Projet de réservoir hors cours d'eau de Springbank

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Attachment Stoney Nakoda Nations to IAAC - PCP Comments on Project Change

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Stoney Nakoda Nations
  • Numéro de référence : 1411
  • Présenté : 2024-12-13 18 h 23
  • Mis à jour : 2025-02-04 16 h 18
  • Raison : Commentaire mis à jour pour cause administrative
  • Phase du projet : Postdécision
  • Avis de participation : Avis public - Période de consultation publique sur les modifications proposées à la déclaration de décision
  • See the attached submission / Veuillez consulter la pièce ci-jointe  
  • Inclus pièce jointe
  • Stoney Nakoda Nations – Comments on the Proposed Changes to the Springbank Off-Stream Reservoir Project Page | 1 December 13, 2024 Submitted via Email Veronica Mossop Analyst, Decision Statements Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario, K1A 0H3 Veronica.Mossop@iaac-aeic.gc.ca Dear Ms. Mossop, RE: Stoney Nakoda Nations – Review of Proposed Changes to the Springbank Off- Stream Reservoir Project This letter is submitted to the Impact Assessment Agency of Canada (IAAC) by the Stoney Consultation Office. The Stoney Consultation Office works with Stoney Tribal Administration which represents the Stoney Nakoda Nations (“Stoney”), comprising the Bearspaw First Nation, Goodstoney First Nation, and Chiniki First Nation. The Chiefs and Councils of these three Nations have the authority to protect the collective rights and interests of their members as recognized by Treaty No. 7 and the Natural Resources Transfer Agreement, 1930, and protected by Section 35 of the Constitution Act, 1982 (collectively referred to as “Section 35 rights”). The IAAC notified Stoney about proposed changes to the Alberta Transportation and Economic Corridors (ATEC) Springbank Off-Stream Reservoir Project (the “Project”), requesting feedback by December 13, 2024. Along with its notification, the IAAC included ATEC’s May 2, 2023, memorandum to the IAAC requesting amendments to IAAC approval conditions for the Project, which included Stantec’s comments on revised fencing installation. Stoney understands that the IAAC paused its review of ATEC’s proposed changes in 2023, pending amendments to the Impact Assessment Act (IAA). The IAAC’s review, now including updated amendments from ATEC, ...
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Attachment Siksika Nation to IAAC - PCP Comments on Project Change

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Siksika Nation
  • Numéro de référence : 1412
  • Présenté : 2024-12-13 16 h 38
  • Mis à jour : 2025-02-04 16 h 17
  • Raison : Commentaire mis à jour pour cause administrative
  • Phase du projet : Postdécision
  • Avis de participation : Avis public - Période de consultation publique sur les modifications proposées à la déclaration de décision
  • See the attached submission / Veuillez consulter la pièce ci-jointe  
  • Inclus pièce jointe
  • December 13, 2024 Via email (Veronica.Mossop@iaac-aeic.gc.ca) Attn: Veronica Mossop Analyst, Decision Statements Impact Assessment Agency of Canada Dear Ms. Mossop, Re: Siksika’s response to IAAC’s draft Analysis Report: Analysis of TEC's Proposed Change to the Springbank Off-Stream Reservoir Project I write as Consultation Coordinator for the Siksika Nation (“Siksika”) regarding the Springbank Off-Stream Reservoir Project (the “Project”). I write to respond to the Impact Assessment Agency of Canada’s (“IAAC”) draft Analysis Report titled Analysis of TEC's Proposed Change to the Springbank Off-Stream Reservoir Project. Background A main feature of the Project is that the proposed reservoir will be dry for long periods of time and has the potential to provide consistent, protected, and prioritized access to Siksika and other Indigenous groups to carry out traditional activities such as hunting, fishing, and trapping. The Project was approved by the IAAC in 2021 with conditions (the “Project Conditions”).1 The Project area has privately-owned parcels of land that were originally supposed to be purchased by Alberta Transportation and Economic Corridors (“TEC”). These parcels border two roadways and used barbed wire fencing to prevent cattle from entering the roads. TEC was supposed to purchase these parcels from the landowners and replace the barbed wire with wildlife-friendly fencing. However, TEC entered into right-of-way agreements instead of land purchase agreements. As a result, the general public and Indigenous groups will not have direct access to these private parcels unless they seek private arrangements with the land owners. Proposal from TEC regarding fencing TEC is ...
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Attachment Please do not kill fishes for pollution monitoring

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Nicole Corrado
  • Numéro de référence : 1409
  • Présenté : 2024-12-13 15 h 02
  • ?https://iaac-aeic.gc.ca/050/evaluations/document/159604?culture=en-CA   https://iaac-aeic.gc.ca/050/evaluations/proj/80123?culture=en-CA   While there are a lot of good plans to save fishes, amphibians, birds, and other animals during construction, there is also a very unfortunate mandate in this document to kill 12 predator fishes and one lower food chain fish from each site to dissect them and test their muscles and organs for methyl mercury and other chemicals.  This is said to test their meat for contaminants that may harm human consumers.  While human health concerns are huge, as many Indigenous people rely on fishes for food, it would be kinder to either take samples from fishes who were already killed for food (instead of killing them for testing), or, better yet, take non lethal muscle biopsies and blood tests from the fishes.  We use cruelty free methods to bio monitor humans.     ??I noticed a lot of wildlife live here.  ?????Please preserve the trees at this location. Please do not harm animals with this project. Please do not use animal testing for pollution and effluent monitoring. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish ?Please work with the Canadian Centre for the Alternatives to Animal Methods. https://www.uwindsor.ca/ccaam/ Please only use non lethal ways to live with geese, beavers, and other wildlife. Develop a Living With Coyotes program with the animal welfare organization Coyote Watch Canada. www.coyotewatchcanada.com Please only use non lethal ways to manage wildlife. There are humane, non lethal ways to deal with beavers. Here's a great resource. ...

