Response Records Part 2

8/2/2019 Response Records Part 2

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Russell, Veronica A ENV:EX

From: Babakaiff, Scott C ENV:EXSent: Friday, January 8, 2010 8:28 AMTo: 'Knight, Francesca'; Bennett, Timothy A ENV:EXCc: Stoddard, Erin M ENV:EX; 'Busto, Vince'Subject: RE: Ashlu long-term monitoirngAttachments: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264):

Operations Environmental Management Plan

Yall,

There seems to be two different versions of the Ashlu IPP long-term monitoring Plan floating around thereview agencies at the moment. In the process of reviewing the OPP (v.4 dated November 24 2009), Idiscovered (in Appendix E of the OPP) a long-term monitoring plan developed by Cascade Environmental(dated May 2009, submitted by Kelly Boychuk to Vince Busto). This plan was never submitted to MOE,and I didnt even know it existed until yesterday. This (again) illustrates the value in our regular & ongoingmeetings & communications regarding IPP review issues.

For the record, Chessy: I agree with your conclusions. The May 2009 plan developed by CascadeEnvironmental is lacking many critical elements of an appropriate monitoring Plan, including a poweranalysis which (I suspect) would confirm that the baseline work completed to date is far from adequate.

The Ashlu IPP long-term monitoring Plan which was submitted by Robert Kulka to MOE in November2009, and subsequently reviewed by MOE (see attached email from Tim Bennett, which was sent to theproponent a few weeks ago), was very different than the Plan submitted to DFO in May. It seems that thisis not a matter of one version superceding another, but rather that the proponent has submitted differentplans to DFO and MOE. I dont know whether the proponent has done this intentionally, believing thatone Plan would meet the needs of DFOs Authorization, and the other Plan would address Water Licenserequirements. Or perhaps the different reps for the Proponent (Kelly Boychuk & Robert Kulka) arent evenaware that the two different plans exist.

Regardless, it seems that action is required from MOE & DFO to ensure that the proponent is made awarethat:

1. a single long-term monitoring Plan should be developed to meet the needs of both DFO & MOE,and,

2. the Plan(s) in their present form are far from adequate.

Scott

From: Knight, Francesca [mailto:[email protected]]Sent: Thursday, January 7, 2010 6:54 PM

To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EXCc: Stoddard, Erin M ENV:EX; Busto, Vince

Subject: Ashlu long-term monitoirng

Hi guys,I'd been meaning to take a look at the Ashlu's long-term monitoring plan. Does anyone know who wrote the plan?After seening the Fitz creek plan, the Ashlu one leaves me wanting a bit. I believe the approach for most of theindicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusionsregarding any potential biological responses to the alterted flow regime. I'll give you a couple of examples:1. The report claims that fish population density will be evaluated, but in fact, there is no method included for

establishing a population estimate in the diversion reach. What will actually be measured is prsence/absence, whichis useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise uselessfor telling us whether the diversion has influenced the fish population. In addition, there is no method for counting


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From: Babakaiff, Scott C ENV:EXSent: Tuesday, January 12, 2010 5:15 PMTo: Bennett, Timothy A ENV:EXSubject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264):

Operations Environmental Management PlanAttachments: image001.jpg; 091214 Ramping Studies Memo.pdf

Tim,

I will include technical review of the ramping document (sent today by Innergex) along with review of thedocuments sent three days ago (which youve requested my opinion on).

Ill complete my review by Monday Jan 18th at the latest.

Scott

From:RobertKulka[mailto:[email protected]]

Sent:Tuesday,

January

12,

2010

3:39

PM

To:Bennett,TimothyAENV:EX

Cc:Babakaiff,ScottCENV:EX;XT:Busto,VinceDFOEAO:IN;[email protected];RichardBlanchet;Kelly

Boychuk;BillJohnson;MikeNelson

Subject:RE:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):Operations

EnvironmentalManagementPlan

HiTim,

FollowingupourletterdatedJanuary8,IattachedthereportofprojectEnvironmentalMonitorMikeNelson,

R.P.Bio(CascadeEnvironmentalServices)regardingtherampingstudiesdonesofar. Asperourletter,itis

recommendedto

perform

further

studies

in

late

summer/early

fall

and

we

intent

to

document

this

as

arequirement

inthefirstyearofoperation(2010)intheOEMP.

Regards,

Robert________________________________________

ROBERT J. KULKA, P. Eng . , Dip l . -W ir t . - I ng .Construction ManagerInnergex nergie renouvelable - Innergex Renewable Energy

Suite 303 - 38 Fell AvenueNorth Vancouver, British Columbia V7P 3S2

Phone:604984.8600Fax:604984.8699

Cell.:778227.0434

From:RobertKulka

Sent:Saturday,January09,20101:46PM

To:'Bennett,TimothyAENV:EX'


Boychuk;Bill

Johnson;

'Mike

Nelson'


E i t l M t Pl


4/298

HiTim,

Pleasefindattachedourresponsetoyourcommentsprovidedinunderneathemail. Iwilltrytocallyouearlynext

weektodiscussapathforward,includingoveralltimingandLTCcommissioningandoperation.

RegardsandhappyNewYear,

Robert________________________________________



Phone:604984.8600Fax:604984.8699

Cell.:778227.0434

From:Bennett,TimothyAENV:EX[mailto:[email protected]]

Sent:Friday,December18,20093:12PM

To:RobertKulka


Boychuk


EnvironmentalManagementPlan

HiRobert,

Thankyou

for

providing

your

draft

OEMP

for

our

review.

Staffhaverevieweditandprovidedthefollowingpreliminarycomments:

ReportAuthorshipunknown: Thereportshouldbepreparedandsignedbyappropriatelyqualifiedlicensed

professional(s)(e.g.,RPBio).

Fewcommitmentstofollowcommonlyacceptedguidelinesfordatacollection&analysis,despitea

proposalthatmonitoringdetailsmeettherequirementsofDFOandMOE(p.6oftheOEMP). Many

detailsproposedintheOEMPareseeminglyarbitraryanddonotreferenceanyguidelinesorstandards

typicallyreferencedbyProvincialorFederalagencies. Forinstance:

Stagedischargeratingcurves theOEMPcommitstocollectingaminimumofthreedischarge

measurementsand

warns

that

...it

is

unlikely

that

flows

will

be

able

to

be

measured

above

20%

of

mean

annualdischarge. Thereareclearandwellestablishedguidelinesfordevelopingstagedischargerating

curves(e.g.LWBCHydrometricGuidelines;B.C.ProvincialHydrometricStandards(see

http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric%20Stand

ards%20V1.0,%20March%2012,%202009.pdf)thattheproponentisrecommendedtomeet.

Reportingofstreamflowdata:theOEMPcommitstocollecttocollectflowdataonacontinuousbasis,

typicallyin15minuteintervalsandpromisesthatdatawillberecorded...andcanbeprovidedtoonsite

DFOand/orMOEstaff...forcompliancepurposes...flowdatawillbereportedquarterly. Isuggestthereis

noneedtosubmitdatatoreviewagenciesmorefrequentlythanonceperyear,butagenciesmustbe

informedwithin24hoursofanynoncompliance(e.g.IFRprovision,rampingrates),andtheproponent

mustresolvetheissueofnoncomplianceimmediately. Intermsofdatacollection&logging,Inotethatthe

BCProvincial

Hydrometric

Standards

(Section

3.2.2.3)

recommends

astage

reading

every

15

minutes,

but

advisesthat"thisisaminimumrequirement...sitespecificflowregimesmaynecessitateashorter

frequency " For purposes of verifying compliance with flow ramping requirements in fishbearing waters


5/298

shorterstagesamplingfrequency(say,10second),witha2minuteaverageforstorageinthedatalogger

(andsubmissiontoagencies). Iwouldalsorecommendthatdatabedownloadedfromtheloggerona

frequencynolessthanoncepermonth,toensurethatanyequipmentmalfunctions(e.g.batteryloss,

equipmentdamage)donotresultinlengthydatagaps. Forpurposesofgraphicalpresentationin

monitoringreports,itmaybehelpfultoapplyanhourlyaveragetothe2minutestagedata.

Developmentoframpingrates:Section12.2oftheOEMPproposesthattherampingratesshallnotexceed

29.0cmsper90minutes. Thisratewillbeestablishedduringthecommissioningprocessoftheplant,and

maybesubjecttodifferentflowconditionsinthecreek. Thisratewasbasedonthenaturalrampingrates

thathave

been

historically

observed

in

Ashlu

Creek

over

several

years

since

1991....

The

OEMP

provides

somedetailregardingproposedmethodsforestablishingrampingratesduringcommissioning,butIwould

suggestthatsuchprotocol(andsuchinterimrateslike29cmsper90minutes)shouldbeestablishedand

scientificallyjustifiedbyanexperiencedprofessional,withreferencetoestablishedagencycriteria(e.g.

DFOsdefaulthourlyrampingratesof2.5cm&5.0cmforfry&juveniles)orrecommendedguidelines.

Finally,IsuggestthatthecommitmentwithinSection14oftheOEMPtosubmittherampingratereportsix

monthsaftercommissioningrepresentsaninappropriaterisktofish&fishhabitatgiventherapidinterim

rampingrateproposedandthefishvaluespresentinthediversionreach.

FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfordata

collectionoranalysisareproposed,despitethebibliographicreferenceinSection16oftheOEMPto

Hatfield&Lewis(2007). The MOEESDinformationchecklistprovidedintheProvincialIPPGuidebookalso

providessupplemental

guidance

for

OEMP

development.

It

is

my

understanding

that

the

baseline

biological

datacollectedinrecentyearsdidnotfollowanyparticularprotocol,butwasundertakenbyseveraldifferent

biologistsindifferentlocations,usingdifferentmethods. Assuch,itisimperativethatallbaselinedatabe

collatedandassessedbyaprofessionalbiologistwithexperienceintherelevantspecialization(ie.fisheries

biology,macroinvertebratebiology),andcompiledforassessmentregardingitsadequacyasabaselineto

assessfuturechangesthatmaybeattributabletooperationoftheIPPfacility.Onthisnote...

Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g.

durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,aprioriagreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory

measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.) cannotbe

objectivelyconsidered

without

preliminary

analysis

of

baseline

data,

including

statistical

power

analysis.

In

theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I

havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany

diversioninducedchangesinthesebiologicalresponsevariables.DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith

textinthebodyoftheOEMP. Forinstance,page3oftheOEMPclearlystates:InthecaseoftheAshlu

Project,baselinestudieswerecarriedoutfrom2001to2006,aperiodoffive(5)yearsandweredoneprior

tothenewProvincialguidelines(HatfieldandLewis,2007);therefore,notallofthecriteriaoutlinedinthe

guidelinesforcontrolsiteshavebeenimplementedduringthesepreviousstudies. However,monitoring

proposedforsomecomponents(e.g.biologicalcomponentsfromTables35oftheOEMP)havebeencopied

verbatimfrom

the

guidelines

(which,

incidentally,

are

not

referenced

correctly)

and

subsequent

case

study

(TroutCreek),soitisunclearwhataspectsofthemonitoringcriteriawillorwillnotbeundertakenperthe

OEMP.

Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated. For

instance:

installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentofassociated

ratingcurvesforwaterflow(Section4)andinstreamflow(Section11)monitoring;

Collectionofstreamchannelmorphologydata(perSection10oftheOEMP). ThiscomponentoftheOEMP

isparticularlyilldefined:therearenoexplicitguidelinesorstandardsreferenced,andIalsoquestionthe

proposedbenefitsofcompletingrepeatsurveysatafewtransectstoassesswhethertheIFRisaffectanyof

thefish

habitat

as

was

originally

predicted.

Assessment

of

changes

in

channel

morphology

related

to

projectoperations(e.g.flowdiversion,changesinsedimentandLWDtransportratesandvolumes,etc.)is

crucial but should be considered more holistically using lowlevel air photos and longitudinal survey


6/298

monitoringprograms(ie.afluvialgeomorphologistorriverengineer)betaskedwithdevelopingthestudy

designandundertakingtheworkpriortofinalcommissioning;

IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE?

Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff.

Regards,

TimothyBennett,M.Sc.,P.Eng.

SectionHead,WaterAllocation

WaterStewardshipDivision

MinistryofEnvironment

10470 152Street,Surrey,BCV3R0Y3

Ph.(604)5825227 Fx.(604)5825235

[email protected]

From:RobertKulka[mailto:[email protected]]

Sent:Friday,November27,20093:04PM

To:Bennett,

Timothy

A

ENV:EX


Boychuk

Subject:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):OperationsEnvironmental

ManagementPlan

HelloTim,

Attachedarethefollowingfiles:

RevisionBoftheOperationsEnvironmentalManagementPlanfortheAshluCreekproject.

JpegfileofthemonitoringmapshownasFigure1intheOEMP.

Coverletter

regarding

submission

of

the

OEMP.

Hardcopiesareinthemailtoyou,toScottBabakaiff,andtoVinceBusto. Pleasecontactmeifyouhaveany

questions.

Regards,

Robert

________________________________________

ROBERTJ.KULKA,P.Eng.,Dipl.Wirt.Ing.ConstructionManagerInnergex nergierenouvelable InnergexRenewableEnergy

Suite303 38FellAvenue

NorthVancouver,BritishColumbiaV7P3S2

Phone:604984.8600Fax:604984.8699

Cell.:778227.0434


7/298

30 Gostick Place | N. Vancouver, B.C. V7M 3G3 | 604.980.6011 | www.nhcweb.com

water resource specialists

December 9, 2009

ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP

Suite 303 38 Fell Avenue

North Vancouver, BC V7P 3S2

Attention: Mr. Robert Kulka, P.Eng.

Via Email: [email protected]

Subject: Ashlu Creek IFR Flow Measurement Revision B

Northwest Hydraulic Consultants (NHC) is pleased to submit the following results from our November

26, 2009 survey at the Ashlu Creek Intake Site. The purpose of the survey was to measure flow through

the downstream end of a steel pipe installed within the abutment of the sluiceway designed to provide

instream flow release (IFR) for the project.

Background (from email provided by Ashlu Creek Investments)For the Ashlu Creek Project the Department of Fisheries and Oceans (DFO) Authorization calls for a

minimum IFR of 2.42 m3/s. In order to provide a reliable means for the IFR a 30-inch steel pipe was

installed within the abutment wall of the sluiceway. The pipe inlet can be controlled with a handoperated knife gate valve located downstream of a coarse trash rack. The pipe was designed to provide

the IFR at the lowest head pond operating level (the elevation of the pipe CL is 272.0m and the head

pond operating level is between 275.5 to 276.5m net head of the pipe inlet is between 3.5 to 4.5m).

Flow calculations were provided to the DFO. The objective of these measurements was to confirm the

release.

Field MeasurementsOn November 26, 2009 NHC met on-site, Photograph 1, to measure IFR flows at the downstream end of

the 30-inch pipe using a Pitot tube. Velocities were measured from above through the centerline of the

pipe. It was assumed that flow at the end of the pipe was fully developed and any blockage effectgenerated by the Pitot tube and support structure was insignificant. Results from the survey indicated

that both assumtions are reasonable. Photographs on the following page illustrate the site, flow

conditions, and measurement approach.

Flow measurements were recorded along the centerline of the pipe for two conditions. The first set of

measured velocities were recorded with debris located in the vicinity of the entrance to the pipe. The

velocities indicated that the discharge was approximately 15% below the minimum IFR of 2.42 m3/s.

The initial results prompted the operators to sluice the approach channel. The velocity measurements

Page 7FNR-2011-00265 Part 2


8/298


December 9, 2009 Revision B

Page 2

were then repeated and the discharge through the pipe exceeded the required IFR by approximately

20%. Both sets of measurements were compared to theoretical velocity distributions and presented in

Figure 1 and Figure 2 on page 3.

Headpond elevations were recorded through the day and varied between El. 276.03 m and El.

276.08 m.

Photograph 3 View of the IFR from above Photograph 4 Measurements were

recorded using a Pitot tube.

Photograph 1 Overall view of the project site

(Photogragh provided by Innergex)

Photograph 2 View of the IFR from

downstream of the 30 inch pipe.

IFR Pipe Outlet



9/298



Page 3

Velocity measurements are considered accurate to within 3% and the locations are accurate to within

5mm.

Water levels were also recorded downstream of the inlet structure. During the first series of velocitymeasurements the water level downstream of the inlet gate was at El. 274.40 m while the head pond

was at El. 276.08m, a loss of 1.68m (discharge of 2.05 m3/s). Following sluicing of the debris, the

water level downstream of the trash rack was El. 275.76 m while the head pond dropped slightly to

El. 276.06 m, a loss of 0.30 m (discharge of 2.90 m3/s).

Figure 1 Measured and theoretical velocity

distribution. Discharge = 2.05 m3/s

Figure 2 Measured and theoretical velocity

distribution. Discharge = 2.90 m3/s

Figure 3 Based on the measurement

recorded on November 26,

2009, the water level

downstream of the inlet gate

must be at El. 275.00 m to

drive 2.42 m3/s through the

IFR pipe



10/298



Page 4

IFR Inlet Gate OperationAt water levels above 275.3 m the well maintained IFR system will discharge flows greater than

2.42 m3/s. To reduce losses the IFR inlet gate could be operated to manage the release. Due to the

interaction between the trashrach, inlet gate, and pipe entrance it is difficult to calculate precise

operation of the gate. However, assuming a loss gate coefficient of 0.61 an estimated (losses could

vary by about 10% to 20%) gate operation scenario is presented in the following table.

DownstreamofTrashRack

275.1 274.8 fullyopen 100%275.2 274.9 fullyopen 100%275.3 275.0 fullyopen 100%275.4 275.1 0.1 79%

275.5 275.2 0.2 75%

275.6 275.3 0.3 71%

275.7 275.4 0.4 68%

275.8 275.5 0.5 65%

275.9 275.6 0.6 63%

276.0 275.7 0.7 61%

276.1 275.8 0.8 59%

276.2 275.9 0.9 57%

276.3 276.0 1.0 56%

276.4 276.1 1.1 54%

276.5 276.2 1.2 53%

276.6 276.3 1.3 51%

276.8 276.5 1.5 49%

277.0 276.7 1.7 47%

Assumed the h eadl o ss through the trash rackis a constant0.3mIF RIn l etGate openingis effectively1.2mhighby1.0mwideAssumed IF RIn l etGate l o ss coefficientis 0.61

OperatingRange

GateOpening(%)

HeadLossAttributedtotheIFRInletGate(m)

WaterSurfaceElevation(m)Forebay

* * *

We appreciated this opportunity and look forward to the opportunity of working with Ashlu Creek

Investments and their partners in the future. Please do not hesitate to contact me directly in NHCs

Vancouver office at (604) 980-6011 or via email at [email protected] if you have any questions.

