Environmental Assessment Office

February 9, 2012

Please accept Watershed Watch Salmon Society's comments on the proposed Big Silver, Tretheway and Shovel Creek projects.

I am a whitewater kayaker from Seattle, WA. Each year my friends and I spend many weekends kayaking in southern British Columbia. Tretheway Creek is featured as one of the best creeks on the continent in the leading whitewater guidebook (The River Gypsies Guide to North America). Although I have not had the opportunity to paddle Tretheway Creek personally, I have been in the area several times and it is wilderness like this that compels me to spend much of my vacation time in British Columbia. I am opposed to the development of an IPP on Tretheway Creek because I feel that the value of experiencing a free-flowing whitewater river in such a spectacular wilderness by current and future generations far outweighs the relatively small amount of electricity that would be generated by dewatering this creek.
If an IPP is approved, I strongly urge you to require predictable and dependable whitewater recreational releases on multiple weekends throughout the summer so that people can continue to enjoy one of the best whitewater creeks in North America.
Thank you for the opportunity to comment on this project.

I am writing in response to the Environmental Assessment Application submitted by Cloudworks Energy Inc. to the EAO for permitting approval for their proposed 23 MW Hydroelectric Facility to be located on Tretheway Creek, BC. 

Tretheway Creek is of great interest to kayakers and navigation will definitely be affected by this proposal.  The proposed facility will divert a flow of 11.4 cumecs which is a significant volume for this size of creek.

Cloudworks Energy Inc. has submitted a Navigational Assessment report prepared by TyPlan as part of this application.  This report contains a number of inaccuracies, misleading statements, has insufficient research and does not provide adequate mitigation measures for recreational purposes.  The following content highlights some of the inaccuracies and shortfalls of this report:

• Section 2: No navigable flow levels or navigable flow frequency information statistics are provided in the report.  It is easy for the author to state navigation will not be affected if flow data is not provided to prove otherwise.  The three referenced photographs all of different dates show a maximum flow of 6.92 cumecs which is less than the potential diversion flow suggesting that the creek will very rarely be of sufficient capacity for navigation post construction.

• Section 2: It appears that all information provided in this report is based on data in the Minor Waters Assessment prepared by Ecofish.  No field visits by TyPlan are indicated.  It is unlikely that Ecofish’s scope of work include navigation otherwise the navigation report would have been prepared by Ecofish.  It seems that a minimal effort has been used to assess navigation of this creek which is not acceptable considering how important this creek is as a resource for kayakers.

• Section 3:  Considering that Tretheway Creek is included in the River Gypsies Guide book highlighting the best 294 rivers in North America, the report severely understates the importance of this river to recreational users particularly for kayakers. 

• Section 3:  The author tends to focus on references to Vancouver Kayak Club and Whitewater in Southwest British Columbia guidebook implying that Tretheway Creek is of no interest to kayakers as it is not referenced in these sources.  This guidebook and the VKC are geared towards beginner and intermediate kayakers with references stating as such, so are unlikely to focus on this creek.  Tretheway Creek is reported in a number of other sources not mentioned including the LVM video magazine in episodes #1 and #37 that is distributed to kayakers worldwide which highlights again the importance of this creek to kayakers.

I recommend that the EOA reject the application submitted by Cloudworks Energy Inc. based on recreational navigational purposes.  Construction of the proposed hydroelectric facility will be detrimental to the navigation of this creek. This type of facility does not contribute to better kayaking conditions but detracts from the wilderness experience. 

However, if the EOP approves the applicant's submission, the following conditions should be included to provide some mitigation (although any form of mitigation does not make up for the loss of such a resource) for loss of navigability on Tretheway Creek:

1.  There must be recreational whitewater releases provided by Cloudworks to account for the dewatering of the creek during its historical season of navigation. Water releases should be of satisfactory duration to accommodate safe travel for kayakers down the creek taking into account time variations due to group size, skill level and familiarity of the kayakers to the river. Water releases must allow for a range of suitable flows as different water levels provide different experiences while navigating a river. 

2.  There must be real time water level and flow gauge information publically available online to account for the variance from seasonal flow periods for the creek due to the dewatering. The gauge information must include both inflows and outflows from the facility (including the volume of water removed from the creek) and an indication of the projected volume of water to be removed from the creek for the upcoming period. This is particularly important on non-release days when there is significant rain forecast in the watershed.  Notification shall be provided to the local kayaking community indicating upcoming water releases beyond those scheduled for recreational purposes.

3.  Access to the creek via existing roads (and future roads constructed as part of the project) must remain open during and after the construction period.