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Attachment Tsuut'ina Nation to IAAC - PCP Comments on Project Change

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Tsuut'ina Nation
  • Numéro de référence : 1410
  • Présenté : 2024-12-11 6 h 01
  • Mis à jour : 2025-02-04 16 h 18
  • Raison : Commentaire mis à jour pour cause administrative
  • Phase du projet : Postdécision
  • Avis de participation : Avis public - Période de consultation publique sur les modifications proposées à la déclaration de décision
  • See the attached submission / Veuillez consulter la pièce ci-jointe  
  • Inclus pièce jointe
  • <Original signed by>

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Attachment FW: Springbank Off-Stream Reservoir Project SR-1

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Stoney Nakoda Nations
  • Numéro de référence : 1379
  • Présenté : 2021-06-29
  • Please see the attached submission.
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  • Page 1 of 2 June 29, 2021 The Honourable Jonathan Wilkinson, P.C., M.P. Minister of Environment and Climate Change Ottawa, Canada, K1A-0H3 Via email : iaac.minister-ministre.aeic@canada.ca Re: Stoney Nakoda Non-Objection Letter to Springbank Off-Stream Reservoir Project. Dear Minister Wilkinson, The Stoney Nakoda Nations (SNN) are comprised of the Bearspaw First Nation, Chiniki First Nation, and Wesley First Nation that are situated on: the Stoney Indian Reserves #142, 143, 144 at Morley, Alberta; the Eden Valley Indian Reserve #216; the Rabbit Lake Indian Reserve #142B; and the Bighorn Indian Reserve #144A. The SNN were signatories to Treaty No. 7 in 1877. The Stoney Nakoda have reached an understanding with Alberta Transportation regarding the above noted project. The Stoney Nakoda do not object to the above-named application, on the basis that Alberta Transportation has adequately addressed our project-specific concerns. The Stoney Nakoda Nations are therefore of the view that Alberta Transportation’s consultation should be deemed adequate. As a result of our work with Alberta Transportation, the Stoney Nakoda support the development of the project. Nothing in this letter shall be interpreted in a manner that extinguishes, abrogates or diminishes the Stoney Nakoda Nation’s Aboriginal or Treaty Rights, including Aboriginal Title, which are protected under section 35 of the Constitution Act, 1982 and is without prejudice to its assertions and claims within the Stoney Nakoda Nations Aboriginal Title Claim (Action No. 0301-19586). Sincerely, William Snow Acting Director of Consultation Stoney Tribal Administration C.C: Chief Darcy Dixon Chief Aaron Young Stoney ...
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Attachment Springbank Dam project should not go ahead

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Cheryl Curtis
  • Numéro de référence : 1367
  • Présenté : 2021-06-23 20 h 22
  • I do not believe this project has thoroughly examined the science behind the design. Plus how can the government force out families who have lived and farmed in the area for over 100 years? It seems so wrong that a project designed to help Calgary avoid flooding would hurt another community in the process. Please do not give the go ahead for this project make them rethink a different plan.

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Attachment FW: concerns - SR1

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Jan Erisman
  • Numéro de référence : 1378
  • Présenté : 2021-05-30
  • Good afternoon, Re; SR1 dry diversion - changes to information during the NRCB hearing   The dam takes 30-40 days to drain and during that time the shoreline will be producing fugitive dust with our constant winds. Biologists are supposed to be stunning fish and removing them.  Fugitive dust is an invisible occupational health hazard.  This means that the tourism months of June, July, August will have unacceptable levels of invisible dust at the very least in a tourism corridor. A high water table reduces the weight the land can take by ¾.  This area has a high water table.  Has that been accounted for?  It has not been mentioned. During flood season basements flood at 8’-0.  If the channel is 82’-20’ deep how will it not fill with groundwater?  Therefore the channel can not take the same amount of water off the river flow.  Will it always be partially full of water?  Is this a hazard? The fact that the air quality tests now show an unacceptable level of fugitive dust and the maps show that it goes into Calgary and to the schools, how is this going to be controlled? Alberta Environment was not at the hearing but they are the body that will control the diversion after construction and all of the processes.  Alberta Transportation would answer all process questions that Alberta Environment will deal with it.  That is not an answer.  This included everything from Indigenous questions to emergency ...

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Attachment springbank_MNAR3_Apeiron_29aug2019.pdf

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Métis Nation of Alberta, Region 3 & Apeiron Resources Ltd.
  • Numéro de référence : 1381
  • Présenté : 2021-05-21
  • Please see the attached submission.
  • Inclus pièce jointe
  • Métis Nation of Alberta, Region 3 
 Métis Cultural Heritage Resources and Traditional Knowledge Report 
 
 Springbank Off-Stream Reservoir Project Alberta Transportation August 29, 2019 
 MNAR3 Métis Cultural Heritage Resources and Traditional Knowledge Report 
 Springbank Off-Stream Reservoir Project This report is only intended for the current phase of the project (i.e. single-use only). The information contained in this report is the property of Métis Nation of Alberta, Region 3. No part of this report may be reproduced, stored in a retrieval system or transmitted, in any form or by any means, without the prior written consent of Métis Nation of Alberta, Region 3. 
 ! !3 MNAR3 Métis Cultural Heritage Resources and Traditional Knowledge Report 
 Springbank Off-Stream Reservoir Project Contents Contents 4 Report Preparation and Acknowledgements 5 Abbreviations 5 List of Figures 5 Introduction 6 Project Significance to the MNAR3 6 Métis Traditional Use around the project area 7 Métis Historical Land Use around the Project Area 9 HRIA Evaluation 14 MNAR3 Concerns about the project 15 Management Recommendations 20 References Cited 22 ! !4 MNAR3 Métis Cultural Heritage Resources and Traditional Knowledge Report 
 Springbank Off-Stream Reservoir Project Report Preparation and Acknowledgements Métis Nation of Alberta, Region 3 Lawrence Gervais, President Judy Gentes, Vice-President Apeiron Resources Ltd. Team Peter McPherson Dr. Kisha Supernant Tess Evenson Sarah Graham Abbreviations AT Alberta Transportation CPR Canadian Pacific Railroad EIA Environmental Impact Assessment HRIA Historical Resources Impact Assessment HBC Hudson’s Bay ...
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Attachment ATTN: Jennifer Howe and Barb Pullishy

