Response Records Part 2

Russell, Veronica A ENV:EX
From: Sent: To: Cc: Subject: Attachments: Babakaiff, Scott C ENV:EX Friday, January 8, 2010 8:28 AM 'Knight, Francesca'; Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX; 'Busto, Vince' RE: Ashlu long-term monitoirng 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 the review agencies at the moment. In the process of reviewing the OPP (v.4 dated November 24 2009), I discovered (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 & ongoing meetings & communications regarding IPP review issues. For the record, Chessy: I agree with your conclusions. The May 2009 plan developed by Cascade Environmental is lacking many critical elements of an appropriate monitoring Plan, including a power analysis 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 November 2009, and subsequently reviewed by MOE (see attached email from Tim Bennett, which was sent to the proponent a few weeks ago), was very different than the Plan submitted to DFO in May. It seems that this is not a matter of one version superceding another, but rather that the proponent has submitted different plans to DFO and MOE. I dont know whether the proponent has done this intentionally, believing that one Plan would meet the needs of DFOs Authorization, and the other Plan would address Water License requirements. Or perhaps the different reps for the Proponent (Kelly Boychuk & Robert Kulka) arent even aware that the two different plans exist. Regardless, it seems that action is required from MOE & DFO to ensure that the proponent is made aware that: 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:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, January 7, 2010 6:54 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: 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 the indicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusions regarding 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, which is useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise useless for telling us whether the diversion has influenced the fish population. In addition, there is no method for counting adult fish... just gee traps for the little guys.
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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 are some other short-comings related to methods, but the limited analysis is the biggie. In addition, there is of course nothing proposed for evaluating changes to community structure, but you all know that is my main concern with how invertebrates 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 we would 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 check on 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 any useful interpretation or determine any flow/biological response relationships. C
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From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Tuesday, January 12, 2010 5:15 PM Bennett, Timothy A ENV:EX FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan 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 the documents 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:RKulka@innergex.com] Sent:Tuesday,January12,20103:39PM To:Bennett,TimothyAENV:EX Cc:Babakaiff,ScottCENV:EX;XT:Busto,VinceDFOEAO:IN;gsteeves@ameresco.com;RichardBlanchet;Kelly Boychuk;BillJohnson;MikeNelson Subject:RE:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):Operations EnvironmentalManagementPlan HiTim, FollowingupourletterdatedJanuary8,IattachedthereportofprojectEnvironmentalMonitorMikeNelson, R.P.Bio(CascadeEnvironmentalServices)regardingtherampingstudiesdonesofar.Asperourletter,itis recommendedtoperformfurtherstudiesinlatesummer/earlyfallandweintenttodocumentthisasarequirement inthefirstyearofoperation(2010)intheOEMP. Regards, Robert ________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.
Construction Manager
Innergex nergie renouvelable - Innergex Renewable Energy
Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2
Phone:604984.8600Fax:604984.8699 Cell.:778227.0434 From:RobertKulka Sent:Saturday,January09,20101:46PM To:'Bennett,TimothyAENV:EX' Cc:Babakaiff,ScottCENV:EX;XT:Busto,VinceDFOEAO:IN;gsteeves@ameresco.com;RichardBlanchet;Kelly Boychuk;BillJohnson;'MikeNelson' Subject:RE:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):Operations EnvironmentalManagementPlan

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HiTim, Pleasefindattachedourresponsetoyourcommentsprovidedinunderneathemail.Iwilltrytocallyouearlynext weektodiscussapathforward,includingoveralltimingandLTCcommissioningandoperation. RegardsandhappyNewYear, Robert ________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.
