Submission regarding the Bute Inlet Hydro Electric Project to the B.C. Environmental Assessment Office and Canadian Environmental Assessment Agency

February 2, 2009

As the elected representative for Electoral Area C of the Strathcona Regional District I would first of all like to thank the EAO for deciding to hold a public meeting / open house in Campbell River at our request. I hope that as this process unfolds, you will also consider public meetings / open houses on Quadra Island, on Read Island at Surge Narrows and on Stuart Island at Big Bay, as these are where the majority of the people most directly affected by this proposal either live or work out of.

To be clear at the outset, I am deeply concerned by this project overall. I will try to address the issues that we have been asked to address regarding the Terms of Reference, but I will also need to address some of the concerns of my constituents.

I am not a scientist. I do not have the expertise to address, point by point, the 68- page document released on January 19th. I am sure that it took many scientific staff in many different departments to develop the Terms of Reference. I have no staff. I am an elected representative that has represented this area, including the area of the proposal, for the past twenty years. I am familiar with the area and its spectacular beauty and know something about the wildlife that abounds there at present. I also know of the importance of this area to the people that I represent.

The government of the day has, rightfully so, invested a great deal of money into promoting small business throughout the province.

As the local government representative I have spent a great deal of my time and appropriate amounts of local government tax dollars to try to diversify our economy to mitigate the negative impacts of the downturn in the resource extraction industries that have played such a crucial role in the development of our coast and our province. The logging and the fishing industries have been severely impacted over the past decades.

To counter this decline in my constituents’ ability to make a living in the places where they live, I have supported them in their efforts to develop new ways of making a living. A huge proportion of the existing woodlots in this province are located in our area, creating truly sustainable forestry for families in the places where they live. We have allowed shellfish aquaculture and finfish aquaculture to develop in appropriate sites, employing local residents. We have a growing tourism based economy that includes ecotourism, adventure tourism, backcountry tourism, guided heli-fishing, wildlife viewing, scuba diving, recreational sport fishing, world class resorts in wilderness locations and countless other activities that depend on the nearby wilderness that we are so fortunate to have in our backyards. Your Terms of Reference must address all of the socio-economic impacts on this region; not just in general terms but specifically, case by case.

The contribution to the provincial economy of these ventures is not insignificant. The “rich and famous” have been coming here for years to recreate and many have taken up residence on a part or full time basis. They came here due to the wilderness qualities and the abundance of wildlife and the absence of industrial activity. Some places need to be left alone for all of the aforementioned to be able to exist.


I would be remiss in not bringing to your attention the motion passed by the Strathcona Regional District in the spring of 2008 that emphasizes the concerns of the Regional District regarding this project and the request for a moratorium on proceeding with any further work. I have attached the actual resolution for your information. To date this has been ignored, even though it is the wish of the only local government that has jurisdiction over the current area being studied.

I would like to go on record as expressing my continuing vocal opposition to the high-handed actions of the provincial government in taking away the ability of local governments to deal with land use issues where independent power projects are concerned, on fresh water. I am speaking of the imposition of Bill 30. Land use planning is within the jurisdiction of local government as legislated by the province. The Community Charter, which I helped to write, recognizes the respect and the autonomy with which the provincial government must give to local government. The imposition of Bill 30 was a slap in the face to all local governments in this province, and consequently to all constituents of those local governments. This will not be forgotten.

As a local government, here on Quadra Island, through the Strathcona Regional District, we entertained, supported and gave all zoning approvals to one of the first tidal generation plants in the country. We support sustainable energy production in appropriate sites. The applicants for this tidal site are to be commended for having the foresight to locate their proposal right under the existing high voltage transmission lines that come to Quadra Island from Vancouver Island. They will produce more power than Quadra Island will use when in full operation. This is the type of supportable and sustainable energy production that should have little or no environmental, social or economic impacts to our island.

If this Bute Inlet proposal were to be a project to provide power to a small community, such as the Homalco development at Orford River in Bute Inlet, with few or no additional roads, transmission lines or structures, it would be supported by all. It would get that development off of diesel power generation completely and warrant the title of sustainable energy production. This same rationale would apply, in most peoples’ minds, to other places on the coast; Hartley Bay in the Central Coast comes to mind as a recent example.

Getting back to the actual Terms of Reference regarding the very first question that we should all be considering; the Need for the project, sec.1.3.1. The first topic is the demand for electricity in B.C. At the time of year that this project will be producing power, there will be no need for the power produced; spring run-off period. So where will the power go? Will it be exported? What will be the share of the profit to the people of B.C through their government? Please include these questions in your review with actual numbers. Next on my list are the land requirements; How much land do all of the roads, diversions, structures and finally the transmission corridors actually equal? How much carbon sequestration does that amount of treed land actually represent? Actual numbers? And how much does that represent in an offset to Green House Gas emissions if it were to be replacing “dirty power” generation? How much of the power that it will replace is actually dirty in the first place? Is it to replace coal fired, gas fired, nuclear generated, biomass or what? Or is to just supplement other sustainable power elsewhere in some other jurisdiction that would like to use more power? And what about conservation? How much of our current and future needs can actually be met simple by conservation? I would like all of these questions added to your TOR with real numbers to back them up.