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Siksika Nation
  • Numéro de référence : 1362
  • Présenté : 2021-05-13
  • My apologies,   Here you go Jennifer,   Best,     Richard Sparvier, B’Comm Siksika Nation, Tribal Manager   Cellular: <personal information removed> Office: (403) 734-5184 Email: RichardS@siksikanation.com     CONFIDENTIALITY: This e-mail message (including attachments, if any) is confidential and is intended only for the addressee. Any unauthorized use or disclosure is strictly prohibited. Disclosure of this e-mail to anyone other than the intended addressee does not constitute waiver of privilege. If you have received this communication in error, please notify us immediately and delete this. Thank you for your cooperation.       From: "Howe, Jennifer (IAAC/AEIC)" <jennifer.howe@canada.ca> Date: Thursday, March 25, 2021 at 10:28 AM To: Richard S <RichardS@siksikanation.com> Subject: RE: ATTN: Jennifer Howe and Barb Pullishy   Hi Richard,   I noticed there is no attachment on the email. Please forward the letter when you can. ...
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  • <original signed by> <personal information removed>

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Attachment Spring Bank

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Fisheries and Oceans Canada
  • Numéro de référence : 1365
  • Présenté : 2021-04-30
  • Please see the attached submission.
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  • .../2 Fisheries and Oceans Canada Pêches et Océans Canada Ontario and Prairie Region Fish and Fish Habitat Protection Program Burlington, Ontario L7S 1A1 Région de l'Ontario et des Prairies Programme de la protection du poisson et de son habitat Burlington (Ontario) L7S 1A1 April 30, 2021 Our file Notre référence 16-HCAA-00537 Barb Pullishy Impact Assessment Agency of Canada Attention: Jennifer Howe, Project Manager, Prairie and Northern Region 1145-9700 Jasper Avenue Edmonton, Alberta T5J 4C3 Subject: Springbank Off-Stream Reservoir Project – Advice under Section 79 of the Species at Risk Act and Comment on Conceptual Offset Measures Plan The Fish and Fish Habitat Protection Program (the Program) of Fisheries and Oceans Canada (DFO) indicated to the Impact Assessment Agency of Canada on February 3 2021, that the draft Environmental Assessment (EA) Report (dated January 2021) for the Springbank Off-Stream Reservoir Project did not consider: a jeopardy assessment for Bull Trout (Threatened, Schedule 1), a listed aquatic Species at Risk; and measures to offset residual impacts to fish and fish habitat, as well as aquatic species at risk and their critical habitat. Section 79(1) and (2) of the Species at Risk Act (SARA) states: 79 (1) Every person who is required by or under an Act of Parliament to ensure that an assessment of the environmental effects of a project is conducted, and every authority who makes a determination under paragraph 82(a) or (b) of the Impact Assessment Act in relation to a project, must, without delay, notify the competent minister or ministers in writing of the ...
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Attachment NRCB Hearing Outcomes & SCA Comments: SR1 Project

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Springbank Community Association
  • Numéro de référence : 1376
  • Présenté : 2021-04-29
  • Please see the attached submission
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  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: Biodiversity and Fish Summary of Findings: • Offsetting plans and costs for wetlands and fish offsets are missing from the Proponent’s submissions. • Fish impacts are negative and rescue operations, as discussed by the Proponent at the NRCB hearing are costly and unrealistic. • SR1 contravenes the SSRP’s statements on intact native grasslands. • Wetland Policy • Desktop analysis for Elk mapping is inconsistent with observed elk in the area. • SR1 is at odds with Alberta Wetland Policy. • Cumulative impacts have not been adequately considered and the regional assessment area is not consistent with the Terms of Reference. Offsetting Plans: The Stoney Nakoda raised omissions in the offsetting plans for fish, which they have apparently been told will include offsetting habitat on the Bow River. Until the NRCB hearing, we hadn’t heard of this plan at all! We do not see plans of any sort for wetland offsets even though there is permanent loss of wetlands. We are totally unclear if there are any other offsets required for the loss of native fescue grasslands, which are unlikely to be successfully re-established, according to both Cliff Wallis and Dr Osko. Does IAAC require details on these offsetting plans in advance of the final report for SR1? Additionally, no costs have been provided by the Proponent for any offsetting plans which appears to be a gap in the submissions. 2 Fish: The Proponent should be required to estimate fish entrainment at the various SR1 structures in various ...
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  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: SR1 Benefits, Costs and the Impact of the Bow River Reservoir Summary of Findings: SR1 flood-only design is dependent on new drought management capabilities on the Bow River. SR1 benefits are lower than MC1 benefits. SR1 capital costs continue to increase while operating costs are not disclosed. SR1 operating costs estimates are insufficient. SR1 benefit/cost ratio does not appear to include the worst case for operating costs in a design flood, but assumes worst case scenario is avoided in the “benefits” calculations. Drought on the Bow and Flood Mitigation on the Elbow Beginning on page 102 of Ex 349, Mr Rae asks a series of questions about drought and the scope of the SR1 analysis. This is a crucial line of questioning that we hope regulators are taking seriously. In Ex 325, the Proponent states that drought management for the City of Calgary will be taken care of by a new (as yet conceptual) project on the Bow River. Therefore, the Proponent is asking regulators to approve SR1 – a flood mitigation only project – and disregard its inability to address drought based on a theory that drought mitigation will take place on the Bow River. 2 3 4 It is clear that the timelines for a Bow River project are lengthy, with a project possibly more than a decade away (if at all). This is illustrated by the following exchange in Ex 357, pdf page 73 in an exchange between Mr Rae from Stoney Nakoda and the City of Calgary: . Should regulators approve SR1, a single-purpose ...
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Attachment Springbank Conceptual Offset Measures Plan progress