Sincerely,

northwest hydraulic consultants

original signed

Kenneth J. Christison, P.Eng.

Principal

Page 10FNR-2011-00265 Part 2


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January 8, 2010

Tim Bennett, P.Eng.Section Head - Water AllocationMinistry of Environment10470 152nd Street, 2nd FloorSurrey, BC, V3R 0Y3Tel: (604) 582-5235Email: [email protected]

Re: Ashlu Creek Green Power Hydroelectric ProjectResponse to Comments on Operations Environmental Monitoring Plan

Dear Tim;

The Ashlu Creek Investments Limited Partnership (ACILP) acknowledges receipt of your emaildated December 18, 2009 regarding the Ministry of Environments (MOE) comments toACILPs Operation Environmental Monitoring Plan (OEMP) Revision B for the Ashlu CreekGreen Power Project (the Project) near Squamish. The following are our responses to yourquestions, in the same order as they were presented.

Background

For reference purposes, the baseline studies for the Project were performed in 2001 to 2004. Atthis time, MOE (then known as the Ministry of Water, Land and Air Protection) was acting as areferral agency for environmental issues but not providing any direct comments to ACILP; theDepartment of Fisheries and Oceans Canada (DFO) was ACILPs primary contact for allfisheries-related baseline study input, and DFO referred information to MOE on an as-needed

basis. Therefore, ACILP had no direct communication or referral interaction with MOE.

For the preparation of the Canadian Environmental Assessment Act (CEAA) screening report,DFO acted as the lead federal agency, and included MOE in its referral (refer to Section 3.3.2,Provincial Agencies on page 7 of the CEAA and All proposed hydro facilities are referred tothe BC Ministry of Water Land and Air Protection (WLAP) by LWBC for comment). The CEAAreport was signed off by DFO on October 18, 2004. DFO issued the Fisheries Authorization forthe project on July 31, 2006 based on the CEAA report and the baseline information provided byACILP.

1. Report Authorship Unknown

The OEMP (Revision B) was based on ACILPs Five-Year Post-Construction MonitoringPlan (2010 to 2014) that was submitted to DFO on May 18, 2009. The document wasprepared by ACILP based on several post-construction monitoring reference documentsprovide to ACILP by DFO and on environmental baseline studies and data collection thathad been performed by Tom Cleugh, RP Bio., in 2001 to 2004 (while with Sigma

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Page 2

Engineering Ltd.) and in 2005 to 2008 (while working independently as TRC BiologicalConsulting Ltd.).

The next revision of the OEMP will incorporate the comments presented by MOE and will besigned by Mr. Bill Johnson, RP Bio., of Focus Environmental, Inc. Mr. Johnson is qualified,licensed professional biologist.

2. Commitments to Follow Guidelines for Data Collection and Analysis

a. Stage-Discharge Rating Curves

Stage discharge curves are developed in accordance with the guidelines referred to inyour email dated December 18, 2009 (LWBC Hydrometric Guidelines; B.C. ProvincialHydrometric Standards). The next revision of the OEMP will be adjusted accordingly.

b. Reporting of Stream Flow Data

Recording frequency of data logged at the powerhouse and intake PLC since start ofcommissioning is every 60 seconds (total creek flow at intake, IFR flow, diverted/plantflow). Recording frequency of data logged with stand alone data logger(s) is currently 15minutes and this particular equipment is unable to average data and has limited storagecapacity. We have now ordered new logger(s) in order to follow you recommendationfor shorter sampling frequency (10-second) and recording of averaged readings (every 2minutes). The new equipment will be installed upon availability (expected to be no laterthen end of February). The revised OEMP will follow your recommendation for reporting(regular reporting to agencies once per year, reporting of non compliance within 24hours and confirmation that non-compliance has to be resolved immediately).

c. Development of Ramping Rates

ACILP has sent a Plan to confirm Ramping Rates to DFO prior to commencing wetcommissioning; the plan was copied to Independent Engineer George Steeves and toTransport Canada, Navigable Waters Protection Division because of TCs interest inramping rates as referred to in the DFO Authorization (see enclosed letter dated October14). TC confirmed the plan during a site visit on November 30. The other recipientshave not formally responded to the plan. The plan was developed in consultation withthe Environmental Monitor (Mike Nelson, R.P.Bio., Cascade Environmental ResourceGroup, Squamish) and can be summarized as follows:

Preset plant control system to ramping rate suggested in DFO Authorisation;

Identify, survey, and mark specific areas that could be impacted by ramping, suchas side riffles and pools along gravel banks and similar areas where fish could

potentially get stranded if water levels change too rapidly (done by the EM in theweek of October 5th, 2009)

During ramping, continuously survey marked areas by qualified personnel (allpersonnel was provided and directed by the EM);

Ramping tests were performed in stages as follows:1. 0 -> 2 -> 0 cms (ramp up in 10 minutes, hold 10 to 30 minutes, ramp down

in 10 minutes);

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Page 3

2. 0 -> 5 -> 0 cms (ramp up in 15 minutes, hold 10 to 30 minutes, ramp downin 15 minutes);

3. 0 -> 10 -> 0 cms (ramp up in 30 minutes, );

4. 0 -> 15 -> 0 cms (ramp up in 45 minutes, );5. 0 -> 20 -> 0 cms (ramp up in 60 minutes, );6. 0 -> 25 -> 0 cms (ramp up in 75 minutes, );7. 0 -> 29 -> 0 cms (ramp up in 90 minutes, );

Between each step the adequacy of the ramping rate was confirmed by the EMbefore proceeding with the next step;

The EM is currently finalizing his report on the ramping and the report is expected to beavailable early next week and will be forwarded to you promptly. The report will confirmthat the ramping rates are in general adequate to prevent fish stranding. However, thereport will recommend to conduct further ramping studies during in late summer and/orearly fall 2010 when fry are in the system and water levels are somewhat reduced, to

elucidate the potential for stranding when fish are less mobile. The next revision of theOEMP will require conducting this study in the first year of operation and adjustment oframping rates if determined by this study. ACILP plans to contract the environmentalmonitoring component during those tests to Cascade and a similar report will be issuesafter completion of the tests. Notice will be given to MOE and DFO prior tocommencement of tests and the report will provided to both agencies.

d. Fish Abundance

The revised OEMP will provide reference to provincial data collection protocols andanalysis standards such as Resource Inventory Committee Standards (RISC) and otherprovincial standards as they apply to various disciplines. Many of these protocols andstandards pre-date the current project. Although the baseline studies completed todate were compiled by various professionals, it is ACILPs understanding the datacollection and analysis was completed using appropriate standards at the time. It isACILPs intention to have all of the baseline material reviewed by qualified professionalsat the time the data of the first year of operation becomes available (say late 2010) andrequires comparison with the base line data.

3. No Baseline Data or Power Analysis

The original baseline data was collected between the period of 2001 to 2004, and thepermits issued by the various federal and provincial environmental agencies were based onthis data. Additional data continued to be collected during the 2005 to 2006 period while theproject was awaiting the results of the regulators, as ACILP took advantage of this waiting

period to continue to build a database of various baseline data (i.e. water quality,temperature). In addition, some pre-operation baseline data continued to be collected in2007 to 2008 during construction of the project.

It is ACILPs intention that all of this collected data be considered as baseline data forreference during the operational years of the project. However, ACILP is cognizant that therequirements for baseline data for Independent Power Projects (IPPs) have been evolvingin British Columbia over the past decade. As more IPPs are developed, the federal and

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Page 4

provincial review agencies, as well as qualified licensed professional biologists, have moreoperating projects to observe and study, and hence the existing regulations and baselinerequirements are modified and expanded upon. For the Ashlu Creek project in particular,

there have been two modifications to MOEs guidelines for IPPs (in 2004 and 2007) thathave set new standards and require more information to be collected. As such, some of thedata collected years ago for the environmental baseline may not match with the latestversion of MOEs requirements; however, it is ACILPs intent to comply with the lateststandards wherever possible.

We have carefully reviewed the OEMP with regards to your comments that some referencesin Tables 3 to 5 were not done properly as well as one reference to Trout Creek. We havenot found any inconsistency in those references or any reference to Trout Creek itself;however, we will ensure that references in the next revision of the OEMP will be scrutinizedand explanations provided where potential for misinterpretation may arise.

4. Details of Monitoring Commitments

The details of monitoring commitments are currently under review by Bill Johnson and thenext revision of the OEMP will elaborate on this issue to provide clarity.

