Dear Ms. Jones,

I wish to include comments regarding the environmental assessment of the proposed Site C project.

I have concerns regarding the area of consideration for the environmental assessment of the proposed Site C project.  The impacts from Site C will be far-reaching and it is important to ensure that this is recognized.  If too narrow a region is chosen it will make a visible mockery of the process.   An EA process of any merit will include the full impacts, taking into account the cumulative nature of the impacts also from previous dams on the Peace River, in a broad area range.

Impacts should include the effect on the Yellowstone to Yukon migration corridor which will be quite significant given that this is already the narrowest part of the north-south corridor.  Further narrowing of this pinch point could have devastating affects on the wildlife population which is a global effect rather than merely a localized one.  This impact should also be considered in light of climate change.  It has been well established that these migration corridors to the North will become increasingly important with climate change.

Downstream impacts due to changes in water flow need to be seriously considered.  These impacts will be significant in Alberta and the Northwest Territories and thus the area of study should include these downstream regions.  In addition to the many communities downstream that would be affected, of particular importance downstream is the Peace Athabasca Delta.  This is a site of international significance which has already felt the impacts of regulated water flow upstream with the construction of the previous dams.  Further changes to the water flow could easily exacerbate the previously felt impacts on an already very sensitive ecosystem.  In terms of cumulative impacts, the proposed Site C could be analogous to the straw that broke the camel’s back.

It should also be recognized that the downstream impacts could be far greater than simply those from regulated water flow.  It should be recognized that the slopes of the Peace River are very unstable and prone to sloughing.  There have been significant slides in the past and these are the same banks that will border the proposed reservoir and that the dam would need to be anchored to.  Just downstream of the proposed dam location, the old Alaska Highway bridge collapsed into the Peace River back in 1957.  It was anchored to these same unstable slopes and with a period of heavy rainfall the bank gave way.  It should be noted that there are currently many active slides in the vicinity of the proposed dam and its pondage.  It should also be noted that there has been considerable seismic activity in the area.  In 2001 there was an earthquake of magnitude 5.4 just downstream of the proposed location.  These considerations should be taken into account and far-reaching regions downstream, in Alberta and the Northwest Territories, should be included in the area of study.

Impacts also include the loss of prime agricultural land, presently included in the ALR.  There are over 7,000 acres of class 1 and 2 land that will be destroyed in the filling of the reservoir.  When BC is only 43% self-sufficient in vegetable production (BC-MAFF, 2006), it does not make sense to be destroying land with high capability to grow vegetable crops.  BC has only 1.5% of its land mass being class 1 or 2 and it does not make sense to be destroying what little we have.  The importance of this unique microclimate and its potential as productive farmland should be seriously considered.

The proposed Site C project was rejected by BCUC in the past for two main reasons:  BC Hydro could not justify the need for the power and BC Hydro did not adequately look at the alternatives.  Both of these criteria have yet to be met today.  The main difference today is that the provincial government has removed the hurdle of the BCUC by eliminating its oversight.

The apparent need for Site C has been a moving target.  At first Site C power was needed for export to California, then it was to power 450,000 homes, the power was then destined to the Horn River Basin to power shale gas extraction, and is now said to be needed to produce LNG to ship to China.  The need is no longer with the originally suggested targets as it was easily shifted away from those.  When the power was originally suggested to cover residential need that was based on BC Hydro’s predicted growth.  Their prediction modelling seems to be quite lacking.  Please see the following graph of BC Hydro’s forecasted domestic demand vs. the actual demand based on BC Hydro’s annual reports.

The domestic demand has actually dropped by over 5% since 2008, a far cry from BC Hydro’s predicted growth.  This raises serious doubts about the validity in their prediction of domestic demand for 2020 which is what much of their need justification was based upon.

The latest suggestion of need, to power LNG production, is essentially for BC ratepayers to subsidize the oil companies by providing them power at reduced industrial rates.  Rather than a need this would be more accurately labelled as a desire from industry.  This is not in the best interest of BC citizens but rather of the foreign owned oil and gas companies.

The second criteria that wasn’t met was in considering the alternatives.  This still seems to be the case.  We are the only country in the Pacific ring of fire to not be making the most of the geothermal resources available to us in BC.  BC Hydro speaks very little about geothermal and its potential in BC.  In addition, there are proposed wind farms, such as at Thunder Mountain, that could produce more power than Site C and have only a very small environmental footprint that are not being considered.

Finally, it should be noted that people from all across BC should have a voice and be able to attend hearings not just those in the North.  This is a megaproject in excess of $8 billion and as such will be affecting all BC ratepayers and taxpayers not just those in the Peace region.


Sandra Hoffmann, Ph.D.