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Stantec
  • Numéro de référence : 1366
  • Présenté : 2021-04-29
  • Please see the attached submission.
  • Inclus pièce jointe
  • Memo To: Matthew Hebert From: Lacey AuCoin Alberta Transportation Stantec Consulting Ltd File: 11073396 Date: April 29, 2021 Reference: Conceptual Offset Measures Plan for the Springbank Off-stream Reservoir Project Alberta Transportation is required to prepare an Offset Measures Plan for Fisheries and Oceans Canada (DFO) as part of the Fisheries Act authorization process for the Springbank Off-stream Reservoir Project (the Project; DFO file no. 16-HCAA-00537). Offsetting measures are required to counterbalance the potential for residual harmful alteration, disruption, or destruction (HADD) of fish habitat, or death of fish, as a result of Project activities. Alberta Transportation is committed to offsetting residual effects to fish and fish habitat, including bull trout and its critical habitat, that cannot be mitigated and is committed to developing an Offset Measures Plan that meets the conditions of both the Species at Risk Act and the Fisheries Act. This memo presents Alberta Transportation’s Conceptual Offset Measures Plan for the Project in consideration of the Policy for applying measures to offset adverse effects on fish and fish habitat under the Fisheries Act (DFO, 2019) and stakeholder feedback. This memo discusses: • Offsetting Considerations • Conceptual Offset Measures Plan Approach − Proposed Adaptive Offset Measures Approach − Potential Synergies − Entrainment Estimates and Death of Fish Estimates • Proposed Offset Measures for HADD and Death of Fish Associated with the Elbow River Fish Community • Proposed Offset Measures for HADD and Death of Fish Associated with Bull Trout and its Critical Habitat • Next Steps Alberta Transportation understands ...
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Attachment Required NRCB Hearing Outcomes & SCA Comments: SR1 Project

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Springbank Community Association
  • Numéro de référence : 1364
  • Présenté : 2021-04-28
  • Hello Ms Howe,   The Springbank Community Association submits the attached comments to IAAC following the SR1 NRCB hearing.   We may have additional comments as we are still working through a review of the hearing transcripts.      Regards,     -- Karin Hunter President   https://springbankcommunity.com/  https://www.facebook.com/springbankcommunityassociation
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  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: Sediment & Air Quality Summary of Findings: The Proponent released new information on sediment and air quality on March 12, 2021. This new information has drastic implications for the Project and that impact the conclusions reached by IAAC on human health and on the environmental impact of the Project. Sedimentation is a serious environmental and health outcome that affects IAAC’s report and conditions. Sediment: In our view, sediment is the most problematic operational and environmental outcome of SR1. New sediment maps released by the Proponent in Exhibit 327 pdf page 190 show that sediments over 10cm in depth have increased 3x since the EIA in 2018, from 260 acres to 790 (early release) and 832 acres (late release) for a design flood! This change, dated March 12, is so material as to cause this project to be rejected. The magnitude of this change is completely unacceptable at this late stage. When did the Proponent realize this increase and what was the delay between identifying this increase and notifying the public? From pg 190, Ex 327, regarding sediment modelling: From Page 196: 2 From the EIA (Ex 255, RVC Report, pdf pg 11): 3 What are the impacts of this additional 530 to 570 acres of sediment accumulation >10cm? How does this impact plants, traditional uses, biodiversity? How does this impact the cost of reclamation post-flood? How does this impact the post-flood environment? In Ex 324, pdf page 17, the Proponent states “Desired cover is expected within one to ...
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  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: SR1 Flood Effectiveness Summary of Findings: The MC1 project is superior to SR1 for flood mitigation for all communities and at flood events far larger than the 2013 event. This is demonstrated through a comparison of flow rates. This information was available in March 2016, at the latest, and was reaffirmed in 2017 reports for MC1. Why weren’t SR1 and MC1 compared using flow rates? Why was the basis of the comparison between the two projects total storage volume? Were flow rates accidentally overlooked or was this comparison intentionally avoided? Storage Volumes vs River Flow Rates: An unacceptable oversight At the NRCB hearing for SR1, Alberta Transportation (AT) stated clearly that floods are caused by flow rates, not volumes. NRCB Exhibit 350 Transcript page 156: Matt Wood stated “It is the peak, you know, that is the most important when it comes to flood damages.” Yet, flow rates were not used as an evaluation criterion to choose between SR1 and MC1 (or any other alternative, for that matter). Is an oversight of this magnitude acceptable? This is an oversight that undermines the entire justification for choosing SR1 over MC1! The long-term nature of this project – hundreds of years - necessitates that it is considered with all seriousness and thoroughness. It is evident based on the rate comparison that the decision to choose SR1 was not thorough. A thorough analysis would have considered rates and performed rate analysis for various flood hydrographs! This oversight cannot be ...
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Attachment AT Responses to IAAC Clarification Questions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Alberta Transportation
  • Numéro de référence : 1374
  • Présenté : 2021-04-23
  • Please see the attached submission.
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  • Alberta Transportation Springbank Off-stream Reservoir Project Response to Part B IAAC Follow-up Questions April 2021 ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART B IAAC FOLLOW-UP QUESTIONS i Table of Contents PART B ....................................................................................................................................... 1 Question 1 ...................................................................................................................... 1 Question 2 ...................................................................................................................... 2 Question 3 ...................................................................................................................... 2 Question 4 .................................................................................................................... 13 LIST OF TABLES Table 1 Wetland Flood Duration .................................................................................... 7 ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART B IAAC FOLLOW-UP QUESTIONS ii ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART B IAAC FOLLOW-UP QUESTIONS 1 PART B With respect to the comment indicating that there is the possibility of water being held longer for emergencies and other unplanned events, some more information is required to understand the potential effects of such circumstances. Question 1 Request: In what circumstances would water be held longer than the late release scenarios? Provide all circumstances in which this may ...
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Attachment SR1 and NRCB Hearing