5. Pre-Diversion Activities Yet to be Initiated

a. Installation of Four Pressure Transducers

With regards to the actual stations we provide the following information and updates:

Intake: Three submersible pressure transducers are installed in the head pond atvarious locations and readings are continuously logged in the powerhouse. The

total creek flow is calculated as the summary of the diverted flow (as determinedby turbine flows and tail race flow), the IFR flow (see below) and the flows spillingthrough the sluiceway and the spillway. The latter two have known flow dischargecurves due to their designed geometry. Staff gages are installed at severallocations to verify the transducer readings;

IFR flow: Low flows in the Ashlu at the intake area typically range between 5 and10 cms while the minimum IFR as per the DFO Authorisation is 2.42 cms.Measurements near the IFR and establishing a Flow Discharge Curve (DFC) inthe range of highest interest (say 2.5 to 5 cms) were therefore not possible prior toreducing natural flows through headpond filling and diversion. During the firsthead pond filling on March 11, 2009 the EM measured flows at the most suitablelocation approximately 250 meters downstream of the intake area and installed

fixed marks for the measurements corresponding 2.45 cms and 3.52 cms. Apressure transducer was installed at his location in early October 2009 prior tostart of wet commissioning. Correlation of the transducer readings to the marksset by the EM was not possible due to the high natural flows in the creek andconsequently submergence of the marks (flows were approximately between 15and 200 cms). During the early stages of wet commissioning it became evidentthat the calculated flow through the IFR pipe did not correspond with the marks

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Page 5

set by the EM in March, with the EM marks being more conservative (i.e. IFRflow was estimated at 5cms while the marks indicated 2.5cms). The EM tried toperform additional flow readings in November, but was unable to produce reliable

results due to the site conditions. ACILP discussed options to reliably measureand confirm IFR flows with Ken Christison, P.Eng. of North West Hydraulics. OnDecember 3, 2009 Ken performed measurements of the pipe flow at the outlet ofthe pipe with a Pitot Tube. Those measurements confirmed the theoreticallycalculated discharge of the IFR pipe (3.0 cms at normal operating water level of276.0 m). The probe downstream of the intake was then calibrated based on themeasurements made by NW Hydraulics at the pipe outlet. The correspondingreport is enclosed to this letter. We believe that the measurements taken at theIFR pipe outlet are more precisely then the measurements taken with a propellertype submersible flow meter in a rough cobble/boulder type creek bed such aspresent in the area downstream of the intake. ACILP is in the process of installingone additional pressure transducer between the IFR pipe inlet trash rack and inlet

gate in order to ensure that plugging of the trash rack is detected prior toimpacting the flow through the pipe. The probe downstream of the intake willcontinue to measure and record the IFR flow;

Mile 25 bridge station: This station has an established FDC that was developedover a duration of more then 10 years and has seen very little change over time.A staff gage has been installed in September 2009 to visually verify the flows. Aprofessional flow metering crew from Via-Sat was on site on December 15 and 16,2009 to extend the lower end of the DFC and to ready the station for the winter.ACILP will continue to service this station and verify the DFC;

Powerhouse tail race: A pressure transducer reads the water level in the tail race.The tail race can be considered a sharp crested weir with a known FDC. Thedischarged flows measured in the tailrace correspond to the estimated turbine

flows of the plant. Index testing of the turbines has not been performed yet due tolack of water. Once index tests have been performed those results will be used toconfirm the discharge through the tailrace.

b. Collection of Stream Channel Morphology Data

Stream channel morphology was considered by ACILP during the baseline datacollection process; however, it was deemed to be an overall minor factor due to theextensive length of the bypass reach that is contained within the natural granite canyonof Ashlu Creek. Approximately 80%, or 4.4 km of the 5.2 km long bypass reach, iswithin a bedrock controlled canyon; only the initial length of the bypass reach near thewater intake is in a soil (and thus more erodable) environment.

Downstream of the bypass reach is the Ashlu delta, which is a 3 km long deposit ofsediment that exits from the Ashlu canyon and terminates at the confluence with theSquamish River. Along this delta, Ashlu Creek constantly is changing its form andorientation as it behaves like a low energy, meandering channel compared to the highenergy creek in the diversion reach. Storm events frequently cause changes in thedelta, and ACILP has witnessed several changes over the period since 2001. DFOpersonnel, who have constructed a weir and fish habitat off of the Ashlu delta, have

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Page 6

been cognizant of these changes in the delta as well. Hence, ACILP has not proposedmonitoring these natural changes as they are frequent and are influenced by periodicstorm events.

As a result of this, ACILP identified three main areas of potential change in streamchannel morphology: headpond filling, side channel filling at the gravel bar in the AshluCanyon (at km 2.0), and downstream of the tailrace. These areas are proposed formonitoring in the OEMP as they are directly related to the activity of the project.

ACILP agrees that a fluvial geomorphologist would be best suited to perform this work.

6. OEMP Submission to DFO

ACILP provided DFO with its Five-Year Post-Construction Monitoring Plan (2010 to 2014)on May 18, 2009, and the OEMP (Revision B) was based on this document. ACILP hadsent a copy of OEMP (Rev B) to DFO at the time it was submitted to MOE. However, weunderstand that MOE referred Revision B to DFO for comments and the comments receivedin your email dated December 18, 2009 may have DFO contribution. Therefore we assumethat DFO will not provide additional comments to Revision B directly to ACILP. Weunderstand that MOE may at its discretion continue to engage DFO in the currentdiscussions any may choose to refer Revision C to DFO. Therefore, ACILP does not intendto directly issue future revisions of the OEMP directly to DFO except MOE or DFO advisesus to do so.

If you have any further questions or comments, please feel free to contact myself at 604-984-8600.

Sincerely,

Innergex Renewable Energy Inc.

Robert Kulka, P.Eng.Construction Manager

Cc. (per email only): MEO: Scott Babakaiff, Fish Protection HydrologistDFO: Vince Busto, P.EngACILP: Richard Blanchet, Kelly BoychukGeorge Steeves, P.Eng., Independent Engineer MOE

Mike Nelson, R.P.Bio, Environmental Monitor (Cascade Environmental)Bill Johnson, R.P.Bio., Focus Environmental, Inc.

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October 14, 2009

Fisheries and Oceans CanadaHabitat and Enhancement Branch, Lower Fraser Area100 Annacis ParkwayNorth Delta, B.C. V3M 6A2Attention: Vince Busto, B.A.Sc., P.Eng.

Re: Ashlu Creek Green Power Hydroelectric ProjectPlan to confirm Ramping Rates

Dear Vince;

Pursuant to the requirements of DFO Authorization N. 04-HPAC-PA2-000-000530 (theAuthorization), ACILP provides the following plan to determine ramping rates during

commissioning:

The EM has in the week of October 5th surveyed in preparation of commissioning the areasidentified as fish community in the 5 year post construction monitoring plan (Revision Asubmitted to DFO on May 19, 2009) and marked specific areas in the field that could beimpacted by ramping rates. Those are mainly side riffles and pools along gravel banks andsimilar areas where fish could potentially get stranded if water levels change too rapidly. Duringcommissioning, the diverted flow will be gradually increased and decreased in several steps atthe ramping rate suggested in the Authorization. During each step, the EM will survey themarked areas and observe the impact of the ramping. It is the goal to confirm that thesuggested ramping rate is adequate for all lower and medium creek flow conditions and that ashorter ramping rate may be adequate for higher flow conditions.

ACILP believes that the then established ramping rate will also be adequate to meetrequirements of the project approval provided by Transport Canada, Navigable WatersProtection Division with regards to safety of recreational users of the Ashlu Creek.

If you have any questions or comments regarding this plan, please contact the undersigned.

Sincerely,

Innergex Renewable Energy Inc.

Robert Kulka, P.Eng.Construction Manager

Cc. (per email only): DFO: Francesca Knight, M.Sc., R.P.Bio.TC/NWP: Shannon Vollema, NWP Area OfficerACILP: Richard Blanchet, Kelly BoychukEM (Cascade): Mike Nelson, R.P. Bio, Hilary Lindh, R.P. Bio.George Steeves, Independent Engineer MoE

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From: Babakaiff, Scott C ENV:EXSent: 010 4:11 PMTo: Subject: ashlu

Tim,

As per your request, Ive reviewed three reports submitted to MOE by the proponent for the Ashlu IPP intwo emails dated January 9 & 12 2010:

1. Ashlu Creek Green Power Hydroelectric Project: Response to Comments on OperationsEnvironmental Monitoring Program prepared by Robert Kulka (Innergex Renewable Energy Inc.),for Tim Bennett (MOE-WSD), dated January 8 2009, 6 pp. Referenced hereafter in this review asKulka (2010);

2. Ashlu Creek IFR Flow Measurement prepared by Northwest Hydraulic Consultants Ltd for AshluCreek Investments Limited Partnership, dated December 9 2009, 4 pp. Referenced hereafter in thisreview as NHCL (2009);

3. Ashlu Creek Flow Monitoring During Ramping prepared by Cascade Environmental ResourceGroup Ltd for Innergex Renewable Energy Inc, dated December 14 2009, 6 pp. Referencedhereafter in this review as CERG (2009).

A few notes: I am not reviewing the October 14 2009 letter sent by Robert Kulka to DFO regarding the proposed

ramping strategy undertaken per report #3 above (which was also included in the January 9 2010email); I was not provided the opportunity to review the proposed ramping work prior to itscompletion, and since the work has already been completed, provision of review comments nowseems redundant.

Ill refer to the proponent in this review simply as the proponent, since the reports seem to useInnergex Renewable Energy Inc & Ashlu Creek Investments Limited Partnership (ACILP)interchangeably.

