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Linda Jones, Panel Manager

Canadian Environmental Assessment Agency

22nd Floor, 160 Elgin Street

Ottawa ON K1A 0H3

May 30, 2012

Dear Ms. Jones,

The purpose of this letter is to provide a response to the opportunity to comment on the EIS Guidelines for the proposed Site C dam presently undergoing environmental assessment.

There are so many reasons why this dam makes no sense, that it is hard to know where to start.  Bearing the complexity of this project in mind, it is critical that the guidelines are fully comprehensive so that the far reaching, devastating consequences of this dam are taken into adequate consideration by the joint review panel.  The guidelines must incorporate the detail required to ensure that a rigorous cumulative impact assessment will be undertaken so that the true effects of this project are fully understood and contribute to the final decision.

Given that one of the guiding principles of environmental assessments is consideration of the concept of sustainability, it is essential that not only the environmental, but the economic impacts of this project be fully considered as part of the EA.  Sustainable development seeks to meet the needs of present generations without compromising the ability of future generations to meet their own needs.  Not only do the objectives of sustainable development include the preservation of ecosystem integrity, but they also include consideration of the attainment of durable and equitable social and economic benefits.  Given the present financial situation of BC Hydro (tens of billions of dollars in debt and deferral accounts), it would be imprudent of the decision-makers to allow this project to go through.

Following are a number of concerns that I present for your consideration as you rewrite the EIS Guidelines for Site C:

1.The boundaries of the study area should be set with careful consideration. There are wide-ranging cumulative effects that would be felt throughout BC and adjoining provinces and territories. Thorough consideration must be given to the full range of impacts that could result from the dam, including: cumulative effects of all past, present and foreseeable activities in the area; severance of the Yellowstone to Yukon Wildlife Corridor; and, elimination of the long term food production potential that could supply produce to northern BC and Yukon Territory.

2. The Guidelines do not adequately recognize the unique capabilities and strategic importance of Peace River Valley agriculture. The unique microclimate of the Valley, combined with the soils, make farmland in the area extremely productive. In a time when there are significant concerns about global warming and the need to protect farmland, it doesn’t make sense to wash away 13,000 acres of agricultural land.

3. The guiding principles required according to the EA Act are not adequately incorporated into the Draft EIS Guidelines, including: sustainable development; the precautionary principle; incorporation of traditional and local knowledge; and, meaningful public participation.

4.The ‘need for’ the project is inadequately justified. Premier Christy Clark recently stated that 100% of the energy from Site C is required to supply liquid natural gas (LNG) to Asia. (Vancouver Sun, Feb 15, 2012)

China recently discovered that it has the 2nd largest shale gas reserves in the world. Site C won’t be complete until 2022 at best. China will be producing its own gas by that time.

Most recently, BC Hydro has stated that is it no longer pursuing the Northeast Transmission Line  (NETL) project, stating, “…due to market conditions, the pace of natural gas industry development in northeast B.C. has been slower than expected and consequently, load requirements remain unconfirmed.”  This statement from the proponent clearly reinforces the fact that building an $8 billion dam, at taxpayers’ expense, primarily for the purposes of supplying an LNG plant is an extremely poor rationale for proceeding. Surely the rationale for shelving the NETL would apply to the case for LNG plants in Kitimat, which in turn would completely eradicate the case for Site C.

Additionally, one must consider the need for the project in light of the commitments that BC Hydro has with existing independent power producers. Presently (May 2012), turbines at some Hydro dams are sitting idle. (Vancouver Sun, May 11, 2012)

How can it possibly make sense that another dam is required in this province?

It is imperative that guidelines ensure that the foundation upon which the rationale for the dam is formed, is truly and rationally reflected in the ‘purpose of’ and ‘need for’ the dam.

5. The current draft guidelines are vague about how ‘alternatives to’ the project are to be assessed. Presently, they don’t include cumulative effects, social, heritage, health, or Aboriginal interests and rights considerations – even though these are mandatory areas for assessment. Additionally, this section needs to include the option of not proceeding with the project.

Thank you for your consideration of these concerns.