The Mayor of Quesnel speaks out against Site C – says it threatens the viability of the industry that the town depends upon:

How Site C Will Hurt BC’s Forest Towns

Mills would face loss of biomass energy sales to BC Hydro, soaring rates.

By Bob Simpson Today | TheTyee.caBob Simpson is mayor of Quesnel and a former MLA for Cariboo North.

As the deadline nears for the provincial government’s momentous decision on whether to proceed with the $9-billion (and counting) Site C dam, one aspect of the controversial BC Hydro project deserves more attention: What do rising hydro rates and a glut of power mean for the financial viability of numerous forest companies and the rural communities they operate in?

Many forest companies produce more than just lumber, panels, pulp and pellets. Some also produce power that is sold under multi-year contracts to BC Hydro.

At present, 17 companies in B.C. produce a combined 850 megawatts of “biomass” power, or 77 per cent of the power available from Site C should that dam be completed. Those plants are diverse and include the Atlantic Power project in Williams Lake, a regionally significant thermal electric plant, and many pulp and paper mills and sawmills on Vancouver Island and throughout the Interior.

Chemical pulp mills in particular are at the forefront of forest company gains in energy efficiency and energy output, gains made largely possible by a $1-billion “green transformation” fund initiated by the federal government that assisted nearly 100 mills across the country.

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Economist Marvin Shaffer recently wrote a piece on his blog generally in support of Site C.  PVEA’s Randy Hadland, who has been involved in fighting for the Valley since the 1970’s had a detailed response.  Here are the two pieces:

http://marvshaffer-policy.blogspot.ca/2017/11/the-trade-off-government-faces-with.html

There is no ‘right’ answer as to what government should do with respect to Site C. There will be unavoidable adverse impacts if the project is completed — impacts that some First Nations and residents argue are unacceptable and unnecessary. At the same time it should be clear that there will likely be significant costs to ratepayers if the project is terminated at this time.

BC Hydro, the agency that by far has the most expertise capable of analyzing the cost consequences, calculated that terminating Site C would be some $7.5 billion (in 2018 present value terms) more expensive for ratepayers than completing the project. BCUC, based on its own set of assumptions and calculations, concluded the difference in cost would be small, within the error of the estimates, but its actual numbers also suggest that ratepayers would likely be significantly worse off if the project is terminated at this time.

After correcting for errors in its surplus sales calculations, BCUC reported that the present value cost of termination would be $295 million greater than completion. And in response to questions from the Deputy Ministers, the BCUC reported that that difference would increase to $900 million if one were to take into account the recovery of sunk and termination costs over a 20 year period in the case of termination and over the expected 70 year life of the asset if Site C were completed.

BC Hydro identified other errors in the BCUC calculations that would would increase the difference in present value cost another $500 million. And then there were the costs that the BCUC failed to take into account — the costs customers would incur for the demand side management measures it assumed would be undertaken in its alternative portfolio and the cost of advancing the Revelstoke 6 project to deal with shortfalls of peak generating capacity without Site C.

Taking those additional errors and costs into account, but otherwise maintaining all of the Commission’s assumptions about costs, surplus sales values, and load growth, assumptions that I and others believe are tilted against Site C, the corrected BCUC estimate of the cost of terminating the project would be some $2 billion greater than completing Site C.

There are of course other issues and risks to take account.

There is the risk that Site C construction costs escalate above the $10 billion BCUC assumed for its analysis. But there is also the risk that load will grow more rapidly than BCUC assumed.

There is the impact on taxpayers as distinct from ratepayers. There is a cost to taxpayers associated with the BC Hydro debt government guarantees. A question government should ask for this and indeed all crown corporation and Ministry investments is what is the magnitude of this cost — what would government have to charge in a debt guarantee fee to offset the cost taxpayers are effectively assuming. In the case of Site C the issue is how would this fee compare to the very significant water rental payments BC Hydro would pay if the project goes ahead.

There are GHG implications.  Surplus sales from Site C will reduce thermal power production and GHG emissions in neighbouring jurisdictions. Government should ask itself here what value it places on the reduction in GHG emissions that can be expected if Site C is completed. It is arguably a significant benefit of proceeding with the project.

