eao response

7/29/2019 EAO Response

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File: 30050-20/NIHY-05-06

Reference: 102603

January 25, 2013

Peter Schober, PrincipalNarrows Inlet Hydro Holding Corp.666 Gibsons Way, Box 1161Gibsons BC V0N 1V0

Dear Mr. Schober:

Re: Modification of the Application Review Timeline for the Proposed NarrowsInlet Hydro Project

Thank you for your letter dated January 25, 2013, requesting the EnvironmentalAssessment Office (EAO) modify the time period for the Application review of the

proposed Narrows Inlet Hydro Project (proposed Project).

Under section 24(2) of the Environmental Assessment Act, I have the authority tomodify the time limit prescribed for the review of the Application if the review is delayed


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y p pp y

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While studies are ongoing, EAO will work with NIHH to provide the Working Group withongoing updates of the studies progress and results in order to minimize themodification to the timeline for the proposed Projects environmental assessment. EAOwill work with NIHH to ensure that additional studies are circulated to members of theWorking Group and the shshlh Nation; EAO will also encourage the Working Group toprovide preliminary comments as soon as practical so that NIHH can respond to anyissues that may arise in the Working Groups review of the additional studies. Pleasenote that EAO will be posting all relevant material related to the additional work carried

out by NIHH on our website.

At this point, it is premature for me to make a determination on the need for a formalpublic comment period on any changes to the proposed Project or any additionalstudies. This determination will be made once EAO has an opportunity to fully reviewthe additional studies and seek advice from the Working Group and others, includingthe shshlh Nation.

Should you have any questions relating to this letter please feel free to contact me at250-888-2020, or Adrienne Butler, Project Assessment Officer, at 250-387-0215.

Yours truly,

Garry AlexanderProject Lead

E l N I l t f t t di i


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Narrows Inlet Hydroelectric Project

Identification of Information Deficiencies and Show Stopping Issues in the Proponents EA Application

Wildlife and Vegetation

Information Deficiencies Show Stoppers

1. Lack of adequate baseline data for Tailed Frogs.Consequently, it is not possible to determine whether mitigationand/or compensation proposed to offset indirect Project effects(water level changes and fluctuations) is sufficient to reduceresidual effect to non-significant

2. Mitigation measures proposed for direct Project effects onTailed Frogs and Tailed Frog habitat is expensive andonerous. There is concern over whether construction canreasonably occur based on restrictions

3. No mitigation or compensation commitment from Proponentto offset Project-related habitat loss for Northern Goshawkasspecifically requested by FLNRO. The mitigation for nesting birdsis adequate but general habitat loss from Project footprint is notaddressed, and therefore a significant residual effect on thisspecies cannot be ruled out

1. Information provided and proposed mitigation for Project-related loss of Grizzly Bear habitat is not sufficient to assessspecific impacts and reduce effects to below significant.

Additionally, it is unclear whether compensation (funds forresearch) offered will benefit locally affected area and whetherthere is any mechanism to address Project-driven effectsidentified in the research.

2. The effect of the proposed level of drawdown in CC, SS andRamona Lakes on Small (highelevation) Lake Ecosystemsis not mitigable. No compensation has been proposed by theProponent to render this residual effect non-significant.


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Freshwater Fish and Fish Habitat

Information Deficiencies Show Stoppers

1. Lack of adequate baseline data and/or consideration given toProject-related effects on water quality. Specifically, methylmercury formation due to proposed flooding at CC and RamonaLakes, and acid rock drainage/metal leaching.

2. Fish bearing status of several reaches has not beendetermined. Consequently, the effectiveness of the proposedmitigation is uncertain as well as level of compensation requiredto render the residual effect non-significant.

3. Several information deficiencies/uncertainties in the IFA have

not been addressed including: effects on geomorphology,inadequate transect numbers and measurements at differentflows, extrapolation of data from one system to another, theimpact of proposed IFRs that are lower than the lowest measuredflow is unclear, not all species/life stages present in the systemare considered, and the system-specific periodicities of thespecies/life stages is not known. Consequently, confidence in theresult of the IFA is low.

4. There is uncertainty regarding the feasibility of the Projectadhering to the standard DFO ramping rates. No considerationhas been given or modelling done to address concerns around

simultaneous forced plant shut downs or plant generationchanges at the plants with lake storage.

5. Estimates of total riparian losses are not accurate and noconsideration has been given to baseline riparianvalues/conditions at impact sites. Proposedmitigation/compensation may not be adequate to reduce residualeffect to non-significant.

6. Lack of baseline data on macroinvertebrate habitat and effectof Project on stream connectivity. Proposedmitigation/compensation may not be adequate to reduce residual

1. Increase in Total Suspended Solids as a result of lakestorage. No mitigation is proposed by the Proponent (other thandilution, which is not appropriate). Post-Project TSS levels in SS,CC and Ramona systems will exceed provincial guidelines. Thiseffect can be mitigated by decreasing lake drawdown.

2. Proposed Project-related losses to fish habitat significantlyexceed those typically allowable by regulatory agencies.Notwithstanding the issues associated with the confidence in theresults of the IFA, the proposed losses to fish habitat are as muchas 85%. The question becomes whether losses of this magnitude

are able to be compensated for so that no net loss is achieved.This effect can be mi tigated by increasing the proposed IFR.


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effect to non-significant.

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