Under Project Benefits, sec1.3.2, you speak of seasonal employment. Are you speaking of the need to deal with the continual need to keep the right of way clear of trees and brush? If so, how do you intend to do that? Will you be using manual brushing techniques on 450 km’s of right of way or will it be done with chemical suppression? And what will the materials used to construct the transmission towers be made of? Will they be treated wood? If so, what chemicals will be used and what affect will they have on the ecosystem? I would like these questions added to the TOR.

Your last point under sec. 1.3.1 refers to social and economic benefits to aboriginal people. While this is important, what are the economic and social benefits to the non-aboriginal people of the area? What are the impacts to both the aboriginal and the non-aboriginal people of the area? I would like these very important questions added to your TOR.

Under sec 2.2.7, Local government, the three and one half lines that the TOR devotes to this are pathetic. We are the ones closest to the public whom will be most effected by this proposal and we are basically an afterthought. You did not consult us at all on the East Toba / Montrose project even though it was in the area that I represent and the project is now underway without any of our input. Meaningful consultation must be added and it must be in the communities I mentioned earlier; Quadra, Read and Stuart Islands. I would like this added to your TOR.

The transmission corridor (sec. 3.3.2) is one that many people are concerned about and I am one of them. How can you propose a 450 km. long linear clear cut in an area that depends on this scenic corridor for the livelihood of its residents and the very existence of the creatures that live there? This is unimaginable! The Minister of energy Mines and Petroleum Resources just stated in the Times Colonist on Feb. 1st, “Last month we released the terms of reference for an inquiry to look at the transmission needs of the province for the next 30 years. That will be a public, open process.” If that is the case, then why are we looking at this project outside of that process? I would like that issue dealt with in the TOR, and a specific answer to that question.

As a general comment, I see the word mitigate throughout. Mitigate means “to make less severe, intense or painful”. This is not my idea of your role. You should be making sure that this project is not severe, intense or painful to any of us or any of the creatures that inhabit the area; not to try and “mitigate” the valid concerns that you hear. With regard to the environment, if we are not more selective about what we review, we are going to “mitigate” ourselves into a compromised world that will not be able to support any of us.

I have touched upon a number of the points that I feel need to be “beefed up “ in the TOR and I know that some of them have short references later on. But they are not good enough. The burden of proof needs to be on the proponent to prove all of the points that the public has concerns about. The EAO must evaluate that “proof” and scientifically accept or deny it.

I do not feel that this process is good enough. It is only a beginning and it has gotten off to a bad start. What we really need is a full Federal Review Panel to review this project in detail. This project does not just affect the people of this area, but of the entire province and it doesn’t stop there. The impacts and implications are national in scope and will become international in scope as soon as we sell the power generated to other jurisdictions across our international border. We are going to be governed by international trade agreements and we are going to need to know all of the implications of those agreements prior to this project proceeding any further. How locked into providing power in the future to other jurisdictions will we become? At what cost to our own future needs? Please add to the TOR

We are going to need to know the cost of the power that will be generated, at what price we will be paying for it, (should we actually get the benefit of using it), and the cost to other jurisdictions. Our previously completely publicly owned power utility company generated enormous wealth for this province. How much wealth will this independent power project inject into our government coffers annually beyond the water license and other tenure fees? Please quantify these numbers in your TOR.

To conclude, I would like to mention that as the local government representative for this area, I receive all of the referrals from the provincial agencies dealing with land tenures, water licenses and investigative permits. I am very concerned by the sheer volume of these referrals and am very concerned that no one at the provincial or federal level is looking at the cumulative impact of all of these projects. So far, I am being inundated with referrals for Toba, Bute, Loughborough and Knight Inlets and many of the islands in between. I am one person trying to deal with the individual and cumulative impact of this assault on the area that I have been elected to represent. If you are going to insist on reviewing this project with the intent of moving forward then I once again request that you ask the Federal Minister of the Environment, the Honourable Jim Prentice, to appoint a Federal Review Panel to expand the process and thoroughly review all aspects of the bigger picture.

I sincerely hope that with the adoption of improved terms of reference and the review by the Federal Panel Review, the ultimate conclusion will be that this project should not proceed.

Thank you for your time.

Jim Abram
Electoral Area C Director
Strathcona Regional District

For further information, contact me at:

abramfamoberon.ark.com
250-285-3355
Box 278
Quathiaski Cove, B.C.
V0P 1N0