There is the loss of agricultural land due to the flooding and related works at Site C. The Joint Review panel concluded that those impacts, while very important locally, would be relatively insignificant from a provincial and national perspective. The government should consider if and why it concludes differently.

I’ve been involved with Site C for a very long time. I was a consultant advisor to the first BCUC hearing into Site C in the early 1980’s. I testified before the recent Joint Review panel on behalf of the Peace Valley Environmental Association. I provided expert testimony for a First Nation in a Court Injunction hearing into the costs of suspending the project after one year of construction. For some time I have been an independent analyst of the consequences of terminating the project now. And this past month I wrote a critique for the Allied Hydro Council of the BCUC’s Final report on Site C.

Though people with differing views seldom accept this, in all of this work I have tried to analyze the issues and options as best and objectively as I can. All I hope is that government, however it resolves the politically challenging trade-off it faces with Site C,  does the same.

Response from Randy Hadland:

This is my reply to Shaffer on the blog he put out that is below here.  If anyone has a minute, I seem unable to publish my comments on his blog site.  Part of it is that it is too long, and I can cut it into about thirds to get it on, but it still isn’t showing up.  Any ideas?  Randy

The difference between choosing the ‘right’ answer, being to stop the construction/destruction, and the alternative, is that while it is possible to stop the dam and avoid the unacceptable and unnecessary, if the government were to choose to continue it, we would be left with the costs of the dam and the unacceptable and the unnecessary impacts. I don’t believe that you have examined the conservation/efficiency options that the Panel was presented with. There are conservation options for example that negate the need for spending any amount of money at this time and for some time in the future, either by Hydro or by its customers.
BC Hydro may, as you say, have the most expertise capable of analyzing the costs involved in Site C. However I think that saying this does a disservice to the BCUC which if you recall was set up to do this very thing the first time that Site C went to the BCUC in ’82. If it is your opinion that the BCUC is not presently qualified to examine the complexities and implications of the proposed dam then I would ask you to join with me in calling on the present government to halt the project, retool the BC Utilities Commission and have a hearing that examines the issues from an independent, qualified, and non-biased point of view. That is the crux of the matter. BC Hydro may be the most qualified, but the BCUC was set up to examine the issue, simply because BC Hydro has too many interests involved to be able to deliver an unprejudicial analysis. And we the people of BC deserve an honest and fair determination.
It would make sense that, if you have to pay off a mistake like having started Site C, and stopping construction, faster than if you pay it off over a far longer time frame just because you finished the mistake, that it would be less expensive for ratepayers. After all you can discount the 35 Billion dollars that would have to be paid in interest on the 10 Billion dollar loan. But there is no reason why you have to pay for the mistake, one way faster or slower than the other. Choosing to make the dam less expensive by arbitrarily setting a timeframe biases the decision. Not exactly an objective methodology.
Please see my earlier remarks about the relative bias of anything coming out of BC Hydro, that criticism applies also to their identification of errors in the BCUC report. It seems more objective to report on the various opinions about the correctness of Hydros opinions.

BC Hydro has always planned on completing the Revelstoke project anyway. You tried in this ‘report’, http://marvshaffer-policy.blogspot.ca/2017/11/a-report-on-bcuc-site-c-final-report.html to imply that the total costs of the Revelstoke 6 should be considered in the costs of stopping Site C. I am glad to see that it is only the costs of advancing Revelstoke 6 that is of concern to you. And since we don’t know how long that we might have before that would occur there are no measurable cost increases to apply to the termination option.
If we are going to go on and on about those, possible, errors on the part of the BCUC, why would we maintain all of the Commissions other assumptions? I and others for example see many of the assumptions being tilted towards Site C. Take for example the Sunk costs which were estimated at some 2.1 Billion dollars. Money that was spent on roads that the community can use, bridges that have as much value as was put into them, a luxurious work camp that could be bought out for far less than the cost of rent and maintenance, and serve many different purposes in the Peace region, gravel pits and other work that can be left as is for British Columbia. Or let’s consider the costs of remediation that the Panel set as an example of possible expense. Another 1.8 Billion dollars that was based on altogether too little evidence or documentation or even remediation work direction. Obviously that kind of expense is up to a question of what we choose to do. There are estimates of anywhere from 5 Million to 2.3 Billion for this work and accepting the Commissions estimate seems ridiculous unless a complete lack of common sense is prevalent.