Phone:604984.8600Fax:604984.8699 Cell.:778227.0434 From:Bennett,TimothyAENV:EX[mailto:Timothy.Bennett@gov.bc.ca] Sent:Friday,December18,20093:12PM To:RobertKulka Cc:Babakaiff,ScottCENV:EX;XT:Busto,VinceDFOEAO:IN;gsteeves@ameresco.com;RichardBlanchet;Kelly Boychuk Subject:RE:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):Operations EnvironmentalManagementPlan HiRobert, ThankyouforprovidingyourdraftOEMPforourreview. Staffhaverevieweditandprovidedthefollowingpreliminarycomments: ReportAuthorshipunknown:Thereportshouldbepreparedandsignedbyappropriatelyqualifiedlicensed professional(s)(e.g.,RPBio). Fewcommitmentstofollowcommonlyacceptedguidelinesfordatacollection&analysis,despitea proposalthatmonitoringdetailsmeettherequirementsofDFOandMOE(p.6oftheOEMP).Many detailsproposedintheOEMPareseeminglyarbitraryanddonotreferenceanyguidelinesorstandards typicallyreferencedbyProvincialorFederalagencies.Forinstance: StagedischargeratingcurvestheOEMPcommitstocollectingaminimumofthreedischarge measurementsandwarnsthat...itisunlikelythatflowswillbeabletobemeasuredabove20%ofmean 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 BCProvincialHydrometricStandards(Section3.2.2.3)recommendsastagereadingevery15minutes,but advisesthat"thisisaminimumrequirement...sitespecificflowregimesmaynecessitateashorter frequency...".Forpurposesofverifyingcompliancewithflowrampingrequirementsinfishbearingwaters, particularlythosewiththediversityoffishvaluesintheAshludiversionreach,Iwouldrecommendamuch
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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 thathavebeenhistoricallyobservedinAshluCreekoverseveralyearssince1991....TheOEMPprovides 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).TheMOEESDinformationchecklistprovidedintheProvincialIPPGuidebookalso providessupplementalguidanceforOEMPdevelopment.Itismyunderstandingthatthebaselinebiological datacollectedinrecentyearsdidnotfollowanyparticularprotocol,butwasundertakenbyseveraldifferent biologistsindifferentlocations,usingdifferentmethods.Assuch,itisimperativethatallbaselinedatabe collatedandassessedbyaprofessionalbiologistwithexperienceintherelevantspecialization(ie.fisheries biology,macroinvertebratebiology),andcompiledforassessmentregardingitsadequacyasabaselineto assessfuturechangesthatmaybeattributabletooperationoftheIPPfacility.Onthisnote... Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g. durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,apriori agreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.)cannotbe objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis.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 verbatimfromtheguidelines(which,incidentally,arenotreferencedcorrectly)andsubsequentcasestudy (TroutCreek),soitisunclearwhataspectsofthemonitoringcriteriawillorwillnotbeundertakenperthe OEMP. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated.For instance: installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentofassociated ratingcurvesforwaterflow(Section4)andinstreamflow(Section11)monitoring; Collectionofstreamchannelmorphologydata(perSection10oftheOEMP).ThiscomponentoftheOEMP isparticularlyilldefined:therearenoexplicitguidelinesorstandardsreferenced,andIalsoquestionthe proposedbenefitsofcompletingrepeatsurveysatafewtransectstoassesswhethertheIFRisaffectanyof thefishhabitataswasoriginallypredicted.Assessmentofchangesinchannelmorphologyrelatedto projectoperations(e.g.flowdiversion,changesinsedimentandLWDtransportratesandvolumes,etc.)is crucial,butshouldbeconsideredmoreholisticallyusinglowlevelairphotosandlongitudinalsurvey profiles.Again,itisrecommendedthatanprofessionalexperiencedwithdevelopmentofchannel
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monitoringprograms(ie.afluvialgeomorphologistorriverengineer)betaskedwithdevelopingthestudy designandundertakingtheworkpriortofinalcommissioning; IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE? Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff. Regards, TimothyBennett,M.Sc.,P.Eng.

SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment
10470152Street,Surrey,BCV3R0Y3 Ph.(604)5825227Fx.(604)5825235 Timothy.Bennett@gov.bc.ca From:RobertKulka[mailto:RKulka@innergex.com] Sent:Friday,November27,20093:04PM To:Bennett,TimothyAENV:EX Cc:Babakaiff,ScottCENV:EX;XT:Busto,VinceDFOEAO:IN;gsteeves@ameresco.com;RichardBlanchet;Kelly Boychuk Subject:AshluCreekHydroProject(WaterStewardshipDivisionfilenumber:2001264):OperationsEnvironmental ManagementPlan HelloTim, Attachedarethefollowingfiles: RevisionBoftheOperationsEnvironmentalManagementPlanfortheAshluCreekproject. JpegfileofthemonitoringmapshownasFigure1intheOEMP. CoverletterregardingsubmissionoftheOEMP. Hardcopiesareinthemailtoyou,toScottBabakaiff,andtoVinceBusto.Pleasecontactmeifyouhaveany questions. Regards, Robert ________________________________________ ROBERTJ.KULKA,P.Eng.,Dipl.Wirt.Ing.
