#216-45598 McIntosh Drive                Chilliwack, British Columbia               V2P 7J3            www.chilliwackfieldnaturalists.com

November 25, 2010


Kathy Eichenberger

Project Assessment Director

Environmental Assessment Office

PO Box 9426 Stn Prov Govt

Victoria, BC V8W9V1


RE: Environmental Assessment of the Proposed Statlu Creek, Tretheway Creek, Shovel Creek and Big Silver Creek Waterpower Projects by Cloudworks Energy Inc.  


Dear Ms. Eichenberger,

It was reassuring to hear you presentation at the November 3, 2010 Open House in Chilliwack.  You genuinely seemed interested in what the public had to say about these projects.  Your and Lyle Thompson’s explanation of the British Columbian and Canadian assessment processes helped us understand how increased cooperation between ministries and levels of government works to ensure that procedures, regulations and legal requirements are followed by Cloudworks to acquire environment assessment certificates.


However, as the EA assessment process presently stands, we do not believe it will protect the environmental health of the region.  Please visit this link to read Environmental Law Centre’s recent “Environmental Assessment in British Columbia” report: http://www.elc.uvic.ca/publications/documents/ELC_EA-IN-BC_Nov2010.pdf


It is our task as public to point out to you what the Application information Requirements submission is missing or what additional studies should be done.  This is a daunting task in view of the fact that a huge team of Cloudworks professional staff has worked for the last few years putting together their report.  However, this being said, the Chilliwack Field Naturalist’s Club has a number of concerns on the environmental, social, economic, heritage and health impacts of the proposed projects. 


Environmentally the adverse impacts of run-of-river (ROR) projects in general and those on Harrison Lake in particular are unacceptable to members of our club.  The scale of any project over 20 MW should be considered industrial.  Both Tretheway and Big Silver exceed this limit according to the Open House invitation and all but Statlu do according to information I copied from a BC government site available online. This information notes: Tretheway is 30 MW, Big Silver is 40 MW, and Shovel is 22 MW. A web search also revealed Pacific Greengen Power was awarded an electricity purchase agreement EPA August 3, 2010 for a Bremner/Trio 45MW (148 GWh/year) Run-of-river Project near Harrison Hot Springs.


Industrial sized projects require strict and routine oversight by governmental environmental agencies. We are especially concerned with the cumulative environmental footprint that the many ROR’s – producing or planned- will have on our province’s biodiversity. However, there is a limited ability for the vastly downsized BC ministry of environment and federal DFO to cope.


Geologically, Cloudworks states that three very short, north-trending faults are mapped on the hillside above the south side of the lower reach of Tretheway Creek (Golder 2008b).

The Big Silver Creek project area lies within a valley that partially follows a north to northwest-trending geologic structure interpreted as regional-scale thrust fault (Golder 2008c). The Shovel Creek Waterpower Project area lies within a valley that partially follows a north to northwest-trending geologic structure interpreted as regional-scale thrust fault (Golder 2008c).  In another part of the AIR there’s a table listing permits needed.  Amongst them is one for explosives.  It is concerning that ROR projects would be taking place in areas with faults. 


The adverse environmental effects of loss, fragmentation, reduced quality, introduction of invasive plants, blocked downstream movement of gravel and wood, reduced water flow, water warming and general alteration of critical habitat will cause a loss of biodiversity of all plant and animal species including listed ones. Biodiversity is the essence of environmental health.


No reclamation effort can ever replace the massive loss of riparian, wetland and forest habitat – some of it old growth- these projects will inflict.  Not only are the components of the project – intake, penstock, turbines powerhouse and tail race- going to adversely affect the habitats but also the associated and off-site project components –roads, aggregate borrowing, batch plants, Laydown areas, construction worker camps, habitat compensation areas, communication sites, air strips and barge landings- will. 


There is a huge environmental cost to these projects all of which are all located on Provincial Crown Land. We would like to know just how many hectares of land will really be bulldozed, cleared, blasted or tunnelled or otherwise altered to create 86 to 100 MW   of so-called clean, green hydro power? Where does Cloudworks plan to mine gravel? Where will all the rock and soil removed for the 1.8 km long tunnel at Big Silver be dumped?  How will deer migrate from their summer to winter-feeding grounds?  How will Mountain Goats cope with the blasting and helicopter traffic?  What of the Grizzly bears that Cloudworks didn’t even place on their study list? How about all the aquatic species not covered by DFO regulation?  Not to mention of insects, plants or small mammals overlooked on Cloudworks study lists?  These latter species are crucial to the ecosystem. The Chilliwack Field Naturalists believe the natural environment is far too complex and far too understudied for any one to possibly assess the true effects of the Four Proposed Projects.  On the record, Cloudworks Energy Inc. does not have a unblemished history for environmental compliance on its Miller and Rutherford Projects.


The economics of electricity production in BC for domestic consumption is confusing to us.  Despite efforts searching the web, we were unable to answer the question, “How many MW of power is used annually in our province, how much is presently being generated and how much of it (%) from each source i.e. hydro, wind, thermal, etc.?” Without an answer to this it is difficult to evaluate the economics. 


What web searching did reveal was there is much attention to BC energy production from many interests- private producers, multinational corporations, BC Hydro, BC Utilities Commission, BC Citizens for Public Power, Wilderness Committee etc.  Amongst other things we found and quote the following:

·         “The Province is to become a net exporter of electricity from clean and renewable resources, with BC Hydro being the aggregator and with matters regarding exports being exempt from BCUC regulation (this is a particularly notable and significant part of the law)” (http://www.bcenergyblog.com/promo/about/)

·        “On March 11, 2010, 470 days after it received proposals from 43 proponents for 68 clean energy projects, BC Hydro announced today the results of its 2008 Clean Power Call.  14 hydro-electric (run-of-river) projects were selected and will provide BC Hydro with 1,203 GWh of firm electricity per year”.