First, Ill summarize what I consider to be the key points from Kulka (2010), NHCL (2009) and CERG(2009)

1. Kulka (2010) proposes to submit a Revised OEMP, with additional analysis undertaken by BillJohnson, RP Bio., of Focus Environmental. However, Kulka (2010) does not commit to address theOEMP deficiencies identified in the email sent to the proponent t that alot of baselineenvironmental data has been collected since 2001, and suggests that any deficiencies identified inour December 18

Scott Babakaiff, M.Sc. P.Geo.Regional Fish HydrologistMinistry of EnvironmentLower Mainland Region2nd Floor- 10470 152nd StreetSurrey, BC, V3R 0Y3

604-930-7121


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From: Stoddard, Erin M ENV:EXSent: Friday, January 15, 2010 12:20 PMTo: Bennett, Timothy A ENV:EXCc: Willcox, Michael ENV:EX; '[email protected]'; 'Francesca.Knight@dfo-

mpo.gc.ca'; Babakaiff, Scott C ENV:EX; Barrett, Scott ENV:EXSubject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264):

Operations Environmental Management PlanAttachments: image001.jpg

Tim,

IhadaquicklookthroughtheOEMPandsupportScottscommentswithrespecttofishandfishhabitat. Itappears

thatScotthasalsoaddressedfishandfishhabitatmonitoringintheJanuary9th

Innergexresponse,butcouldyou

pleaseforwarditsoIcanhaveaquicklookatitaswell. IhaveconcernswiththisOEMPandprevious

ones/monitoringprogramsfromwhatIamassumingtobethesameauthor,andreoccurringissuesaround

inadequaciesandnonconsistentimplementation. Itcreatessignificantinefficienciesforagenciesandthe

proponents,andresultsinineffectivemonitoringoftheseprojects.

Thanks.

Erin

From: Babakaiff, Scott C ENV:EX

Sent: Friday, January 15, 2010 11:53 AMTo: Bennett, Timothy A ENV:EXCc: Stoddard, Erin M ENV:EX; Willcox, Michael ENV:EX; [email protected]; [email protected]: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations

Environmental Management Plan

Tim,

As per your request, Ive reviewed three reports submitted to MOE by the proponent for the Ashlu IPP intwo emails dated January 9 & 12 2010:

1. Ashlu Creek Green Power Hydroelectric Project: Response to Comments on OperationsEnvironmental Monitoring Program prepared by Robert Kulka (Innergex Renewable Energy Inc.),for Tim Bennett (MOE-WSD), dated January 8 2009, 6 pp. Referenced hereafter in this review asKulka (2010);

2. Ashlu Creek IFR Flow Measurement prepared by Northwest Hydraulic Consultants Ltd for Ashlu

Creek Investments Limited Partnership, dated December 9 2009, 4 pp. Referenced hereafter in thisreview as NHCL (2009);

3. Ashlu Creek Flow Monitoring During Ramping prepared by Cascade Environmental ResourceGroup Ltd for Innergex Renewable Energy Inc, dated December 14 2009, 6 pp. Referencedhereafter in this review as CERG (2009).

A few notes: I am not reviewing the October 14 2009 letter sent by Robert Kulka to DFO regarding the proposed

ramping strategy undertaken per report #3 above (which was also included in the January 9 2010email); I was not provided the opportunity to review the proposed ramping work prior to itscompletion, and since the work has already been completed, provision of review comments now

seems redundant. Ill refer to the proponent in this review simply as the proponent, since the reports seem to use

Innergex Renewable Energy Inc & Ashlu Creek Investments Limited Partnership (ACILP)


24/298

My review of Kulka (2010), NHCL (2009) and CERG (2009) indicates three general points of concern:

1. I n c o n s i s t en t I F R p r o vi si o n , w i t h a r e a s o n a b l e l ik e li h o o d o f n o n - co m p l ia n c e: NHCL(2009) undertook a series of measurements at the outlet of the IFR pipe, clearly indicating thatinadequate delivery of IFR from the pipe can be triggered by accumulations of sediment andLWD in the approach channel. The issue of insufficient IFR provision was resolved once theoperators "sluiced the approach channel" but it is unclear how often such sluicing methods will be

required during normal operations in order to reliably deliver IFR to the diversion reach. NCHL(2009) taabluate the requisite headpond elevation (275.3 m) to maintain IFR provision but alsowarn that this requires a "well maintained IFR system". NCHL (2009) suggests that IFR inlet gatecould also be operated to manage the IFR release, but warn that "Due to the interaction between thetrashrack, inlet gate, and pipe entrance, if is difficult to calculate precise operation of the gate"

2. Co m m i tm e n t s m a d e i n K u l k a ( 2 0 10 ) r e ga r d i n g a n i m m i n e n t r e v is io n t o t h e O E M P d on o t a d d r e s s a l l c o n c e r n s i d e n t i fi e d i n M O E r e vi e w s o f p r e v io u s O E M P d r a ft s .

Kulka (2010) proposes that the OEMP (Revision B dated November 26 2009) recentlyreviewed by MOE is based on the Monitoring Plan previously (May 18 2009) presented toDFO and indicate that another version (a revision) will incorporate the comments

presented by MOE. Kulka (2010) suggests that the next OEMP revision will fully addressMOE concerns regarding stage-discharge rating curves (p.2) and streamflow data reporting(p.2). Kulka (2010) states that it is ACILPs intent to comply with the latest [MOE]standards wherever possible, but subsequently proposes to defer (or implies to ignore)several deficiencies previously identified by MOE.

For instance, Kulka (2010) suggests deferring the fulfillment of some MOE concerns:

Installation of adequate data loggers and transducers (February 2010);

Baseline data analysis: It is ACILP's intention that all collected data [2001-2008] be considered as baseline data gor reference during the operational

years of the project...It is ACILPs intention to have all of the baseline material

reviewed by qualified professionals at the time the date of the first year ofoperation becomes available (say, late 2010);

Collection and analysis of channel morphology data (no date specified).

Finally, and of greatest concern, Kulka (2010) makes no commitment to address MOEconcerns regarding the inadequacy of present streamflow monitoring to verify compliance

with instream flow requirements (IFR), ramping rates and maximum flow diversion.Rather, Kulka (2010) simply presents an argument regarding the adequacy of existingequipment & operational assumptions to meet compliance verification needs (see p. 5 ofKulka, 2010).

3. R a m p i n g r a t e s m e a s u r e d i n s t r e a m b y CE R G ( 2 0 0 9 ) fa r e x c e e d t h e D F O d e f a u l t r a t e s( 2 .5 -5 .0 c m / h r ) : detailed ramping rate study is proposed to be undertaken in late summerand/or early fall 2010 'when fry are in the system and water levels are somewhat reduced toelucidate the potential for stranding when fish are less mobile" (p.3 of Kulka, 2010). This seems likea reasonable strategy, except that CERG (2009) found that the ramping rates measured at theprimary sites of interest resulting from the present operating strategy (zero to full flow diversion in90 minutes, or 0.3 cms per minute) far exceeds the default rates typically accepted by DFO:

Si te High d i s cha r ge (10 -30 cm s ) L ow d i s cha r ge (0 -10 cm s )

R a m p U p R a m p D o wn R a m p U p R a m p D ow n

1. Twin Bridges 12 cm/hr n/a (darkness) 12 cm/hr 22 cm/hr (up to240 cm/hr)

2. Powerhouse 24 cm/hr n/a (darkness) 47 cm/hr Unknown

3. km 4.0 - - - -

l b d /h / (d k ) /h / (d k )


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CERG (2009) refers to the operating strategy (0.3 cms per minute) as the 'prescribed' ramping rate, andsimilar language is used by the proponent in reference to the DFO Authorization, but I do agreewith this assertion.

Finally, it is apparent that the proponent does not believe they are responsible for delivering a single OEMPthat meets both MOE and DFO needs, and they seem unaware that it is their responsibility to jointlyaddress agency review comments & co-ordinate subsequent OEMP drafts (see p.6 of Kulka, 2010). As Idescribed in my Jan. 8 2010 email, there is a bit of confusion since the proponent has submitted two

different OEMPs to DFO and MOE, and there are incongruent (and inadequate) commitments in them.

but am available to discuss this review later

Scott

From: Bennett, Timothy A ENV:EX

Sent: Tuesday, January 12, 2010 11:20 AM

To: Babakaiff, Scott C ENV:EXSubject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): OperationsEnvironmental Management Plan

HiScott,

Whenyouhaveachance,canyoupleaseletmeknowifyouhaveanycommentsonthematerialsenttousre:the

AshluOEMP?

Thanks!


SectionHead,

Water

Allocation



10470 152Street,Surrey,BCV3R0Y3

Ph.(604)5825227 Fx.(604)5825235

[email protected]

From: Robert Kulka [mailto:[email protected]]Sent: Saturday, January 9, 2010 1:46 PM

To: Bennett, Timothy A ENV:EXCc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; [email protected]; Richard Blanchet; KellyBoychuk; Bill Johnson; Mike Nelson

Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): OperationsEnvironmental Management Plan

Hi Tim,

Please find attached our response to your comments provided in underneath email. I will try to call you early nextweek to discuss a path forward, including overall timing and LTC commissioning and operation.