There are other risks to consider. For example the cost might balloon to more than 12 Billion, given the geophysical problems that seems quite likely. There is the risk that demand will not grow, as the commission said, even as fast as Hydros low load growth forecast. Anf I personally would only consider that a risk if the government approves the dam. You will remember the term used in the 82 hearings, the Utility Death Spiral, in which consumers decline to purchase the power from expensive new generation projects, choosing instead to cut back on their energy use. This in turn causes the Utility to raise rates further for the usage that is still there, causing people to cut back further, and the spiral continues. That is a serious risk, given the amount that consumers can cut back if push comes to shove.
When the former Liberal government cut back on the water rental fees that BC Hydro was supposed to be paying, in part as compensation for the significant irremediable impacts of their projects on the environment and society, they laid a groundwork in which those costs would have to be collected some other way. If what you are saying is that the BC Government would have to support a loan to cover the costs of terminating Site C and that the water rentals would have covered the cost of a completed Site C, then I would suggest that this would be an inappropriate use of those funds.
Arguably would be the operative word in a discussion of whether there would be benefits from a GHG emissions point of view. For example, If as the BCUC found we can generate our own electricity supply cheaper than building Site C and cheaper than terminating Site C and including the costs with the costs of the new supply, does it not stand to reason that our neighbouring jurisdictions also have that ability? In short, what indication is there that Site C power exported would not instead subtract from alternative non fossil fuel energy development.
The Joint Review Panel, in its examination of the value of the agricultural resource in the Peace River valley, did not have agricultural expertise in its staff, and when the JRP asked the Chairman of the Agricultural Land Commission to appear before it and discuss the implications for agriculture, the Chairman was called away to ‘very important meetings’ with the then Liberal government in Victoria the day before he was to appear at the BCUC. If the present government takes the time they say they are going to take to look at issues that go beyond the set terms of the current BCUC Inquiry hopefully they will ask the Agriculture Ministry staff to review evidence such as that submitted by Wendy Holm who found that the land in the valley will be very important to all of our futures. Ms Holm came to that conclusion based on material that BC Hydro themselves prepared.
I’ve been involved with Site C for a very long time. I have been questioning the need for and the costs of Site c since the early 70’s. I do not try to be objective, that is the job of the BCUC and I hope the Government now takes the time to examine everything that comes before it. The BCUC has served us well in the past, despite making reports that contained inaccuracies, and they have done a very good job of looking at the aspects of this dam that they were asked to examine. When the Government includes in their analysis the impact that a large surplus of power in the system will have on developing a growing alternative energy industry, when they include the incredible impact that this Site C dam would have on the first Nations who have, already, suffered immensely because of our Hydro dam system, when they consider that the land in the valley could provide vegetables for more than a million people, when they consider that the biodiversity of the entire Peace valley all the way to the MacKenzie relies to some extent on the first class climate and isolation provided by the valley bottom lands, and when they consider the political fallout from approving the Liberals and our Provinces biggest mistake, I am hopeful that they will shut Site C down for good and forever.

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Hello Friends!

We are at the 11th hour of our fight to stop the Site C Dam. The BC NDP Cabinet is meeting with six advisors on the dam RIGHT NOW, and a decision is expected soon! We have deeply appreciated your support with our campaign in the past and we are hoping that at this critical time, you would be willing to undertake one or more of the actions below to make sure that when the NDP cabinet ministers return from their meeting today, their offices are flooded with messages from all of us that WE DON’T WANT SITE C!!The NDP have not yet made their final decision on Site C and we need to help build their confidence in making a decision to protect all British Columbians from this unnecessary, destructive and costly project. They need to hear from as many British Columbians as possible and feel supported in a decision to cancel Site C.

