested addition to Section 8.4.2, pp25. Consider adding a table similar to Table 8.2 for Temporal Boundary Descriptions the included but not limited to the following:

i) Description of the influence of waterway fluctuation over time and the effects on natural and rehabilitated plant communities (e.g. what dynamics are expected here in terms of impacted boundaries now and how that might be different over time?)

ii) Describe the potential for mass movement over time adjacent to the reservoir due to the prevalence of glacial lacustrine silt in the Peace Lowlands which is constantly in motion and how this may have effects on natural and rehabilitated plant communities‟ boundaries in sediments that were once stable. (e.g.

perception may be that what are now upper bank grassland communities that would remain stable communities as water levels fluctuate over time).

iii) Include in this descriptive table the

perceived changes in plant communities, forest age and structure over time in management areas within the hydro right of way

11.2.2. Vegetation and Plant Communities Temporal Boundaries

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Page 30 of 463 See section 11.2.2., page 42, EIS-G

Suggest including area (patch size) in addition to distribution (distance between patches) to fully represent the spatial component, and how the extent and occurrences of these unique ecosystems are related to the RAA and areas inside and outside of the inundation zone within the LAA.

Suggest including methods on assessments of invasive plants in the 11.2 section. Section 21, Summary of Proposed Environmental

Management Plans, P 88, line 19, includes a “Vegetation and Invasive Plant Management Plan” but invasive plants are not mentioned in

11.2.

11.2.3. Vegetation

and Plant Communities

Baseline

Ecosystems will be spatially described to the extent of the habitat mapping available for use. This will be completed for those portions of LAAs where standard Terrestrial Ecosystem Mapping is available. Other habitat mapping (see response to BCMFLNRO_tbl_046) can be used for a subset of the RAA, although it is not available for the entire proposed RAA.

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Please provide additional detail and

clarification related to the application of the composite mapping.

Recommend aligning methods with BC‟s mapping standards.

Suggested clarification to be added to

preamble to bullet points starting on pp42, line 10:

Please clarify assumptions associated with composite mapping results as they relate to the interpolation of BEC Site Units from VRI

mapping based on a predetermined VRI/TEM relationship to spatially extend the TEM information as there is potential weakness here, especially when inferring structure from VRI. More specifically, please clarify the implications of application when applying composite mapping to complex versus homogeneous ecological units and please provide breakdowns of such.

Please clarify how much of the baseline information from mapped results from pure interpolation (e.g. no TEM/ ground-truthing) versus that which is TEM mapped with corresponding ground plots.

Please clarify whether the report Definition of Composite...Mapping refers to 1989

Biophysical Mapping, completed at 1:50 000 scale. That is the only 1:50 000 mapping project which may be the only one of its type for this area. The intent may be to update stand age and structure, but it‟s not clear how the matching to current biogeoclimatic site units is to be done. The Reference is (Lea, E.C., and L.E.H. Lacelle. 1989. Biophysical Habitat Units of the Lower halfway Study Area: Expanded Legend. Wildlife Working Report No.

WR-11.2.3. Vegetation

and Plant Communities

Baseline

Standard Terrestrial Ecosystem Mapping will be used for the LAA with the exception of one quarry site and some of the proposed temporary roads that are to be built during the construction phase. The broader "Composite" mapping will be used for these areas in particular, as well as helping to set the context for habitat and wildlife studies completed in a more regional setting (areas outside the LAA).

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Page 32 of 463 43.B.C. Ministry of Environment, Victoria.).

Please provide clarification as to how an X-walk from the earlier project map legend be applied to current BEC classification? See section 11.2.3., page 42, EIS-G

Please clarify what is meant by “currently designated” and how this is being assessed. Ecosystem Classification for the Boreal zone has been updated recently resulting in a revised listing of CDC Red and Blue lists. Recommend consideration of this and incorporation of this into the assessment. While all wetlands are sensitive to hydrological regime changes, some wetland types (e.g. occurring on primarily mineral soils) are more resilient than others and respond positively to restoration activities following disturbance. Bogs and fens are much more complicated and resilience depends on the extent of alteration to deep organic soils and soil ph.