I do not agree with this project under its current mitigation regarding recreation. Specifically, I do not agree that there will be little to no residual effect to recreation. 
The pre and post project hydrograph was not included in the Typlan navigation assessment and though I have not found this graph and do not understand how an assessment saying that paddling may increase as a result of this project can be made. I request that the proponent do another assessment and make this information public and consult as to how release days along with post project peak flow days will increase paddling opportunities on this creek. 

The recommended mitigation should increased from 0 a minimum of 20 release days that should operate in the manner as they do on Ashlu Creek. If this is not acceptable I would offer a solution that this project should only be approved at 50% of its’ current nameplate capacity. 

Kayakers need days at the start and the end of the season to preserver recreation in the province. The Harrison Lake route is a tourism benefit and helps kayaking retailers stay in business and contribute to the economy. 

I, like many people in the tourism industry, work in the mid-summer and rely on the shoulder season flows to get on the water. If this project has no paddling days, I will never be able to paddle this river, essentially destroying all recreational values it has for me and numerous other people who can’t afford time off mid-summer. 

In addition to the above point some of the release days should be mid-week as those of us in the tourism industry typically work on the weekends running tours ect. 

On the whole I do not like how one sided many of the navigational impact assessments are worded as they only effect expert kayakers, like we don't matter. Or that recreation may increase as a result of the project therefore no mitigation, such as release days, are needed. Recreation may also decrease!!!!! I would like the proponent to address these concerns by providing paddling days. A minimum of 20 above and beyond any times that the water is spilling over the weir. 

I also disagree with using the limited written material about paddling to make concrete decisions on the paddling usage on these creeks. For example, using the Whitewater in Southwest BC - Guide for Beginner, intermediate and Advanced Kayakers guidebook by Claudia Schwab as the 'bible' for creeking aka extreme kayaking in BC. 

With all due respect to Ms. Schwab, she is not a class 5 creeker. She will tell you this herself and thus I feel as though there is a lot of information within the paddling community that could better address the usage of this creek. 

I would like another assessment done by the proponent to outline how they are going to provide release days to mitigate recreation losses. Power project should improve recreation. I do no see the evidence within Typlan's assessment that it will increase paddling usage on this creek and thus request that the project does not go through or to facilitate paddling days that could increase this streams usage. 

Offering kayakers an online gauge is useless if there is no water in the diversionary section!!! With regards to the online gauge I think it would be best to have two, one above the diversion and within the diversion section. This would be a better fit for other rivers as well such as Ashlu Creek. With the recent changes in how much power the government is looking for I do not this project is necessary. We typically operate in excess of thousands of gigawatt hours a year and I think that this stream is more valuable than the electricity it is going to provide the grid. In my opinion, it is much more valuable than the shareholders’ pockets of Innergex.

February 8, 2012

Hello,

I'm writing this letter to voice my concerns over the development of an IPP on Tretheway Creek.  I feel the mitigation measures put forward by the proponent that account for dewatering the river and the subsequent loss of navigability are inadequate.

Should the project be approved, the following points must be considered:

-    Dewatering a river and altering the natural flow patterns do not ‘improve kayaking’ as stated in the navigability assessment.

-    The dewatering of a navigable river such as Tretheway can only be mitigated by providing recreational flow releases and a real time, publically available flow gauge.

-    There are mandatory recreational whitewater releases in the Harrison Lake area on dewatered rivers that have little or no record of recreational use or are inaccessible by road (Stave, Fire, Douglas, Tipella etc.).  Tretheway Creek is in a similar situation and as such similar mitigation measures should be put forward.

-    A sign up system similar to that on Ashlu Creek is ideal.  This way, the boating community still has opportunity to use the creek and are assured ideal flows should they want to use the resource.  In the case they aren’t signed up for, the proponent does not have to provide an unutilized release.

Remember, even though this isn’t a high traffic whitewater resource, diverting the water from the creek eliminates the possibility of it being used for recreation.  The fact that places like this provide the backdrop for adventure in pristine wilderness is a significant part of their value.  This will be lost for, at minimum, the proposed lifespan of the project (40 + years).

Thanks for your time – I trust these comments will be carefully considered.

I am a whitewater kayaker from Germany and I am living in BC since 2008. This province is known for its world class white water in remote wilderness areas. Since I am living here I am realizing more and more that this will not be the same anymore in a couple of years. It seems like every creek and little river has at least one proposal for an IPP project. This is not just bad for kayakers, it is even worse for wild life. Pristine wilderness will be destroyed by excavators and chain saws. 

Country's like Germany would be very happy to have so many untouched rivers and would not allow any wilderness river to be diverted today. Its just a matter of time for me until BC is realizing that as well, but than it is probably too late.

Thanks for considering my comment.

This is one of the best runs in north America, it is stated as so in the newest guide book. if you are going to allow this project there must be lots of scheduled releases.