Take Action to Stop Site C Now by:

  • Go to Peace Valley Environment Association’s SiteC.RealHearings.org site to compose your letter and it will automatically be sent to all 23 BC NDP MLAs plus your MLA.
  • Go to Sierra Club BC’s letter writing site and submit a pre-drafted letter (or modify to make it your own) to key BC NDP ministers.
  • Send a short letter to all of your local papers at once through Yellowstone to Yukon Conservation Initiative’s handy web-based tool here.
  • Call any number of cabinet ministers’ offices you choose and leave a message that you want Site C cancelled through Wilderness Committee BC’s site here.
  • Share this e-mail with your friends and share our campaign posts on Facebook and Twitter.
You will find any further information you need about the issues of concern associated with Site C at this informative website. Additionally, you will learn much about the issues in our latest video:

VIDEO: Would you still build Site C?

Thank you so much for your support.  We are within reach of the finish line on this project that the PVEA has been battling for over 40 years.  The PVEA has board members who have spent their entire lives protecting the Peace River Valley and all British Columbians from Site C.  We don’t need this power, and if and when BC does need more power, there are far less destructive and less expensive ways to obtain it.

The BC NDP campaigned on the implementation of their Power BC plan. This plan includes less expensive and more effective options for addressing BC’s energy needs through building retrofits, existing hydro infrastructure upgrades, and the pursuit of solar and wind energy. Please send a letter endorsing this plan that they campaigned on and let them know that you fully support their decision to cancel this project.

For the Peace,

EPSON MFP image

Dear Premier John Horgan,

I have been told by your staff that you will pay attention to new and important information regarding Site C dam.  Here is new and important information. Please pay attention.

I am writing about extremely serious concerns regarding the safety of Site C dam that Dr Vern Ruskin,  has drawn to my attention over the course of several lengthy and extremely informative conversations. While this is late in the debate about Site C I believe we have an ethical obligation to take it seriously, apart from any political or other concerns and feelings we have about Site C.

If you are unaware of who Dr Ruskin, (PhD,MCom,BSc,Retired PEng (BC) ,PE(WA) Numbered Author) is and why you should believe him please see my NOTE below.

In 2011 there was a major design change to the original Site C dam with no evidence that it is safe beyond a shadow of a doubt. When it comes to public safety the engineering information should be publicly accessible upon request and in Dr Ruskin’s experience it is not.

It is Dr Ruskin’s professional opinion that a serious risk to public safety of the redesigned SiteC dam exists and that people downstream of the dam are at potential risk of dam failure. 

Further these risks require a second opinion by independent geo technical engineers of the re- engineering that changed the original safe design to the new potentially unsafe design.

This is the question I am now bringing forward to you to have it addressed. Can you assure me that Site C is safe beyond a shadow of a doubt?

Dr Ruskin brought these concerns forward to the recent BCUC hearings but I have been informed by the Commission secretary, Patrick Wruck, that the question of dam safety was deemed to be outside the TOR and therefore not addressed in the Inquiry. I have tried to the best of my ability to ensure that the information I am giving you has merit and deserves to be taken very seriously. I do not believe this information has reached your attention to date and I cannot in conscience fail to bring it forward.

As I understand it Dr Ruskin questions the safety, stability and costs of the redesign and why it has not been proven safe beyond a shadow of a doubt. He mentions at least three major issues:

  1. that the change from the original design to the right angle design is inherently less safe unless pinned and anchored in bedrock. (As I understand it the risk is that the force of the water could pull apart the right angle and that the margin of safety may not be adequate with the new design.)
  2. that the original design and standard engineering practice would use the island in the centre of the river as a stable anchor.
  3. that the appearances of significant unexpected tension cracks and other evidence of site instability are substantive evidence of the potential for dam failure should the project continue.

(NOTE: Dr Vern Ruskin is the engineer hired in 1955 by Dal Grauer of then BC Electric, to be Director, Planning Division with a 45 person staff and responsible for planning, designing, budgeting and contracting more than ten Dams in BC, including WAC Bennett, Peace Canyon and Site C (obviously not building) on the Peace River and 4 Dams on the Columbia River. Although he is a retired professional engineer his knowledge and experience are vast and detailed and reliable.)

Dr Ruskin’s concerns invoke the Mount Polley redesign failure with its catastrophic outcomes. I ask that you take the time and actions necessary to ascertain this dam’s safety. I believe that Dr Ruskin’s opinions are unlikely to be discredited and that his facts and analysis are unassailable. I also believe there is a need to factor in updated understandings about climate change impacts that weren’t understood or considered during the original design or the redesign.

