The PVEA is asking supporters to please submit a letter to the CEAA/BCEAO by April 4th with comments on the Site C Environmental Impact Statement (EIS).  Following is some background information as well as a template letter that you are free to use as a basis for your submission.  Thank you for your on-going support! 🙂

Background Information:

BC Hydro wants to develop Site C, a major dam and hydroelectric generating station on the Peace River in northeastern BC – a region already strained from bearing the burden of BC’s resource extraction industries.  The Peace is a vital agricultural region for British Columbia, providing the majority of the province’s wheat, oats, barley, canola and other important crops. Site C poses a major threat to the flourishing farm economy in the Peace, and to the food security the region helps bring to BC. Many of Site C’s impacts will be significant and irreversible.

To identify potential impacts of Site C and how to avoid or mitigate those impacts, the project is currently undergoing an environmental assessment by both BC and Canada, under the joint administration of the BC Environmental Assessment Office (EAO) and the Canadian Environmental Assessment Agency (CEAA).

BC Hydro has just released a draft of its Environmental Impact Statement (EIS), which is the information it must provide to BC and Canada on the project, including its likely environmental, social, economic and heritage effects and how to avoid, mitigate and manage those effects. The EIS is not adequate. It fails to include important information on the effects of Site C, relies on false assumptions for conclusions and uses misleading analyses that downplay potential effects.

CEAA and the EAO must consider public comments on the adequacy of the EIS. The deadline for submitting comments on it is April 4, 2013. Comments may be submitted in any one the following ways:

  1. By sending a letter to CEAA via email or regular mail, to:

Linda Jones, Panel Manager

Canadian Environmental Assessment Agency

22nd Floor, 160 Elgin Street

Ottawa ON K1A 0H3

SiteCReview@ceaa-acee.gc.ca

  1. By sending a letter to the EAO by fax or regular mail, to:

Brian Murphy, Executive Project Director

B.C. Environmental Assessment Office

PO Box 9426 Stn Prov Govt

Victoria BC V8W 9V1

Fax: 250-356-7477

  1. By filling out an on-line form on the EAO’s website, at: http://www.eao.gov.bc.ca/pcp/forms/Site_C_form.html.

You may write your own comments, use the comments suggested below, or use a combination of both.

Information on Site C, including the EIS and how to submit comments, can be found on the CEAA Registry website at http://www.ceaa-acee.gc.ca/050/details-eng.cfm?evaluation=63919.

Suggested Comments

Date [mm/dd/yyyy]

Linda Jones, Panel Manager

Canadian Environmental Assessment Agency

22nd Floor, 160 Elgin Street

Ottawa ON K1A 0H3

Email: SiteCReview@ceaa-acee.gc.ca

Brian Murphy, Executive Project Director

B.C. Environmental Assessment Office

PO Box 9426 Stn Prov Govt

Victoria BC V8W 9V1

Fax: 250-356-7477

On-line form: http://www.eao.gov.bc.ca/pcp/forms/Site_C_form.html.

Dear Sir/Madam:

RE:     Comments on Adequacy of Site C Clean Energy Project Draft Environmental Impact Statement

Please accept my comments regarding the adequacy of BC Hydro’s Environmental Impact Statement for the Site C Clean Energy Project (the EIS).

Site C will have significant and irreversible environmental, health, social, economic and heritage effects that will unjustifiably add to the industrial burden that northeastern BC already bears. Impacts of this dam will include:

  • Harm to food security, crop diversity and farming communities

The Peace is a region of exceedingly good productivity, capable of growing a broad diversity of crops and home to a rich farming community. Site C will result in the permanent loss of 6,469  hectares (15,985.25 acres) of agricultural land, 2,601 ha (6427.21) of which are Class 1 and 2 lands.

In addition to the loss above, an additional 6,290 ha, of which 343 ha are Class 1 and 2 lands, would be seriously at risk from flooding, slope instability and high waves.

Global warming is destroying and threatening traditional food producing lands in BC and around the world. As the value of potential agricultural lands that could be used for food production increases, the unique agricultural potential of the Peace must be prioritized. Also, preserving this land and the agricultural sector in the Peace would help protect the health of our communities, our economies and our families.

  • Unjustifiable cost to ratepayers

BC Hydro claims that the Site C Dam would cost $7.9 billion to construct, but it is widely agreed that the dam’s construction costs would increase to more than $10 billion due to the unstable ground around the dam and reservoir site. The cost of this project would inevitably fall on the shoulders of ratepayers in the form of higher rates.

BC Hydro has not adequately assessed the environmental, economic, social, health and heritage effects of Site C. The following deficiencies in the EIS must be addressed:

  • The potential value of agriculture is not recognized

The Peace River Valley contains its own micro-climate that provides ideal growing conditions for a diverse array of crops. The EIS does not specifically identify the areas where this unique micro-climate occurs, and so underestimates both the growing and economic potential of those areas as agricultural lands. The EIS must map the climate characteristics of the Peace River Valley to accurately account for the potential productivity of the valley and contribute to a more accurate assessment of the economic and social effects caused by flooding the Valley.

  • No description of the pre-industrial environment and effects of past projects

Both federal and provincial law require that the EIS include an assessment of the cumulative environmental effects of Site C in combination with the effects of past projects and activities in the area. Thus, the EIS must describe both the state of the environment prior to any industrial activities in the Valley as well as the effects of previously-existing projects or activities.

  • ‘Future Case Without the Project’ ignores removal of land use restrictions

If there were no Site C, there would be no flood reserve and other project-related land-use restrictions interfering with farming those lands. In order to assess the agricultural and economic potential of the Valley, the “Future Case Without the Project” must describe a future in which all land use restrictions related to Site C have been removed.

  • Assessment of downstream effects stops short of potential actual effects

Many concerns have been raised by the public, First Nations, provincial and territorial governments, Environment Canada and Fisheries and Oceans Canada regarding the need to assess the downstream effects as far as the Peace-Athabasca Delta. Currently, the EIS only describes downstream effects as far as Vermilion Chutes, Alberta – midway down the Peace River. To ensure that all potential downstream effects are considered, the EIS must describe the current conditions and potential effects of the surface water regime, climate, fish and fish habitat, wildlife and vegetation all the way to the Peace-Athabasca Delta.

  • Decommissioning and associated effects ignored

Decommissioning dams is expensive, requires considerable planning and can have significant environmental effects. For example, sediment that has become trapped behind dams can cause turbid waters, harming fish and fish habitat when released. Changing water levels can further endanger already at-risk species. Despite this, Hydro refuses to address decommissioning and associated effects of the dam and generating facilities. As decommissioning is an inevitable component of the project, it must be addressed in the EIS.

Thank you for considering my comments.

Regards,

[        Your name         ]

Address:                                 

                                

Phone:                                    

Email:                                     

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