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Lee Drewry
  • Numéro de référence : 1363
  • Présenté : 2021-04-22
  • It is my understanding that, although a Joint Review Panel was not agreed to by the IAAC, the IAAC would be monitoring and considering the information raised during the NRCB Hearing on the SR1 Project in its final determination of the approval or rejection of this project.   The attached document outlines some of the many concerns raised at the recent NRCB Hearing regarding the SR1 project.  The evidence provided during the NRCB Hearing differs in many significant ways from the overly positive views outlined in the Proponent’s Environmental Impact Statement submitted to the IAAC in 2018.  It is my belief that this information should cause the IAAC to revisit its Draft Environmental Assessment Report.  The environmental consequences of the SR1 project are much worse than was reported in 2018.  Further, the consultation record provided by the Proponent, with regard to both First Nations and the Public, seems to be more activity than outcome focused.  There was a lot of focus on the volume of meetings and not on any meaningful collaboration or consensus building.  The failures of the consulting approach of the Proponent is witnessed by the numerous “facilitation payments” made to dissenting bodies (both First Nations and municipal governments) for them to withdraw their opposition.   I sincerely hope that the IAAC have closely monitored the Hearing and reviewed the evidence and transcripts from it.  If so, then the issues raised in the attached document will have already been discovered by the IAAC.    The evidence suggests that the Project results in uneven protection to ...
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  • Springbank Reservoir (SR1) - Summary of Relevant Information from NRCB Hearing The following is a summary of some of the information provided at the NRCB Hearing into the SR1 project that is relevant to the decision made by IAAC regarding the environmental impacts of the project. Project Benefits It is clear from the evidence presented at the Hearing that the benefits provided to Albertans from the SR1 project are uneven. The project provides 1 in 200 year flood protection to residents downstream from the Glenmore Reservoir in Calgary and significantly less than that to residents upstream of the Glenmore Reservoir in Calgary and residents in Rocky View County downstream from SR1. Residents in the towns of Redwood Meadows (on the Tsuut’ina Nation) and Bragg Creek also receive less than 1 in 200 year flood protection from berms to be built in those towns. Interestingly, in a 2015 presentation to the Calgary River Communities Action Group, the Proponent asserted that berms and dykes inevitably fail. From this presentation - “we shouldn’t consider ourselves safe from flooding with just one line of defense eg: dykes”. This discrepancy in flood protection provided by SR1, in contrast to an alternative project further upstream (MC1) that provides equal protection to all residents along the Elbow River, is not in the public interest. Evidence was presented that the major influencer of floods is the flow rates of the river (Exhibit 350 Transcript page 156: Matt Wood (Stantec/Proponent) stated “It is the peak, you know, that is the most important when it comes to flood damages, not necessarily the volume.”). Yet, the Proponent based their analysis on volume of water to be stored, ...
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Attachment AT Responses to IAAC Clarification Questions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Alberta Transportation
  • Numéro de référence : 1375
  • Présenté : 2021-04-20
  • Please see the attached submission.
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  • Alberta Transportation Springbank Off-stream Reservoir Project Response to Part A IAAC Follow-up Questions April 2021 ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART A IAAC FOLLOW-UP QUESTIONS i Table of Contents PART A ....................................................................................................................................... 1 Question 1 ...................................................................................................................... 1 Question 2 ...................................................................................................................... 6 Question 3 .................................................................................................................... 10 Question 4 .................................................................................................................... 11 LIST OF FIGURES Figure 1 Project Overview ................................................................................................ 5 ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART A IAAC FOLLOW-UP QUESTIONS ii ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO PART A IAAC FOLLOW-UP QUESTIONS 1 PART A Follow up on the suggested changes to the draft potential conditions as discussed by the Decision Statement Team. Question 1 A. BACKGROUND CONTEXT Potential conditions under the Canadian Environmental Assessment Act, 2012 7.6 The Proponent shall decommission and plug off water wells located within the project development area that are not used to monitor ...
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Attachment Review of the Springbank Off-Stream Reservoir Project Draft Environmental Assessment Report and Potential Conditions under the Canadian Environmental Assessment Act, 2012

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Bill Snow and the Stoney Nakoda Nations
  • Numéro de référence : 1358
  • Présenté : 2021-03-31
  • Please see the attached submission.
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  • March 31, 2021 Springbank Off-Stream Reservoir Project Impact Assessment Agency of Canada Jennifer Howe, Project Manager Canada Place 9700 Jasper Avenue, Suite 1145 Edmonton, Alberta, T5J 4C3 Email: jennifer.howe@canada.ca General Email: IAAC.Springbank.AEIC@canada.ca Dear Jennifer: Re: Review of the Springbank Off-Stream Reservoir Project Draft Environmental Assessment Report and Potential Conditions under the Canadian Environmental Assessment Act, 2012 The Stoney Tribal Administration represents the three distinct Stoney Nakoda Nations (“SNN”): Wesley First Nation, Bearspaw First Nation and Chiniki First Nation. The Chiefs and Councils of the SNN have the authority to protect the collective rights and interests of the SNN as recognized by Treaty 7 and the Natural Resources Transfer Act, 1930 (“NRTA”) and protected by Section 35 of the Constitution Act, 1982 (collectively known as “Section 35 Rights”). SNN’s Section 35 Rights include hunting as laid out in Treaty 7, and the right to hunt, trap and fish as detailed in the NRTA. As well as rights not including land, water and resource rights, the right to self-govern, the right to practice SNN culture, the right to speak SNN language, and any right flowing from these aspects (e.g., passing on knowledge to the next generation). This document includes a review of the draft Environmental Assessment (“EA”) report which presents the Impact Assessment Agency of Canada’s (“IAAC”) conclusions on whether the Springbank Off-Stream Reservoir Project (the “Project”) is likely to cause significant adverse environmental effects after taking into account the proposed key mitigation measures. It is our understanding from this report that comments ...
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Attachment Review of Spring Bank Off-Stream Reservoir Project Environmental Impact Statement, March 2018

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Bill Snow and the Stoney Nakoda Nations
  • Numéro de référence : 1360
  • Présenté : 2021-03-31
  • Please see the attached submission.
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  • Stoney Nakoda Nations Assessment of Springbank Off-Stream Reservoir SR-1 EIS 1 Stoney Nakoda Nations Review of Spring Bank Off-Stream Reservoir Project Environmental Impact Statement, March 2018. Prepared by Stoney Consultation March 26, 2021 Project Overview Alberta Transportation (AT or the Proponent) is proposing the construction of the Springbank Off-Stream Reservoir SR-1 (the Project) that includes a storage reservoir, diversion channel, dam structures and outlet structures. The proposed Project is located approximately 18.5 kilometers west of Calgary, Alberta; along Highway 22 and south of Highway 1 (Figure 1) (IAAC 2021). The aim of the Project is to mitigate flood impacts to the City of Calgary. The proposed Project would be located in a floodplain of the Elbow River and its tributaries and is anticipating a peak diversion flow of 600 cubic meters per second during flood events. The proposed Project is a dry dam, meaning that the Project area will remain dry until a flood event occurs and would store up to 77,771,000 metres cubed of diverted water at maximum capacity (IAAC 2021). Diverted water would be gradually returned to the Elbow River once flooding has subsided. The proposed Project will be assessed under CEAA 2012 and the Alberta Environmental Enhancement and Protection Act. The Impact Assessment Agency of Canada (IAAC) is required to undertake a federal environmental impact assessment (EA) as the proposed Project entails, “the construction, operation, decommissioning and abandonment of a new structure for the diversion of 10 000 000 m3 per year or more of water from a natural water body into another natural water body” (CEAA 2012). Concurrently, the proposed ...
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Attachment Technical Review of Hydrology and Aquatic Ecosystems Sections of the Environmental Impact Statement for the Springbank Off-Stream Reservoir Project