My understanding of why he has not given up trying to be heard is that as the engineer originally responsible he could not ethically and morally leave this issue without doing everything in his power to have the engineering reviewed. Vern occurs for me as a non self serving public servant doing his best to bring very important information forward. He is 93 years old and clear as a bell!!! In my view he is not interested in being right but in doing right.

Below are the links to Dr Ruskin’s submissions to BCUC. You will see that he is repetitious and not overly organized or eloquent in his written submissions which he readily admits. Also his deafness gives oral communication special but resolvable challenges. However what he is warning about is very serious and I don’t think his warning has been heard by Government.

I started out planning to send you only a couple of files but ended up sending them all (except the second file as it is a repeat of submission 1). This information is really a shocker and is just buried in all the BCUC submissions. All the files are attached below.

I recommend starting with this file as it is the most succinct overview of the range of concerns he brought to the BCUC. However the other files contain the facts that an independent professional geotechnical engineer must review to ensure confidence in the public safety aspect of the whole Site C dam question.

http://www.sitecinquiry.com/wp-content/uploads/2017/09/DOC_90135_F26-3_Ruskin-V_Site-C-Submission_Redacted.pdf

Thank you for taking this information seriously. I have great respect for you and trust that you will do what is right and necessary to ensure the protection of public safety. Please advise me of receipt of this correspondence and if possible please keep me informed of the progress of your investigation.

Yours,

D Lynn Chapman

Roberts Creek, BC

http://www.sitecinquiry.com/wp-content/uploads/2017/10/DOC_90030_F26-1_Ruskin-V_Site-C-Submission_Redacted.pdf

http://www.sitecinquiry.com/wp-content/uploads/2017/09/DOC_90135_F26-3_Ruskin-V_Site-C-Submission_Redacted.pdf

http://www.sitecinquiry.com/wp-content/uploads/2017/09/DOC_90186_F26-4_Ruskin-V_Site-C-Submission.pdf

This is about the Columbia River Treaty…

http://www.sitecinquiry.com/wp-content/uploads/2017/10/00278_F26-5_RuskinV_SiteC_Submissions_Redacted.pdf

http://www.sitecinquiry.com/wp-content/uploads/2017/10/00279_F26-6_RuskinV_SiteC_Submissions_Redacted.pdf

http://www.sitecinquiry.com/wp-content/uploads/2017/10/00316_F26-7_RuskinV_SiteC_Submissions_Redacted.pdf

http://www.sitecinquiry.com/wp-content/uploads/2017/10/00535_F26-8_RuskinV_SiteC_Submissions_Redacted.pdf

 

The procedural integrity of the BCUC Site C inquiry requires that the BCUC disregard BC Hydro post-inquiry submissions, or give opposing parties an opportunity to respond.
Date:               November 27, 2017

To:                   Mr. Patrick Wruck, Commission Secretary and Manager, BCUC

From:              Robert H. Botterell, Botterell Law Corporation

Dear Commission Secretary Patrick Wruck and BC Hydro Regulatory Group,

Re: British Columbia Hydro and Power Authority – British Columbia Utilities Commission Inquiry Respecting Site C – Project No. 1598922

We are legal counsel for Peace Valley Landowner Association and Peace Valley Environment Association in this proceeding.

We have received a copy of the post-inquiry submission of BC Hydro Chief Regulatory Officer Fred James to the Site C Inquiry (attached BC Hydro letter to BCUC dated November 16, 2017).  Contrary to BC Hydro’s assertion, we do not agree that the letter’s content is limited to “input and calculation errors”.  The kindest interpretation of the submission is that a disappointed proponent is attempting to re-open issues earlier raised and settled in the Inquiry which closed with the Commission’s Final Report on November 1, 2017.

We have asked energy expert Robert McCullough to review the November 16, 2017 letter, and he has advised that several of the points that BC Hydro has sought to represent as neutral calculation errors are in fact points that invite substantive counter-argument and evidence, both on substantive input and methodology.  If given the opportunity, Mr. McCullough would present persuasive evidence in this regard.