Suggested change to text on pp43, line 12: Remove the words “such as wetlands”

Suggest describing rare and sensitive plants or plant communities associated with rare

features e.g. tufa seeps, springs either here or

11.2.3.1. Rare and Sensitive

Plant Communities

Currently designated refers to those ecological communities that are on the Provincial Red-and Blue lists issued by the Conservation Data Center or assigned a rank of 1 or 2 for Goal 2 under the Conservation Framework. The list as of red and blue ecological communities as of April 1st, 2012 for the ecosystems within the LAA will be used when preparing the effects assessment. The Conservation Framework rankings as of April 1st, 2012 will be used when preparing the effects assessment.

BC Hydro has received revised Ecosystem Classification and will be using it in the effects assessment.

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Page 33 of 463 in section 11.2.3.2 Rare Plants.

Please clarify what the "technical study area‟ is and how this relates to the LAA and RAA? See section 11.2.3.1., page 43, EIS-G

11.2.3.1. Rare and Sensitive

Plant Communities

A definition of the technical study area is provided in Table 8.2 on page 25 of the EIS guidelines.

Please provide additional information as to the credentials and affiliation of the indicated “rare plant specialist”

11.2.3.2. Rare Plants

The rare plant analysis work will be under the direction of a senior botanist (rare plant specialist) who meets or exceeds the following qualifications:

- 10+ years of experience conducting impact assessment rare plant studies;

- Master's degree or Ph.D. in a biologically related field from an accredited university;

- registered as a Professional Biologist with one or more of the provincial governing bodies (e.g. R.P. Bio. in British Columbia, P. Biol. in Alberta).

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Line 2: “The methods used to identify rare plants” – Please note, these references are not for identification, they are survey and collection protocols. If it is meant to be identification, then consider listing the floras to be used, as well as confirmation of the actual taxonomic

identification by an expert, and verified through the use of herbarium specimens that are correctly identified.

Line 7: Please provide clarification around the statement “...will also discuss the results of reviews of established herbarium collections that include...”? Is this verifying the specimens from the field surveys with herbarium

collections to determine the correct taxonomic name? If so, please state this clearly.

11.2.3.2. Rare Plants

The EIS will identify the locations of rare plants observed within the LAA. The methods used to conduct the rare plant field surveys will be based on the following:

- Timing (Penny and Klinkenberg 2012)

- Survey protocol and intensity (Whiteaker, et al. 1998; ANPC 2000) - Voucher collection (RIC 1999; Penny and Klinkenberg 2012)

Plant specimens found within the LAA will be identified using a variety of techniques and authoritative references. To confirm identifications, voucher specimens may be:

- keyed using various published floras (Hitchcock, et al. 1955–1969; Lawton 1971; Cronquist, et al. 1977–2005; Moss and Packer 1983; Flora of North America Editorial Committee 1993–2007; Goward, et al. 1994; Cody 1996; Douglas, et al. 1998-2002; Goward 1999);

- compared to species accounts contained in online databases (NatureServe 2011; BCCDC 2012; Klinkenberg 2012);

- compared to correctly identified specimens housed at established regional herbaria (including herbaria at the University of British Columbia, the University of Alberta, the Royal Alberta Museum, the Royal British Columbia Museum and the Canadian National Museum); and

- verified by recognized taxonomic experts.

The EIS will discuss the results of these efforts to confirm voucher specimen identifications, and will describe any taxonomic uncertainties that remain.

In addition to direct area losses, project-related micro-climate changes on plant communities in the areas proximal to the inundation zone may occur and should be assessed base on the results for section 9.3.1.

The context, or implication, of the loss of the ecological communities should be considered in the EIS report (i.e. 100% of the floodplain ecosystems will be lost, etc). A key issue is the loss of ecological function that will result from the loss of a specific ecological community (i.e. wildlife habitat; rare ecological feature - karsts; etc).

Please add “edge effect” and “loss of ecological function” to the fragmentation assessment, line 18.

Please provide clarification around the third

Any effects to the physical environment that could result in effects on wildlife or vegetation (such as micro-climate changes) will be assessed in the EIS.

The implication of the loss of ecological communities will be addressed in the assessment for the relevant VCs.

"Edge effect" and "loss of ecological function" will be addressed in the EIS with the understanding that both will be assessed in a qualitative way to assess whether a viable community will persist. "temporary" refers to both natural regeneration and rehabilitation measures and the assessment will discuss where each would occur.