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Bill Snow and the Stoney Nakoda Nations
  • Numéro de référence : 1359
  • Présenté : 2021-03-31
  • Please see the attached submission.
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  • Memo PGL File #: 4284-03.01 DATE: March 31, 2021 TO: William Snow, Consultation Manager – Stoney Nakoda Nation CC: Shauna McGarvey/Adena Vanderjagt – MNP Sara Louden – Rae and Company FROM: Leslie Beckmann, B.S.c.H., M.A., Senior Environmental Scientist Derek McCoy, M.Eng., P.Eng., Senior Hydrotechnical Engineer (Boreal Water Resources Ltd.) Matt Hammond, B.Sc., P.Dip.E.Sc., R.P.Bio., Senior Environmental Scientist (Senior Reviewer) Re: Interim Memo - Technical Review of Hydrology and Aquatic Ecosystems Sections of the Environmental Impact Statement for the Springbank Off- Stream Reservoir Project 1.0 INTRODUCTION The Springbank Off-Stream Reservoir Project (SR1; the Project) is a proposed project to construct a flood control structure on the Elbow River west of Calgary, Alberta. The project is required to receive both federal (Canada) and provincial (Alberta) approval. The Project entered the federal Environmental Assessment (EA) process in 2016 pursuant to the requirements of the then-in-force Canadian Environmental Assessment Act, 2012. The EA process is now nearing its conclusion and Stoney Nakoda Nation (SNN) is planning to make several sets of final interventions to Alberta’s Natural Resources Conservation Board (NRCB) and to the Impact Assessment Agency of Canada (IAAC; the Agency). To support its work, SNN has retained PGL and its subconsultant, Boreal Water Resources Ltd. (Boreal), to complete a review of two subjects (hydrology and design; aquatic ecology) contained within the Project’s Environmental Impact Assessment (EIA) and provide comments regarding both (a) their scientific/technical sufficiency for effects assessment and (b) their sufficiency as ...
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Attachment Ermineskin - Letter of Non Objection

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Ermineskin Cree Nation
  • Numéro de référence : 1356
  • Présenté : 2021-03-24
  • Good Afternoon,   Our firm is legal counsel to Ermineskin Cree Nation regarding the proposed Springbank Off-Stream Reservoir Project. Please find attached correspondence from Carol Wildcat.   Will you please confirm receipt of this email.   Kind regards,   Jackie   Jackie Wasyluk – Legal Assistant to Blair Feltmate (she/her/hers) Legal Assistant   JFK Law Corporation 816-1175 Douglas Street Victoria  BC V8W 2E1 C <phone number removed> E  <email address removed>   www.jfklaw.ca (http://www.jfklaw.ca/)
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  • <email address removed> <Original signed by> <email address removed>

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Attachment Letter of Non-Objection from Blood Tribe/Kainai

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Blood Tribe/Kainai First Nation
  • Numéro de référence : 1357
  • Présenté : 2021-03-23
  • Hello,   Please see Letter of Non-Objection from Chief Roy Fox with regard to the Springbank Off-Stream Reservoir Project.   Thank you, Blair   Blair Feltmate (he/his/him) Associate JFK Law Corporation 340 – 1122 Mainland Street Vancouver  BC V6B 5L1
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  • KAINAIWA Chief and Counci l Box 60 Standoff, Alberta T0L 1Y0 SCHEDULE "D" Non-Objection to the Federal Regulators March 15, 2021 Fisheries and Oceans Canada 1028 Parsons Rd SW Edmonton AB T6E 0J4 VIA EMAIL: kyle.antonchuk@dfo-mpo.gc.ca / neil.fisher@dfo-mpo.gc.ca Attention: Kyle Antonchuk and Neil Fisher Impact Assessment Agency Prairie and Northern Region #1145, 9700 Jasper Avenue, Canada Place Edmonton, AB T5J 4C3 VIA EMAIL: jennifer.howe@canada.ca / barbara.pullishy@canada.ca Attention: Jennifer Howe and Barb Pullishy Dear Madams and Sirs: Re: Proponent: Alberta Transportation Project: Springbank Off-Stream Reservoir Project ("Project") The BLOOD TRIBE/KAINAI FIRST NATION hereby withdraws all of its objections in relation to the Project proceeding forward in the regulatory process. Further, BLOOD TRIBE/KAINAI FIRST NATION will not participate any further in the current or future regulatory review processes in relation to the Project. Should you have any questions, please contact Ms.Annabel Crop Eared Wolf, Tribal Government Coordinator at . Yours truly, CHIEF ROY FOX BLOOD TRIBE/KAINAI 1 <Original signed by> <phone number removed> <sensitive information removed> cc: Matthew Hebert, Alberta Transportation (matthew.hebert@gov.ab.ca} Crystal Darner, Alberta Transportation (crystal.damer@gov.ab.ca} Adam Downing, Transport Canada (adam.downing@tc.gc.ca} Mathew Wiens, Crown-Indigenous Relations and Northern Affairs Canada (mathew.wiens@canada.ca) Andrea Mclandress, Environment and Climate Change Canada (andrea.mclandress@canada.ca} 2

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Attachment Serious risks with the SR1 project have not been addressed before the hearing