·        “Those developers with projects still remaining in the Clean Power Call who were not awarded EPA's today (there are 28) will take comfort in BC Hydro's statement that it expects to select additional projects for EPA awards in late March.”


It is our understanding that power generated by ROR is purchased by BC Hydro at a price many times above the present market value and above the cost BC Hydro incurs generating for itself. This troubles our club. 


The Cloudworks AIR lists figures of how many will be employed during construction but goes on to say that they have a (trained) work force in place. Once the projects are up and running only a trip a day (this was revealed when they spoke of use of FSR) or at most 2 people would be needed. This indicates to us that local workers will not benefit. Are we to suffer all the environmental effects but gain nothing?  


Cloudworks speaks of obtaining supplies in Harrison Hot Springs.  Are they unaware that even local residents shop elsewhere?  Harrison Hot Springs has corner stores, gift shops, hotels etc. but nothing that would be capable of supplying even the food for the work camp. Maybe one of the Cloudworks executives will stay in a Harrison Hot Springs or Mission Hotel to bring economic gain to the local community? 


None of this gives CFN confidence that ROR’s have economic credibility. Economically these four projects are not a benefit to anyone except the proponents.


 When the increased heavy truck traffic that will travel highways #1, 7 and 9 into the projects is considered, the net economic effect may be negative. In January 2008 the crossing over the Miami River on Highway 9 in Harrison Hot Springs had to be replaced.  Many people said replacement was due.   However, countless heavy trucks hauling supplies into Cloudworks Douglas, Fire, Stokke or Tipella Projects up the east Harrison FSR rumbled through town day and night prior to the problems. May have this hastened its demise?  A Harrison resident complained of being awakened in the middle of the night by heavily laden trucks at that time. Who pays for the wear and tear on the FRS’s? Cloudworks notes in its AIR that they will require overload permits. CFN is concerned. 


Recent blasting for road improvement and widening by Ministry of Forests, Mines and Lands 20 kilometres up the East and West FSR disturbed residents in Harrison Hot Springs.  Both the local Village of Harrison Hot Springs and Municipality of Kent offices received calls from upset people who wanted to know what was happening.  One local person reported new cracks in a driveway at that time.  Causality?  It could be. Proposed Cloudworks projects blasts could also disturb Harrison and Kent Municipality residents.  It is another concern for CFN.


That takes us to health.  Sleep disturbed by truck traffic is just one public health problem.  Increased truck traffic leads to reduced air quality through fumes and dust. Harrison is a Village where people walk.  Pedestrian safety becomes a hazard.  This concerns the CFN who have members living in the community.  Construction may also limit our access to parts of the watershed when we go field tripping.


What assurances does the CFN club have that all the associated and off-site project components will not result in reduced water quality?  Harrison Hot Springs draws its Village water supply directly from the lake.  Cloudworks’ June 2008 “Project Descriptions” notes it will need Authorization to Operate Sewage Disposal System (if required for a camp) (Option: new septic field discharging <22.7 m3/day to ground). With all the other projects proposed for the Harrison Watershed including the approximately 6 500 hectare Hemlock Resort Expansion of 20 000 housing units what will become of the presently pristine waters of the lake?


The projects will be entirely on Provincial Crown Land but the land is the traditional territory of several First Nations specifically Douglas First Nation, Kwantlen Nation, Sto:lo Nation and Chehalis First Nation. Will the benefits of power to the Douglas First Nation of 92 people compensate for the disturbance to traditional territories?  Cloudworks will be providing information to the First Nations, and requesting information on current and traditional uses in the respective areas.  CFN asks, “Does anyone really understand the environmental effects of the four projects and how it will impact users?” 


To close we want to share some thoughts of this year’s winner of the Governor General’s non-fiction book award, Allan Casey, author of “Lake Land: Journeys into the Soul of Canada.” He examined fresh water lakes throughout Canada and did not like what was happening. 

Casey said. “Sixty percent of (fresh water lakes) are crammed into one country and that’s Canada. People from other places are astounded by the landscape for all sorts of reasons. Canadians take it for granted. …. My parents had a small humble cabin built in sixties (on Emma Lake, ask.)  My lifetime there is fundamentally transformed by capital, money, excess materialism and irresponsible development. It really worried me.  Is this unusual or is it a more wide spread problem? …. It is the default pattern. It is very widespread,”


It is the profound wish of the Chilliwack Field Naturalists Club that the Harrison Lake watershed remains as a pristine natural area for citizens of this planet to experience.  Industrialization of the watershed is not in the best interests of British Columbians or Canadians.  Many citizens are following BC Hydro’s “power smart” guidelines.  Projections of huge electricity demands by our province seem over blown.  The Chilliwack Field Naturalists think ROR is more about the money than it is about clean energy.  Besides we believe the energy produced by ROR is anything but green and clean. 


Alan Root, world-renowned African wildlife photographer, lamented in a documentary aired by Knowledge network on November 23, 2010 that the world as he knew it is gone!  He went on to say the rate at which wildlife is disappearing around the world is terrifying.  In the name of progress (land) is paved over for shopping centres and flower farms, he stated. In Canada bird numbers have declined alarmingly in the past fifty years.  The Harrison watershed is a major migratory route for songbirds.


We are asking you, Kathy Eichenberger, as EAO Project Assessment Director, to disapprove this Application Information Requirements by Cloudworks Energy Inc. We do not think the projects at Tretheway, Big Silver, Shovel or Statlu creeks are environmentally, economically, socially, health or heritage friendly.  Thank you. 


On behalf of the Chilliwack Field Naturalists Club,


Janne Perrin