The potential effects of invasive plants will be assessed for rare plants and plant communities if it is determined that a project interaction occurs in the EIS.

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Page 35 of 463 bullet point, line 20-22 “The area of temporary

vegetation/plant community disturbance will be assessed” as to whether the word “temporary” refers to these areas as undergoing temporary disturbance from which they will naturally rebound or require rehabilitation measures. Suggest including potential effects on invasive plants (occurrence, distribution, spread) and plant phenology (e.g. timing of green-up) See section 11.2.4., page 44, EIS-G

Please provide clarification or additional information on what criteria will be used to determine what the potential mitigation measure will be.

Potential mitigation measures will be determined based on a consideration of the: community being affected, nature of effect, duration of effect, timing of the effect, available Best Management

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Please ensure that the “Project Activity Zone” includes all disturbances associated with the project as identified below in comments on section 12.2.1.

The Project Activity Zone as referenced in section 11.2.4 of the EIS-Guidelines will include all direct disturbances resulting from the project.

The potential effect of loss or degradation of ecological communities is currently limited to simple accounting of the ecological

communities that may be lost (i.e. ~30 ha of the Spruce/horsetail ecological community, etc). The context, or implication, of the loss of the ecological communities is not provided (ie. 100% of the floodplain ecosystems will be lost, etc). The loss of ecological function that will result from the loss of a specific ecological community (i.e. wildlife habitat; rare ecological feature - karst; etc) is of concern.

Consider including an analysis of the above in the EIS

The implication of the loss of ecological communities will be addressed in the assessment for the relevant VCs.

Loss of ecological function will be assessed qualitatively to determine whether a viable community will persist. BCMFLN RO_tbl_0 55 BC Ministry of Forests Lands and Natural Resource Operations

Suggest including biodiversity indicators as part of your VC list. Interactions with Project Components and Activities (Table 12.1 column) – suggest including changes in habitat

fragmentation (connectivity), in addition to „change in (alteration) or loss‟ (Line 15, Table 12.1).

12.1. Wildlife Resources Valued Component Scoping and Rationale

Biodiversity will be considered in the Wildlife Resources VC.

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Consider linking Local Assessment Areas to all disturbances created by the project, not just the reservoir & transmission lines. Sections 3.3.1 through 3.3.8 identify activities that will result in the in loss of terrestrial ecosystems (habitat) and as such it is recommended that all of these areas be included in the Local Assessment Area. Disturbed areas that are not listed such as roads required for timber salvage, all

temporary workspaces required for realignment etc. should be included in the assessment Local Assessment Areas should be 4km from all disturbances due to the home range size of many of the mammals to be impacted. It is not believed that 500m would be adequate to address the potential indirect impacts of forcing displaced wildlife onto adjacent occupied habitat (individual displacement and population density implications)

Spatial Boundaries

Table 12.2 in the EIS Guidelines will be revised by the addition of the following:

"An approximate 4-km-wide corridor centred on the Peace River from Hudson‟s Hope to the Alberta border; a 1-km-wide corridor centred on the existing 138 kV wood pole transmission line from the Peace Canyon Dam to Taylor and Fort St. John; a 400 m corridor centred on roads identified for upgrading; a 1-km wide corridor centred on new roads; and a 500 m buffer around the proposed quarry and till sites "

Sensitive wildlife species of provincial or federal conservation concern are not

specifically identified except for western toad. Many of these species will be captured within key species groups, however, the following addition to the Wildlife Resources Baseline section is recommended (similar to Fish and Fish Habitat section 10.2.3):

“The EIS will identify sensitive wildlife species or species of provincial or federal conservation concern, including any species listed in the federal Species at Risk Act (SARA), and endangered wildlife species listed in the BCMOE‟s Endangered Species and

Ecosystems, Provincial Red and Blue Lists and advice from the BC Conservation Framework.” See section 12.2.3., page 46, EIS-G

Baseline

The EIS will identify sensitive wildlife species or species of provincial or federal conservation concern, including any species listed in the federal Species at Risk Act (SARA), and endangered wildlife species listed in the BCMOE‟s Endangered Species and Ecosystems, Provincial Red and Blue Lists and advice from the BC Conservation Framework.