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Flood & Water Management Council (FWMC)
  • Numéro de référence : 1355
  • Présenté : 2021-03-13
  • Dear Laura, Jennifer, and respectable members of the hearing panel, In our submission of Thursday, February 25, 2021, we presented three main concerns and questions have to do with the Springbank dry reservoir (SR1); dam safety, water quality and Environment protection. We urged the NRCB not to ignore any of these serious and high risk issues. A reply from the proponent posted on the NRCB’s site did not address these three issues, providing unsatisfactory reply on one of the issues stating in P. 72, “AT notes that SR1’s capacity accommodates a design flood based on the largest flood on record for the Elbow River, which is the 2013 flood…”. This statement blatantly contradicts a previous acknowledgment of the fact that records show there have been two floods in Alberta 30% larger than the 2013. The attachment includes the three main issues of concern: 1-      Back-to-back floods/a semi-filled reservoir and dam safety. 2-      The most recent report of December 18, 2020 DID NOT address the main safety concerns. 3-      TsuuT’ina Nation clean water immediate challenges. As demonstrated in this submission using the very documents provided by officials and scientists, the question now becomes: Who is willing to bear the onerous responsibility of answering to the residents of Alberta when that dam fails resulting in a catastrophic event that involves the loss of lives, environmental destruction and more billions of dollars? We request addressing these issues fully before approving the project on March 22, 2021. We ...
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  • 1 Table of Contents 1.1 Serious Issues with the Springbank Off-Stream Reservoir Project ...........................3 1.1.1 Back-to-back floods/a semi-filled reservoir ......................................................3 1.2 More alarming issues with Springbank Off-Stream Storage Project .........................4 1.3 December 18, 2020 report DID NOT address the main safety concerns ..................6 1.4 History of failing projects and financial blunders in our province ............................8 1.5 TsuuT’ina Nation Clean Water Immediate Challenges .............................................8 1.6 STUDYING THE ALTERNATIVES, AND THE NEED FOR AN INNOVATIVE APPROACH ..........................................................................................................11 1.6.1 Critical relevant facts .......................................................................................12 1.7 blatant conflict of interest ........................................................................................13 1.8 Renewable power generation ...................................................................................13 1.8.1 Water is life and it is the new “white gold” .....................................................13 1.9 A Timely Innovative and Comprehensive Water Solution ......................................13 1.10 Summary and Conclusion ......................................................................................14 1.10.1 The NRCB Mandate ......................................................................................14 1.10.2 Time lapse until final discission ....................................................................14 ...
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Attachment Langlois (JFK) to Howe (IAAC) Comments on Draft EA Report and Potential Conditions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Ermineskin Cree Nation
  • Numéro de référence : 1353
  • Présenté : 2021-03-04
  • Good Afternoon Jennifer,   Our firm is legal counsel to Ermineskin Cree Nation in relation to the Springbank Offstream Reservoir Project.  Please find attached the following documents:   1.       Comments on Draft EA Report and Potential Conditions (attached); and 2.       Enclosures (found at this link (https://jfklawcorp-my.sharepoint.com/:b:/g/personal/jwasyluk_jfklaw_ca/ESlIc_xE7VVDg3nD0UhwuToBtXCiMNsZMyM5H_wHHdMgUw?e=nKFxYX)).   Will you please confirm receipt of this email?   Kind regards,   Jackie Wasyluk to Blair Feltmate (she/her/hers) Legal Assistant   JFK Law Corporation 816-1175 Douglas Street Victoria  BC V8W 2E1 C <personal information removed> E <email address removed>   www.jfklaw.ca (http://www.jfklaw.ca/)
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  • March 4, 2021 Delivered by Email: (IAAC. Springbank.AEIC@canada.ca; jennifer.howe@canada.ca) Impact Assessment Agency of Canada Prairie and Northern Region #1145, 9700 Jasper Avenue Edmonton, AB T5J 4C3 340-1122 Mainland Street Vancouver BC V6B 5L1 T 604 687 0549 F 604 687 2696 www.jfklaw.ca Jeff Langlois he/him/his Principal Direct Line: C E File No. 1184-009 Attention: Jennifer Howe, Project Manager, Prairie and Northern Region Re: Comments on draft EA Report and potential conditions Our firm is legal counsel to Ermineskin Cree Nation (“Ermineskin”) for the proposed Springbank Off-Stream Reservoir Project (the “Project”). We write to provide comments on the draft Environmental Assessment Report (the “draft EA Report”) and potential conditions published by the Impact Assessment Agency of Canada (the “Agency”) on January 4, 2021. Ermineskin appreciates the Agency extending the timeline to provide these comments. Prior to engaging directly with the draft EA Report and potential conditions, Ermineskin wishes to reiterate what has been said throughout the regulatory process: the Project will directly and adversely affect the exercise of Aboriginal and Treaty rights by Ermineskin members and without appropriate Crown conditions, this Project will have adverse effects on Ermineskin’s Treaty 6 rights. We provide these submissions in the hope that the draft conditions in the report be made more responsive to the needs of Ermineskin and its members. Ermineskin and the Crown have a mutual interest in ensuring that development of <personal information removed> <personal information removed> <email address removed> 2 land and resources is done in ...
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Attachment Langlois (JFK) to Howe (IAAC) - Blood Tribe Kainai - Comments on draft EA Report and Potential Conditions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Blood Tribe/Kainai
  • Numéro de référence : 1354
  • Présenté : 2021-03-04
  • Good Afternoon Jennifer,   Our firm is legal counsel to Blood Tribe/Kainai in relation to the Springbank Offstream Reservoir Project.  Please find attached the following documents:   1.       Comments on draft EA Report and Potential Conditions (attached); and 2.       Enclosures found at this link:  TLU - Traditional Knowledge_ Land_ and Resource use Study - By Dermot O Connor - June 2018(107639.1) (https://jfklawcorp-my.sharepoint.com:443/:b:/g/personal/jwasyluk_jfklaw_ca/EfNafp54yQdMnrY09yV1vFIBu6fEkznAt2U42UBxWDm4mg?e=4:C51TIv&at=9)   Will you please confirm receipt of this email?   Kind regards, Jackie Wasyluk Legal Assistant to Blair Feltmate     Jackie Wasyluk (she/her/hers) Legal Assistant   JFK Law Corporation 816-1175 Douglas Street Victoria  BC V8W 2E1 C <personal information removed> E <email address removed>   www.jfklaw.ca (http://www.jfklaw.ca/)
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  • March 4, 2021 Delivered by Email: (IAAC. Springbank.AEIC@canada.ca; jennifer.howe@canada.ca) Impact Assessment Agency of Canada Prairie and Northern Region #1145, 9700 Jasper Avenue Edmonton, AB T5J 4C3 340-1122 Mainland Street Vancouver BC V6B 5L1 T 604 687 0549 F 604 687 2696 www.jfklaw.ca Jeff Langlois he/him/his Principal Direct Line: C E File No. 1184-009 Attention: Jennifer Howe, Project Manager, Prairie and Northern Region Re: Comments on draft EA Report and potential conditions Our firm is legal counsel to Blood Tribe/Kainai (“Kainai”) for the proposed Springbank Off-Stream Reservoir Project (the “Project”). We write to provide comments on the draft Environmental Assessment Report (the “draft EA Report”) and potential conditions published by the Impact Assessment Agency of Canada (the “Agency”) on January 4, 2021. Kainai appreciates the Agency extending the timeline to provide these comments. Prior to engaging directly with the draft EA Report and potential conditions, Kainai wishes to reiterate what has been said throughout the regulatory process: the Project will directly and adversely affect the exercise of Aboriginal and Treaty rights by Kainai members and without appropriate Crown conditions, this Project will have adverse effects on Kainai’s Treaty 7 rights. We provide these submissions in the hope that the draft conditions in the report be made more responsive to the needs of Kainai and its members. Kainai and the Crown have a mutual interest in ensuring that development of land and resources is done in a way that enhances Kainai’s way of life and promotes reconciliation. <personal information removed> <personal information ...
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Attachment NRCB Submissions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Springbank Community Association
  • Numéro de référence : 1352
  • Présenté : 2021-03-03
  • Hi Jennifer:   I included the wrong link for air quality.  Here it is:   https://www.nrcb.ca/download_document/2/83/10825/20210226-sclg-sub-to-nrcb-hearing-appendix-q-brian-zelt-report   On Mon, Mar 1, 2021 at 4:38 PM Springbank Community Association <email address removed> wrote: Hello, Jennifer:   I hope that IAAC is aware of the relevant submissions to NRCB on the SR1 project.  I would like to highlight the following items that should be considered by IAAC in its decision, report and conditions.     - Dam Risk and Safety Exhibit 257 https://www.nrcb.ca/natural-resource-projects/natural-resource-projects-listing/83/springbank-off-stream-reservoir-project/documents/10815/20210226-sclg-sub-to-nrcb-hearing-appendix-f-austin-engineering-report Exhibit 261 (includes Hydrology) https://www.nrcb.ca/natural-resource-projects/natural-resource-projects-listing/83/springbank-off-stream-reservoir-project/documents/10819/20210226-sclg-sub-to-nrcb-hearing-appendix-j-dr-fennell-report Exhibit 264 https://www.nrcb.ca/natural-resource-projects/natural-resource-projects-listing/83/springbank-off-stream-reservoir-project/documents/10822/20210226-sclg-sub-to-nrcb-hearing-appendix-l1-erosion-and-riverbed-integrity-at-the-low-level-outlet-klepacki Exhibit 259 ...