Regards and happy New Year,Robert

________________________________________



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Phone : 604 984.8600 Fax : 604 984.8699

Cell.: 778 227.0434

From: Bennett, Timothy A ENV:EX [mailto:[email protected]]Sent: Friday, December 18, 2009 3:12 PM

To: Robert KulkaCc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; [email protected]; Richard Blanchet; KellyBoychukSubject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): OperationsEnvironmental Management Plan

HiRobert,

ThankyouforprovidingyourdraftOEMPforourreview.

Staffhaverevieweditandprovidedthefollowingpreliminarycomments:

1. ReportAuthorshipunknown: Thereportshouldbepreparedandsignedbyappropriatelyqualified

licensedprofessional(s)(e.g.,RPBio).

2. Fewcommitmentstofollowcommonlyacceptedguidelinesfordatacollection&analysis,despitea

proposalthatmonitoringdetailsmeettherequirementsofDFOandMOE(p.6oftheOEMP). Many

detailsproposedintheOEMPareseeminglyarbitraryanddonotreferenceanyguidelinesorstandards

typicallyreferencedbyProvincialorFederalagencies. Forinstance:

1. Stagedischargeratingcurves theOEMPcommitstocollectingaminimumofthreedischarge

measurementsandwarnsthat...itisunlikelythatflowswillbeabletobemeasuredabove20%of

meanannualdischarge. Thereareclearandwellestablishedguidelinesfordevelopingstage

dischargeratingcurves(e.g.LWBCHydrometricGuidelines;B.C.ProvincialHydrometricStandards

(see

http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric%

20Standards%20V1.0,%20March%2012,%202009.pdf)thattheproponentisrecommendedtomeet.

2. Reportingofstreamflowdata:theOEMPcommitstocollecttocollectflowdataonacontinuous

basis,typicallyin15minuteintervalsandpromisesthatdatawillberecorded...andcanbe

providedtoonsiteDFOand/orMOEstaff...forcompliancepurposes...flowdatawillbereported

quarterly. Isuggestthereisnoneedtosubmitdatatoreviewagenciesmorefrequentlythanonce

peryear,butagenciesmustbeinformedwithin24hoursofanynoncompliance(e.g.IFRprovision,

rampingrates),andtheproponentmustresolvetheissueofnoncomplianceimmediately. Intermsofdatacollection&logging,InotethattheBCProvincialHydrometricStandards(Section3.2.2.3)

recommendsastagereadingevery15minutes,butadvisesthat"thisisaminimum

requirement...sitespecificflowregimesmaynecessitateashorterfrequency...".Forpurposesof

verifyingcompliancewithflowrampingrequirementsinfishbearingwaters,particularlythosewith

thediversityoffishvaluesintheAshludiversionreach,Iwouldrecommendamuchshorterstage

samplingfrequency(say,10second),witha2minuteaverageforstorageinthedatalogger(and

submissiontoagencies). Iwouldalsorecommendthatdatabedownloadedfromtheloggerona

frequencynolessthanoncepermonth,toensurethatanyequipmentmalfunctions(e.g.battery

loss,equipmentdamage)donotresultinlengthydatagaps. Forpurposesofgraphicalpresentation

inmonitoringreports,itmaybehelpfultoapplyanhourlyaveragetothe2minutestagedata.

3. Developmentof

ramping

rates:

Section

12.2

of

the

OEMP

proposes

that

the

ramping

rates

shall

notexceed29.0cmsper90minutes. Thisratewillbeestablishedduringthecommissioningprocess


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thenaturalrampingratesthathavebeenhistoricallyobservedinAshluCreekoverseveralyears

since1991.... TheOEMPprovidessomedetailregardingproposedmethodsforestablishing

rampingratesduringcommissioning,butIwouldsuggestthatsuchprotocol(andsuchinterimrates

like29cmsper90minutes)shouldbeestablishedandscientificallyjustifiedbyanexperienced

professional,withreferencetoestablishedagencycriteria(e.g.DFOsdefaulthourlyrampingrates

of2.5cm&5.0cmforfry&juveniles)orrecommendedguidelines.Finally,Isuggestthatthe

commitmentwithinSection14oftheOEMPtosubmittherampingratereportsixmonthsafter

commissioningrepresentsaninappropriaterisktofish&fishhabitatgiventherapidinterim

rampingrate

proposed

and

the

fish

values

present

in

the

diversion

reach.

4. FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfor

datacollectionoranalysisareproposed,despitethebibliographicreferenceinSection16ofthe

OEMPtoHatfield&Lewis(2007). The MOEESDinformationchecklistprovidedintheProvincialIPP

GuidebookalsoprovidessupplementalguidanceforOEMPdevelopment. Itismyunderstanding

thatthebaselinebiologicaldatacollectedinrecentyearsdidnotfollowanyparticularprotocol,but

wasundertakenbyseveraldifferentbiologistsindifferentlocations,usingdifferentmethods. As

such,itisimperativethatallbaselinedatabecollatedandassessedbyaprofessionalbiologistwith

experienceintherelevantspecialization(ie.fisheriesbiology,macroinvertebratebiology),and

compiledforassessmentregardingitsadequacyasabaselinetoassessfuturechangesthatmaybe

attributabletooperationoftheIPPfacility.Onthisnote...

3. Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g.

durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,aprioriagreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory

measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.) cannotbe

objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis. In

theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I

havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany

diversioninducedchangesinthesebiologicalresponsevariables.4. DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith

textin

the

body

of

the

OEMP.

For

instance,

page

3of

the

OEMP

clearly

states:

In

the

case

of

the

Ashlu

Project,baselinestudieswerecarriedoutfrom2001to2006,aperiodoffive(5)yearsandweredoneprior

tothenewProvincialguidelines(HatfieldandLewis,2007);therefore,notallofthecriteriaoutlinedinthe

guidelinesforcontrolsiteshavebeenimplementedduringthesepreviousstudies. However,monitoring

proposedforsomecomponents(e.g.biologicalcomponentsfromTables35oftheOEMP)havebeencopied

verbatimfromtheguidelines(which,incidentally,arenotreferencedcorrectly)andsubsequentcasestudy

(TroutCreek),soitisunclearwhataspectsofthemonitoringcriteriawillorwillnotbeundertakenperthe

OEMP.

5. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated.

Forinstance:

1. installationof

the

four

pressure

transducers

(per

Section

4.2.1

of

the

OEMP)

and

development

of

associatedratingcurvesforwaterflow(Section4)andinstreamflow(Section11)monitoring;

2. Collectionofstreamchannelmorphologydata(perSection10oftheOEMP). Thiscomponentof

theOEMPisparticularlyilldefined:therearenoexplicitguidelinesorstandardsreferenced,andI

alsoquestiontheproposedbenefitsofcompletingrepeatsurveysatafewtransectstoassess

whethertheIFRisaffectanyofthefishhabitataswasoriginallypredicted. Assessmentofchanges

inchannelmorphologyrelatedtoprojectoperations(e.g.flowdiversion,changesinsedimentand

LWDtransportratesandvolumes,etc.)iscrucial,butshouldbeconsideredmoreholisticallyusing

lowlevelairphotosandlongitudinalsurveyprofiles. Again,itisrecommendedthatanprofessional

experiencedwithdevelopmentofchannelmonitoringprograms(ie.afluvialgeomorphologistor

riverengineer)betaskedwithdevelopingthestudydesignandundertakingtheworkpriortofinal

commissioning;

I also note that it appears this draft OEMP was provided to DFO in May 2009; were earlier copies submitted to MoE?


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Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff.

Regards,


SectionHead,WaterAllocation



10470

152Street,

Surrey,

BC

V3R

0Y3

Ph.(604)5825227 Fx.(604)5825235

[email protected]

From: Robert Kulka [mailto:[email protected]]

Sent: Friday, November 27, 2009 3:04 PMTo: Bennett, Timothy A ENV:EX

Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; [email protected]; Richard Blanchet; KellyBoychukSubject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations EnvironmentalManagement Plan

Hello Tim,

Attached are the following files:

Revision B of the Operations Environmental Management Plan for the Ashlu Creek project.

Jpeg file of the monitoring map shown as Figure 1 in the OEMP.

Cover letter regarding submission of the OEMP.

Hard copies are in the mail to you, to Scott Babakaiff, and to Vince Busto. Please contact me if you have anyquestions.

Regards,Robert

________________________________________



Phone : 604 984.8600 Fax : 604 984.8699

Cell.: 778 227.0434


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From: Babakaiff, Scott C ENV:EXSent: Wednesday, January 27, 2010 3:26 PMTo: Bennett, Timothy A ENV:EXSubject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264):

Baseline studies and dataAttachments: image001.jpg; 2010-01-26 Ashlu ltr RK to TB Baseline.pdf

It will be interesting to have a look at the January 2010 hydrology update composed by Knight PiesoldConsulting; all hydrology work completed prior to water licensing was based on modelled flow data.

However, in terms of baseline data that would inform an long-term operational monitoring program (aka.OEMP, LTAMP, etc.), it is unfortunate that n o biological or geomorphological data collection/analysisseems to have been undertaken in the diversion reach in the last six years (ie. post-licensing). I reviewedthe biological & geomorphological data collection/analysis that was completed prior to licensing (ie. thepile of reports that Robert is sending to you, under the pretence of baseline data) and it is far fromadequate in terms of allowing any quantification of post-diversion changes to instream biota.