For example, BC Hydro is now attempting to re-open submissions on a methodological issue—how to apportion and recover sunk costs—which is included in item “C” of page two of their recent letter. This is not simply a matter of “input and calculation”, but a substantive issue that raises a range of possible outcomes based upon which principles (relating to e.g. public finance, accounting principles, amortization) are accepted.  The consequences of these choices are significant (as evidenced by BC Hydro’s invitation to weigh a further $345 million in favour of Site C, if the Commission accepts the company’s submission.)

Re-opening an issue with such significant consequence without providing opportunity for further evidence and submission from other parties would be highly inappropriate, would undermine the fair outcome of the proceeding, and would call into question public confidence in the procedural integrity of the Site C inquiry process.

If one party is allowed to re-litigate, it is only appropriate that all parties must be allowed to do so.  It should be noted that Mr. McCullough, on behalf of our clients, has kept abreast of filings in the proceeding, and has pointed out a number of errors in BC Hydro’s submissions.  However, we have not asked the Commission for leave to reopen the errors in BC Hydro’s submissions or the determinations by the Commission based on these errors.

Please either disregard British Columbia Hydro’s out of schedule arguments, or allow opposing parties the same privileges.

Please contact me if you have any questions.

Sincerely,
ROBERT H. BOTTERELL
BOTTERELL LAW CORPORATION

Click the image below to download the November 16, 2017
BC Hydro letter to the BCUC:

For all past reports go to
www.peacevalleyland.com/sitecinquiry.

This is an urgent moment. Please consider signing onto this public letter of solidarity with the Treaty 8 First Nations and many other organizations who are fighting to protect the Peace River from the Site C dam:

https://goo.gl/forms/UqA3aGxlCI2Budk33

I invite you to stand in solidarity with West Moberly First Nations, Prophet River First Nation, the Union of BC Indian Chiefs, Amnesty International, the Peace Valley Landowners Association, the Peace Valley Environment Association, and many others who call for the immediate termination of BC Hydro’s Site C dam in Treaty 8 Territory.

Although the BC Utilities Commission (BCUC) Inquiry recently gave BC the evidence it needs to cancel BC Hydro’s Site C dam, I’m worried that a small group of long-time NDP insiders and lobbyists are working for the building trades unions and using their influence to lobby hard for the continuation of this boondoggle. Their disregard for a public and open process and the lack of consent for the dam from the most directly affected Treaty 8 First Nations, West Moberly and Prophet River, is very disappointing in this time of attempted reconciliation. We need people to understand that they do not represent the union movement, nor the sentiment of many NDP supporters.

We know that proceeding with Site C will destroy the Peace River valley and substantially increase BC Hydro’s debt load for power which the BCUC has shown we don’t need. The NDP may never recover from such a fatal error.

Thank you for considering signing this open letter.  And please share with folks who would want to sign on as individuals – your affiliation is requested only to show where you are based, not to represent your local or riding association:  To sign, click on this link:

https://goo.gl/forms/UqA3aGxlCI2Budk33

More people need to hear the perspectives and experiences of women who’ve been working hard to protect the Peace Valley and their families, such as those at: http://discoursemedia.org/gender-and-identity/women-site-c-concerns-impacts-hidden

and http://www.cbc.ca/shortdocs/shorts/peace-river-rising. Systemic colonial violence impacts Indigenous women disproportionately.

 The dam will cost BC a lot more than $10 billion through its geotechnical instability, lawsuits and the usual cost overruns that come with such mega projects. http://www.cbc.ca/news/canada/british-columbia/west-moberly-prophet-river-first-nations-warn-site-c-approval-could-lead-to-billion-dollar-treaty-violation-1.4411061

Please also consider contacting your MLA and/or your union to urge that the NDP respect the BC Utilities Commission’s findings as well as research done by UBC’s Program on Water Governance (http://watergovernance.ca/projects/sitec/) that shows how dam termination is not only viable but actually generates more long terms jobs.

Please submit your request to the BC NDP to cancel Site C here.

With all the conflicting media, it’s no wonder BCers may be confused about the basic facts surrounding the questions: do we need the energy and are we spending $10-12 billion of BC taxpayers’ money on the right project? Find the answers in the video above.