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Attachment SR1 Comments on CEAA Report and Conditions

  • Projet de réservoir hors cours d'eau de Springbank
  • Auteur : Administrateur de la part de Springbank Community Association
  • Numéro de référence : 1350
  • Présenté : 2021-02-18
  • Please see the attached submission.
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 13, 2021 Re: Air and Human Health (CEAA Sections 6 and 7) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed-opportunities to improve Project outcomes. “No Project” Comparisons The baseline comparison for the Proponent is the “no project” or “without the project” scenario, which was never contemplated. MC1 would have retained sediment, just as SR1 does. However, SR1 leaves this sediment expose to air whereas it would have been ...
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 17, 2021 Re: SR1 Risk Comments Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed-opportunities to improve Project outcomes. In this submission, we highlight concerns with the Proponent’s responses along with inconsistencies and gaps. We look to the regulators to provide robust technical analysis of the IRs, including assessing the engineering changes to SR1 for safety and risk. General Comments Dam Innovation: Regarding ...
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 14, 2021 Re: SR1 Project General Comments Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. These latest changes are just an example of the numerous changes that have occurred to the project, which appears to be in a near-constant state of flux. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed- opportunities to improve Project outcomes. General Comments Terminology and Interpretation The SR1 project is effectively a dike in function, focused purely on flood mitigation and not ...
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) Re: SR1 Land Use (CEAA Sections 6 & 9) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed-opportunities to improve Project outcomes. Comments on the CEAA Report: Uncertainty of Land State Post-Flood The Proponent does not provide much detail regarding the future state of the SR1 lands over time. We continue to point out that sediment will accumulate EACH flood and therefore will become deeper and more broadly dispersed over time. It ...
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 15, 2021 Re: SR1 Project and Migratory Birds (CEAA Conditions Section 4) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed-opportunities to improve Project outcomes. “No Project” Comparisons The baseline comparison for the Proponent is the “no project” or “without the project” scenario, which was never contemplated. Regarding migratory birds, we ask Regulators to require a discussion of the MC1 alternative vs SR1. SR1 requires an ...
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  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 14, 2021 Re: SR1 Project and Wildlife / Biodiversity (CEAA Conditions Section 5) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated design was imminent and it has created additional work for our volunteers. Additionally, the February 3, 2021 deadline for CEAA comments on conditions proposed on January 4, 2021 does not allow adequate time for robust review and comment. The CEAA deadline should at least include the expert evidence that arises at the NRCB hearing. To omit this evidence may result in missed-opportunities to improve Project outcomes. “No Project” Comparisons The baseline comparison for the Proponent is the “no project” or “without the project” scenario, which was never contemplated. Regarding migratory birds, we ask Regulators to require a discussion of the MC1 alternative vs SR1. SR1 ...
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