Scott

From: Robert Kulka [mailto:[email protected]]Sent: Wednesday, January 27, 2010 2:22 PM

To: Bennett, Timothy A ENV:EXCc: Babakaiff, Scott C ENV:EX; [email protected]; Richard Blanchet; Kelly Boychuk; Bill JohnsonSubject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Baseline studies and data

Hello Tim,

As per our conversation on the phone last week, I put together a package with studies and reports regarding baseline

data. The package should be at your office by tomorrow afternoon. Please contact me if you should have anyquestions or need more information.

Regards,Robert

________________________________________



Phone : 604 984.8600 Fax : 604 984.8699

Cell.: 778 227.0434


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Birchard, Leona ENV:EX

From: Knight, Francesca [[email protected]]Sent: Monday, November 16, 2009 1:15 PMTo: Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EXCc: Stoddard, Erin M ENV:EX; Wilson, Greg ENV:EXSubject: RE: Ashlu Incident

an artfully crafted understatement...CFrancesca Knight, M.Sc., R.P.Bio.Habitat BiologistFisheries and Oceans Canada / Pches et Ocans CanadaOceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas FraserUnit 3 - 100 Annacis ParkwayDelta, BC V3M [email protected]: (604) 666-3191 / Fax: (604) 666-6627Government of Canada - Gouvernement du Canada

From: Babakaiff, Scott C ENV:EX [mailto:[email protected]]Sent: November 16, 2009 11:53 AMTo: Busto, Vince; Bennett, Timothy A ENV:EX; Knight, Francesca

Cc: Stoddard, Erin M ENV:EX; Wilson, Greg ENV:EX

Subject: RE: Ashlu IncidentYes, lets discuss further tomorrow.

I havent been privy to all the discussions regarding Robert Kulkas actions (or lack thereof) on this project,but the ongoings of recent weeks suggest that a chain of due diligence has been broken somewhere alongthe line...

From: Busto, Vince [mailto:[email protected]]Sent: Monday, November 16, 2009 11:30 AM

To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; Knight, FrancescaSubject: RE: Ashlu Incident

Tim, Scott, and FrancescaWe can discuss this during our IPP meeting tomorrow

Vince

From: Babakaiff, Scott C ENV:EX [mailto:[email protected]]S N b 16 2009 9 48 AM


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Cc: Busto, Vince; Bennett, Timothy A ENV:EXSubject: RE: Ashlu IncidentUnreal...

Isnt the proponent obligated to ensure that the EM is onsite prior to initiating/undertaking such activities?

S

From: Knight, Francesca [mailto:[email protected]]

Sent: Monday, November 16, 2009 7:56 AMTo: Babakaiff, Scott C ENV:EXSubject: FW: Ashlu Incident

...it never ends,C

Francesca Knight, M.Sc., R.P.Bio.Habitat BiologistFisheries and Oceans Canada / Pches et Ocans CanadaOceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas FraserUnit 3 - 100 Annacis ParkwayDelta, BC V3M [email protected]: (604) 666-3191 / Fax: (604) 666-6627Government of Canada - Gouvernement du Canada

From: Christine Becker [mailto:[email protected]]Sent: November 15, 2009 12:57 PMTo: Robert Kulka; [email protected]; [email protected]; [email protected]; Knight, Francesca;[email protected]; Busto, Vince

Cc: Mike Nelson; Ken McNamaraSubject: Ashlu IncidentHiAll,

Pleasebe

advised

of

the

following

events

as

observed

by

the

EM

today:

TheEMarrivedonsitethismorningtodiscoverthatrampingupto10CMhadalreadybeeninitiatedandcompleted

priortotheEMsarrival. TheEMobservedthatflowsapproximately150mdownstreamoftheintakewerebelow

theminimumflowrequirementof2.4CM. TheEMalsonotedthattheObermeyerweirwasfullyclosedandasa

resulttherewaspotentialforfishstrandingdownstreamoftheweir. TheEMimmediatelyadvisedInnergex

personneloftheseissues subsequentlygate1oftheweirwasimmediatelyopenedtoallowflowtopass

downstreamoftheweir,andrampingwasreversedtobringflowsinthecreekbackuptoambientconditions.

CascadehasrequesteddetailedrampingdatafromInnergexpersonnelfortherampingactivitythatoccurredtoday.

CHRISTINE BECKER (NEE CUNLIFFE). B.SC., B.I.T.Cascade Environmental Resource Group Ltd.Whistler and Squamish, BC | Whitehorse, YK | San Diego, CAUnit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3


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From: Wilson, Greg ENV:EXSent: Monday, November 16, 2009 1:08 PMTo: 'Knight, Francesca'; Babakaiff, Scott C ENV:EX; 'Busto, Vince'; Bennett, Timothy A

ENV:EXCc: Stoddard, Erin M ENV:EXSubject: RE: Ashlu Incident

Attachments: image001.jpg

Doh,sothearsenicstoriesaretrue! Ithinkourguidlinesare5ug/L,butIknownaturalstreamconcentrationsare

canbehigher.Whatvalueshavebeenrecordedrecently?

Havefishkills/strandingsoccurredaswell?

Greg


Sent:Monday, November 16, 2009 12:57 PM

To: Wilson, Greg ENV:EX; Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EX

Cc: Stoddard, Erin M ENV:EXSubject: RE: Ashlu Incident

Hi Greg, thanks very much for your comments; I think you are bang on with your concerns. We are much further alongwith a defensible management strategy for the arsenic issue, but admittedly, we still don't know what arsenicconcentrations will be like over the long-term, during plant operations.

Francesca Knight, M.Sc., R.P.Bio.Habitat BiologistFisheries and Oceans Canada / Pches et Ocans CanadaOceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas FraserUnit 3 - 100 Annacis ParkwayDelta, BC V3M [email protected]: (604) 666-3191 / Fax: (604) 666-6627Government of Canada - Gouvernement du Canada

From: Wilson, Greg ENV:EX [mailto:[email protected]]Sent: November 16, 2009 12:50 PMTo: Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EX; Knight, FrancescaCc: Stoddard, Erin M ENV:EX

Subject: RE: Ashlu IncidentHeyFolks,

Ihavebeenhearingrumblingsfromvarioussources(inandoutofgovernment)regardingmultipleissues,violations

andfishkillsassociatedwiththeAshluIPP,soIaskedScott inpassingandIseethereissometruth.


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Pleaserememberthatatthecoreoftheissueisasmallandstrugglingpopulationofsteelhead/rainbowsdirectly

affectedbythisIPPandany/allactionsinvolvingflowandwaterqualityaffectsthem.

Idontthinksteelhead,asthespeciesmosteffected, gotfaircompensationoriginally(althoughMatthasdonea

reallygoodjobonthechannelsandponds),andifthearsenicpoisoningandfishstrandingstoriesaretruethenthe

cumulativeeffectscouldbesignificant.

PleaseremindtheproponentandtheirEMsofthefollowing:

TheAshluisprobablyalreadyunderseededwithjuveniles,asworkdonebyARL(graphbelow)andBCCFoverthe

lastfewyearsconstantlyshowsomeofthelowestfrydensitiesintheregion. Parrlivebelowthepowerhouseforup

to3 4yearsbeforesmoltingsothereisalongperiodofvulnerabilitytoconstructionandoperationalimpacts

(authorizedornot).

ThisreturnseasontotheSquamishasawholewillprobablybereallybad. Itwillbeaboutthelargestspillimpact

yearforCheakamusfishresultingfromthe2005CNchemicalspillandIthinkthatisdraggingdowntheSquamish

population(peoplecatchCheakamusfishintheSquamish),whichisallontopofaperiodofextremelylowocean

survival,andasaresultSquamishsteelheadareclassifiedasanExtremeConservationConcernformanagement. If

thereismortality(evenifsmall)thenweshouldlookatthenextmanagementactions. Asthereisalreadyabaitban

onthe

Ashlu,

so

the

next

step

would

likely

be

an

angling

closure.

If

you

have

guidance

or

opinion

on

this

Iwould

appreciatesomefeedback. SteelheadingseasonontheAshlu,andtherestofthewatershedstartsinafewmonths

andtherewillbecrankyanglersabootespeciallyastheytryandfisharoundtheOlympicroadrestrictions,etc..

Couldsomeonepleasekeepmeappraisedonallinstances/actionswhichhavethepotentialtoimpactfishoverwhat

theproponentispermitted.

Thanksmuchfolks!

Cheers,

Greg


37/298

From: Babakaiff, Scott C ENV:EXSent: Monday, November 16, 2009 11:53 AM

To: 'Busto, Vince'; Bennett, Timothy A ENV:EX; 'Knight, Francesca'

Cc: Stoddard, Erin M ENV:EX; Wilson, Greg ENV:EXSubject: RE: Ashlu Incident

Yes, lets discuss further tomorrow.

I havent been privy to all the discussions regarding Robert Kulkas actions (or lack thereof) on this project,but the ongoings of recent weeks suggest that a chain of due diligence has been broken somewhere alongthe line...

From: Busto, Vince [mailto:[email protected]]Sent: Monday, November 16, 2009 11:30 AMTo: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; Knight, FrancescaSubject: RE: Ashlu Incident

Tim, Scott, and FrancescaWe can discuss this during our IPP meeting tomorrow

Vince


38/298

From: Babakaiff, Scott C ENV:EX [mailto:[email protected]]Sent: November 16, 2009 9:48 AM

To: Knight, FrancescaCc: Busto, Vince; Bennett, Timothy A ENV:EXSubject: RE: Ashlu IncidentUnreal...