To whom it may concern,

As a lifelong BC resident and dedicated explorer of this province's waterways via kayak & canoe, I am deeply disturbed by the notion of hydroelectric development threatening the Harrison Lake region. The assortment of creeks being targeted in this area are further examples of what the rest of the world thinks of when defining the beauty of our province. 

While I understand that BC remains rich in hydroelectric potential, the recent pursuit of Run-of-River development in remote, sensitive wildlife habitat environments is not acceptable. We are meddling with more than what any current assessment criterion is capable of understanding. 
For these reasons, I strongly oppose the idea of developing Big Silver, Tretheway and Shovel Creeks for unwarranted hydroelectric development. 

I can only wonder what the rest of the world thinks of BC now after learning that such proposals even exist. 

February 6, 2012

Please see that Tretheway Creek is saved from yet another private company.  The track record of Cloudworks (now Innergex) is not good, environmental standards are low, and MoE oversight is sorely limited: The water in Tretheway and other Creeks is in danger of serious misuse. Not only should the creek water be kept flowing for its sustainable nurturing of life in the area, it should never be tampered with (let-alone destroyed) to feed a private-power-for-profit venture that runs counter to our public-power-control needs .

January 28, 2012

NO freakin way are you going to destroy fish habitat! It's illegal !
Take your pipes and hit the road.

January 27, 2012

January 23, 2012

Trethaway River is a navigable waterway, and provides a recreational resource that is very highly valued.

The proposed mitigation measures do not adequately serve the needs of this community.

Please reconsider the IPP project in its entirety. Failing that, please take measures to ensure that the recreational whitewater paddling community in British Columbia is given an opportunity to shape the compensation or mitigation measures are for this given navigable waterway.

January 18, 2012

Every year thousands of people visit Harrison Lake to hike the surrounding hills and fish in the creeks that flow in to the lake. And it’s not just tourists and nature lovers who you will find in those hills. They are also home to western screech owl, tailed frog, harlequin duck, northern goshawk, spotted owl, red legged frog, pacific water shrew and grizzly bears, many of which are listed as species at risk. 
The surrounding creeks are also home to rainbow trout and dolly varden, steelhead, coho, sockeye, longnose dace and cutthroat trout, including Shovel and Big Silver creeks, which are both fish-bearing streams. 
All of this is at risk if we allow Cloudworks Energy Inc. and their new owners Innergex Renewable Energy Inc. to fragment this wilderness with roads and transmission line right of ways. 
Both companies have records of being involved in controversial projects. Freedom of Information requests done by the Wilderness Committee showed that Cloudworks’ nearby Upper Harrison  project and their Rutherford Creek project in the Sea to Sky region had  used poor construction practices, caused destruction of fish habitat, damaged wetland habitat, logged streambanks, illegally built a bridge, and illegally harvested wood and  caused numerous landslides. 

Dear Sir or Madam,
I am writing to express my VEHEMENT OPPOSITION to the proposed Big Silver creek waterpower project. I am opposed to these private power projects in general - as far as I can tell they have been a fiasco - put in against public will. And when the public opposed the first project in Ashlu Creek, the government imposed a law that over-rode the voice and will of the public that the government is meant to serve.

I am opposed to the Big Silvercreek Waterpower Project in particular, because of the potential devastation that I believe this project poses to the natural habitat in the Harrison Lake area. This power project would negatively impact tourism - specifically, the thousands of people who visit Harrison Lake to hike the surrounding hills and fish in the creeks that flow in to the lake. 

And deforestation, roadways and choked waterways in that area, that the project would bring, will - most certainly - have a negative impact on the wildlife in that area, such as western screech owl, tailed frog, harlequin duck, northern goshawk, spotted owl, red legged frog, pacific water shrew and grizzly bears. MANY OF THESE ARE LISTED AS SPECIES AT RISK. 

In addition, re-channeling the water into man-made pipes will, I believe, negatively impact the Shovel and Big Silver creeks, which are both fish-bearing streams. 

I believe that all of this is at risk if you allow Cloudworks Energy Inc. and/or Innergex Renewable Energy Inc. to fragment this wilderness with roads and transmission line right of ways. 

I understand that both companies have records of being involved in controversial projects. Freedom of Information requests done by the Wilderness Committee showed that Cloudworks’ nearby Upper Harrison project and their Rutherford Creek project in the Sea to Sky region had  used poor construction practices, caused destruction of fish habitat, damaged wetland habitat, logged streambanks, illegally built a bridge, and illegally harvested wood and  caused numerous landslides. 

Every year thousands of people visit Harrison Lake to hike the surrounding hills and fish in the creeks that flow in to the lake. And it’s not just tourists and nature lovers who you will find in those hills. They are also home to western screech owl, tailed frog, harlequin duck, northern goshawk, spotted owl, red legged frog, pacific water shrew and grizzly bears, many of which are listed as species at risk.