Isnt the proponent obligated to ensure that the EM is onsite prior to initiating/undertaking such activities?

S


Sent: Monday, November 16, 2009 7:56 AMTo: Babakaiff, Scott C ENV:EX

Subject: FW: Ashlu Incident

...it never ends,

CFrancesca Knight, M.Sc., R.P.Bio.Habitat BiologistFisheries and Oceans Canada / Pches et Ocans CanadaOceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas FraserUnit 3 - 100 Annacis ParkwayDelta, BC V3M [email protected]: (604) 666-3191 / Fax: (604) 666-6627Government of Canada - Gouvernement du Canada

From: Christine Becker [mailto:[email protected]]

Sent: November 15, 2009 12:57 PMTo: Robert Kulka; [email protected]; [email protected]; [email protected]; Knight, Francesca;[email protected]; Busto, VinceCc: Mike Nelson; Ken McNamaraSubject: Ashlu IncidentHiAll,

PleasebeadvisedofthefollowingeventsasobservedbytheEMtoday:

TheEMarrivedonsitethismorningtodiscoverthatrampingupto10CMhadalreadybeeninitiatedandcompleted

priortotheEMsarrival. TheEMobservedthatflowsapproximately150mdownstreamoftheintakewerebelow

theminimumflowrequirementof2.4CM. TheEMalsonotedthattheObermeyerweirwasfullyclosedandasa

resulttherewaspotentialforfishstrandingdownstreamoftheweir. TheEMimmediatelyadvisedInnergex

personneloftheseissues subsequentlygate1oftheweirwasimmediatelyopenedtoallowflowtopass

downstreamoftheweir,andrampingwasreversedtobringflowsinthecreekbackuptoambientconditions.

CascadehasrequesteddetailedrampingdatafromInnergexpersonnelfortherampingactivitythatoccurredtoday.


40/298


From: Knight, Francesca [[email protected]]Sent: Monday, December 7, 2009 10:56 AMTo: Robert KulkaCc: Busto, Vince; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Stoddard, Erin M

ENV:EX; Christine Becker; Ken McNamara; Richard BlanchetSubject: RE: Leave to Construct - Spillway Apron - Fisheries Improvements (File No 2001264;

Licence No. 102203)

Hello Robert,

I have included G. Steeves information regarding spillway modifications to prevent fish stranding (for those who havenot yet seen this text):The following is a general description of the proposed work program as explained by Innergex to the IE.The spillway gate will be temporarily opened and then closed. There will be a fish salvage and theidentification of areas susceptible to fish stranding. The limits of the pools will be marked andchannels designed to link the pools to each other and eventually the main body of the river. Theslopes, widths and depths of the linking channels will as prescribed on site by the attending R.P Bio.

The spillway gate will be partially opened again and the area re-flooded and the effectiveness of thechannels constructed in the first phase evaluated. Should it be determined there is still potential forstranding, additional channels and/or pools will be built, again under the direction of the attending R.P. Bio.The process is to be repeated until the attending R.P. Bio. is satisfied that the potential for strandinghas been mitigated..Clear segregation of the work area from the adjacent stream to ensure no deleterious materialsareallowed to enter the watercourse.. Confirmation from DFO and ESD that this is not instream work isrequired..My comments are as follows:1. The works are definitely "instream" and should be conducted during next year's low-risk fisheries work window. Forthe interim, we may want to consider cracking one of the Obermeyer weir gates such as to allow low flows over thespillway (similar to what we did during the summer headpond filling). I believe you are looking into the possibility of av-notch in the Obermeyer as a more permanent fix (in addition to channel modification)?2. Prior to discussing the timing of the modifications, however, I believe we need to have a design available fordiscussion. The general and qualitative nature of Mr. Steeve's recommended spillway fix precludes DFO fromoffering any substantive comments.3. Further to comment 2 - please prepare a detailed spillway modification plan for review by DFO and MoE, includinga construction management plan to prevent the release of sediment during the works. I have seen a draft modificationplan (provided by Cascade) that shows modifications to the pools closest to the weir (upstream), but does not appearto address stranding in the lower pools (just upstream of the confluence with the river). Fish are also stranded in thesepools if no water is provided via a crack/v-notch in the Obermeyer, so this area needs to be addressed for the long-term.regards,Francesca

Francesca Knight, M.Sc., R.P.Bio.Habitat BiologistFisheries and Oceans Canada / Pches et Ocans CanadaOceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas FraserUnit 3 - 100 Annacis ParkwayDelta, BC V3M 6A2

[email protected]

Ph: (604) 666-3191 / Fax: (604) 666-6627Government of Canada - Gouvernement du Canada


41/298

From: Robert Kulka [mailto:[email protected]]Sent: December 4, 2009 10:22 AMTo: Knight, FrancescaSubject: RE: Leave to Construct - Spillway Apron - Fisheries Improvements (File No 2001264; Licence No. 102203)Francesca,We would like to put together a work plan to do theimprovements in the d/s area of thespillway before we loose access due to snow. In order to proceed I need toknow if youconsider this work instream or not instream as per my inquiry on November 26 (seeunderneath). I would appreciate your early attention.I have asked Cascade to forward all water sample test results to you. Since we are

now in operation, we will decrease the sampling frequency to weekly. Cascade willcontinue to perform the sampling and will continue to forward sample results to you.Regards,Robert

________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.Construction ManagerInnergex nergie renouvelable - Innergex Renewable Energy

Suite 303 - 38 Fell Avenue

North Vancouver, British Columbia V7P 3S2Phone : 604 984.8600 Fax : 604 984.8699Cell.: 778 227.0434

-----Original Message-----

From: Robert Kulka

Sent: Thursday, November 26, 2009 5:09 PM

To: 'Knight, Francesca'; 'Mike Nelson'

Cc: 'Steeves, George'

Subject: RE: Leave to Construct - Spillway Apron - Fisheries Improvements (File No

2001264; Licence No. 102203)Francesca, Mike,George Steeves asked me to forward the attached LTC to you for your records. Francesca: The LTC requires DFO to comment if the work is considered "instream work"

or not. Could you please provide your comment on this?Regards,Robert


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________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.Construction ManagerInnergex nergie renouvelable - Innergex Renewable Energy

Suite 303 - 38 Fell Avenue

North Vancouver, British Columbia V7P 3S2Phone : 604 984.8600 Fax : 604 984.8699Cell.: 778 227.0434

-----Original Message-----From: Steeves, George [mailto:[email protected]]

Sent: Thursday, November 26, 2009 2:02 PMTo: Robert KulkaSubject: FW: Leave to Construct - Spillway Apron - Fisheries Improvements (File No

2001264; Licence No. 102203)Robert.I forgot to copy you, Mike Nelson and Francesca. Can you forward it to them? George

________________________________ From: Steeves, GeorgeSent: Thursday, November 26, 2009 4:57 PMTo: [email protected]: Leave to Construct - Spillway Apron - Fisheries Improvements (File No

2001264; Licence No. 102203)TimPlease find the above leave to Construct attached. Iam planning on visiting Ashlu on

Monday. Any interest in someone coming along/George**************************************************************************************


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not an intended recipient of this e-mail, you are hereby notified that any

unauthorized use, dissemination or copying of this e-mail or the information contained

in it or attached to it is strictly prohibited. If you have received this e-mail in

error, please delete it and immediately notify the person named above by reply e-mail.

Thank you.**************************************************************************************


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From: Knight, Francesca [[email protected]]Sent: Thursday, January 7, 2010 6:54 PMTo: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EXCc: Stoddard, Erin M ENV:EX; Busto, VinceSubject: Ashlu long-term monitoirngAttachments: image001.jpg; image002.jpg; image003.jpg

Hi guys,I'd been meaning to take a look at the Ashlu's long-term monitoring plan. Does anyone know who wrote the plan?After seening the Fitz creek plan, the Ashlu one leaves me wanting a bit. I believe the approach for most of theindicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusionsregarding any potential biological responses to the alterted flow regime. I'll give you a couple of examples:1. The report claims that fish population density will be evaluated, but in fact, there is no method included forestablishing a population estimate in the diversion reach. What will actually be measured is prsence/absence, whichis useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise uselessfor telling us whether the diversion has influenced the fish population. In addition, there is no method for countingadult fish... just gee traps for the little guys.2. The bug data will not be analyzed in any way that enables us to make before-and-after diversion comparisons;abundance will be presented for each sampling event, but no quantitative evaluation of change over time. There aresome other short-comings related to methods, but the limited analysis is the biggie. In addition, there is of coursenothing proposed for evaluating changes to community structure, but you all know that is my main concern with howinvertebrates are used as indicators in the IPP-world.

3. The methods proposed for evaluating physical habitat change (transects) are again, too qualitative. I don't think wewould be able to draw any meaningful conclusions about how the altered flow regime affected available habitat types.4. The monitoring for the compensatory fish habitat is entirely qualitative: "Periodic observations will be made to checkon fish utilization in the channel and pools." No mention of even setting gee-traps!In summary, I think the program is set up to collect some data, but not to offer

Response Records Part 2

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Transcript of Response Records Part 2