The surrounding creeks are also home to rainbow trout and dolly varden, steelhead, coho, sockeye, longnose dace and cutthroat trout, including Shovel and Big Silver creeks, which are both fish-bearing streams.  

All of this is at risk if we allow Cloudworks Energy Inc. and their new owners Innergex Renewable Energy Inc. to fragment this wilderness with roads and transmission line right of ways.

Both companies have records of being involved in controversial projects. Freedom of Information requests done by the Wilderness Committee showed that Cloudworks’ nearby Upper Harrison project and their Rutherford Creek project in the Sea to Sky region had used poor construction practices, caused destruction of fish habitat, damaged wetland habitat, logged streambanks, illegally built a bridge, and illegally harvested wood and caused numerous landslides.

Innergex, furthermore, is the current owner of the Ashlu project near Squamish, which sparked much of the opposition to private power projects in BC when it was forced through over the objections of the local Regional District when the provincial government passed Bill 30.

Clearly we need to stop these companies from getting their hands on any more of our streams and rivers. That is 

The proposed  benefits  of this project do not outweight the losses to  habitat, fish and wildlife, and respectful human stewardship of this area.
Why is a company with a background of questionable construction practices even being considered? 
Please register this comment.

Our creeks and streams are invaluable resources and must be protected.  NO to anymore power projects on creeks and rivers in BC.

I want to keep our rivers wild. There is something about them that is part of my soul. I can sit by a flowing river in the wilderness and feel at peace. There is a well-known phase which goes something like this: 'in wildness is the preservation of the world'. I agree.
In many years my summer holidays have involved a canoe trip lasting several days on a wilderness river. I come home refreshed, having not thought about the rat race for this time. 
In the case of Big Silver, I have spent a few weekends there, helping to train novices in river canoeing. It is a good place for that, and one can camp right beside the river.
Converting it into a power project would be a retrograde step. We need the wilderness and the flowing waters in it. 
As well, there is no overwhelming need for the electrical power it would produce. As I understand it every one of these power projects is going to end up costing us all money unnecessarily.
We have to start protecting our Mother Nature!

Let's find better ways to utilize out natural resources for the long-term picture, instead of selling them and undermining the natural beauty we have here in British Columbia, and surrounding regions.

Thanks - What is the greatest good for the greatest number of dynamics is the real question.

January 15, 2012

I want to keep our rivers and creeks wild. There is something about them that is part of my soul. I can sit by a flowing water in the wilderness and feel at peace. There is a well-known phase which goes something like this: 'in wildness is the preservation of the world'. I agree.
In many years my summer holidays have involved a canoe trip lasting several days on a wilderness river. I come home refreshed, having not thought about the rat race for this time. 
Converting Tretheway into a power project would be a retrograde step. We need the wilderness and the flowing waters in it. 
As well, there is no overwhelming need for the electrical power it would produce. As I understand it every one of these power projects is going to end up costing us all money unnecessarily.

January 12, 2012

I'm opposed to all 4 IPP‟s proposed by Cloudworks Energy in the Harrison Lake area (Treatheway, Shovel, Big Silver).

I travel to BC to enjoy the beauty of nature. In simple terms, I spend money in the province solely based on the natural resources that you are working to destroy.

The damage that will be caused by the proposed projects is irreversible, and will change the face of B.C. forever. 

Much has already gone. Please protect the few beautiful pristine locations we have left. Whether it be for environmental reasons, for future generations, or for the enjoyment of current residents, I urge you to leave these places as they are.

January 11, 2012

To those concerned,

Please reconsider dewatering and permanently scarring this pristine mountain stream.  Since many of our rivers in the southeastern United States are already dammed up, dewatered and generally severely impaired by man, we make regular pilgrimages to southwestern British Columbia to enjoy NATURALLY FLOWING rivers and creeks.  Tretheway Creek in specific, has piqued my interest, after extensive word of mouth describing it as one of the most special gorges in the area.  Canada has the richest abundance of natural resources on the continent, if not the world.  Don't spoil them.  They are your heritage, not a mass array of short-sighted investments that only will leave a wake of desctruction.  How often I and many of my peers across the country visit and pump money into the local economy is directly related to how many of the streams in British Columbia are sold for dollars.  

While it would seem only fair that if water the public has the right to enjoy in its natural state is going to be taken away, then there should be recreational releases for any user group who requests them, let's not kid ourselves that much more important than user access to the water is the protection of these watersheds.  

I am against the proposed development on Big Silver Creek. As a whitewater kayaker, I value the whitewater resources that BC has, and travel a long way to access them. Please do not dewater this creek. I know that Trethaway Creek has some beautiful waterfalls that I do not want to see ruined.