ConstructionManager
InnergexnergierenouvelableInnergexRenewableEnergy
Suite30338FellAvenue NorthVancouver,BritishColumbiaV7P3S2
Phone:604984.8600Fax:604984.8699 Cell.:778227.0434
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30 Gostick Place | N. Vancouver, B.C. V7M 3G3 | 604.980.6011 | www.nhcweb.com
December 9, 2009 ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP Suite 303 38 Fell Avenue North Vancouver, BC V7P 3S2
Attention: Via Email: Subject:
Mr. Robert Kulka, P.Eng. RKulka@innergex.com 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 hand operated 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 Measurements
On 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 effect generated 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
water resource specialists
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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP 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.
IFR Pipe Outlet
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.
Photograph 3 View of the IFR from above
Photograph 4 Measurements were recorded using a Pitot tube.
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Figure 1 Measured and theoretical velocity distribution. Discharge = 2.05 m3/s
Figure 2 Measured and theoretical velocity distribution. Discharge = 2.90 m3/s
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 velocity measurements 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 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
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IFR Inlet Gate Operation

At 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.
WaterSurfaceElevation(m) Forebay 275.1 275.2 275.3 275.4 275.5 275.6 275.7 275.8 275.9 276.0 276.1 276.2 276.3 276.4 276.5 276.6 276.8 277.0 HeadLoss GateOpening Downstream Attributedtothe (%) ofTrashRack IFRInletGate(m) 274.8 fullyopen 100% 274.9 fullyopen 100% 275.0 fullyopen 100% 275.1 0.1 79% 275.2 0.2 75% 275.3 0.3 71% 275.4 0.4 68% 275.5 0.5 65% 275.6 0.6 63% 275.7 0.7 61% 275.8 0.8 59% 275.9 0.9 57% 276.0 1.0 56% 276.1 1.1 54% 276.2 1.2 53% 276.3 1.3 51% 276.5 1.5 49% 276.7 1.7 47%
As s umedthehea dl os s throughthetra s hra cki s a cons ta nt0.3m IFRInl etGa teopeni ngi s effecti vel y1.2mhighby1.0mwi de As s umedIFRInl etGa tel os s coeffi ci enti s 0.61
OperatingRange
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 KChristison@nhc-van.com if you have any questions. Sincerely,
northwest hydraulic consultants

original signed
Kenneth J. Christison, P.Eng. Principal
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January 8, 2010 Tim Bennett, P.Eng. Section Head - Water Allocation Ministry of Environment 10470 152nd Street, 2nd Floor Surrey, BC, V3R 0Y3 Tel: (604) 582-5235 Email: timothy.Bennett@gov.bc.ca Re: Ashlu Creek Green Power Hydroelectric Project Response to Comments on Operations Environmental Monitoring Plan
Dear Tim; The Ashlu Creek Investments Limited Partnership (ACILP) acknowledges receipt of your email dated December 18, 2009 regarding the Ministry of Environments (MOE) comments to ACILPs Operation Environmental Monitoring Plan (OEMP) Revision B for the Ashlu Creek Green Power Project (the Project) near Squamish. The following are our responses to your questions, in the same order as they were presented. Background For reference purposes, the baseline studies for the Project were performed in 2001 to 2004. At this time, MOE (then known as the Ministry of Water, Land and Air Protection) was acting as a referral agency for environmental issues but not providing any direct comments to ACILP; the Department of Fisheries and Oceans Canada (DFO) was ACILPs primary contact for all fisheries-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 to the BC Ministry of Water Land and Air Protection (WLAP) by LWBC for comment). The CEAA report was signed off by DFO on October 18, 2004. DFO issued the Fisheries Authorization for the project on July 31, 2006 based on the CEAA report and the baseline information provided by ACILP. 1. Report Authorship Unknown The OEMP (Revision B) was based on ACILPs Five-Year Post-Construction Monitoring Plan (2010 to 2014) that was submitted to DFO on May 18, 2009. The document was prepared by ACILP based on several post-construction monitoring reference documents provide to ACILP by DFO and on environmental baseline studies and data collection that had been performed by Tom Cleugh, RP Bio., in 2001 to 2004 (while with Sigma
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Engineering Ltd.) and in 2005 to 2008 (while working independently as TRC Biological Consulting Ltd.). The next revision of the OEMP will incorporate the comments presented by MOE and will be signed 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 in your email dated December 18, 2009 (LWBC Hydrometric Guidelines; B.C. Provincial Hydrometric 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 of commissioning is every 60 seconds (total creek flow at intake, IFR flow, diverted/plant flow). Recording frequency of data logged with stand alone data logger(s) is currently 15 minutes and this particular equipment is unable to average data and has limited storage capacity. We have now ordered new logger(s) in order to follow you recommendation for shorter sampling frequency (10-second) and recording of averaged readings (every 2 minutes). The new equipment will be installed upon availability (expected to be no later then end of February). The revised OEMP will follow your recommendation for reporting (regular reporting to agencies once per year, reporting of non compliance within 24 hours 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 wet commissioning; the plan was copied to Independent Engineer George Steeves and to Transport Canada, Navigable Waters Protection Division because of TCs interest in ramping rates as referred to in the DFO Authorization (see enclosed letter dated October 14). TC confirmed the plan during a site visit on November 30. The other recipients have not formally responded to the plan. The plan was developed in consultation with the Environmental Monitor (Mike Nelson, R.P.Bio., Cascade Environmental Resource Group, 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, such as 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 the week of October 5th, 2009) During ramping, continuously survey marked areas by qualified personnel (all personnel 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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2. 0 -> 5 -> 0 cms (ramp up in 15 minutes, hold 10 to 30 minutes, ramp down in 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 EM before proceeding with the next step;
The EM is currently finalizing his report on the ramping and the report is expected to be available early next week and will be forwarded to you promptly. The report will confirm that the ramping rates are in general adequate to prevent fish stranding. However, the report will recommend to conduct further ramping studies during in late summer and/or early 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 the OEMP will require conducting this study in the first year of operation and adjustment of ramping rates if determined by this study. ACILP plans to contract the environmental monitoring component during those tests to Cascade and a similar report will be issues after completion of the tests. Notice will be given to MOE and DFO prior to commencement of tests and the report will provided to both agencies. d. Fish Abundance The revised OEMP will provide reference to provincial data collection protocols and analysis standards such as Resource Inventory Committee Standards (RISC) and other provincial standards as they apply to various disciplines. Many of these protocols and standards pre-date the current project. Although the baseline studies completed to date were compiled by various professionals, it is ACILPs understanding the data collection and analysis was completed using appropriate standards at the time. It is ACILPs intention to have all of the baseline material reviewed by qualified professionals at the time the data of the first year of operation becomes available (say late 2010) and requires 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 the permits issued by the various federal and provincial environmental agencies were based on this data. Additional data continued to be collected during the 2005 to 2006 period while the project 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 in 2007 to 2008 during construction of the project. It is ACILPs intention that all of this collected data be considered as baseline data for reference during the operational years of the project. However, ACILP is cognizant that the requirements for baseline data for Independent Power Projects (IPPs) have been evolving in British Columbia over the past decade. As more IPPs are developed, the federal and
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provincial review agencies, as well as qualified licensed professional biologists, have more operating projects to observe and study, and hence the existing regulations and baseline requirements 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) that have set new standards and require more information to be collected. As such, some of the data collected years ago for the environmental baseline may not match with the latest version of MOEs requirements; however, it is ACILPs intent to comply with the latest standards wherever possible. We have carefully reviewed the OEMP with regards to your comments that some references in Tables 3 to 5 were not done properly as well as one reference to Trout Creek. We have not 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 scrutinized and 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 the next 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 at various locations and readings are continuously logged in the powerhouse. The total creek flow is calculated as the summary of the diverted flow (as determined by turbine flows and tail race flow), the IFR flow (see below) and the flows spilling through the sluiceway and the spillway. The latter two have known flow discharge curves due to their designed geometry. Staff gages are installed at several locations to verify the transducer readings; IFR flow: Low flows in the Ashlu at the intake area typically range between 5 and 10 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) in the range of highest interest (say 2.5 to 5 cms) were therefore not possible prior to reducing natural flows through headpond filling and diversion. During the first head pond filling on March 11, 2009 the EM measured flows at the most suitable location approximately 250 meters downstream of the intake area and installed fixed marks for the measurements corresponding 2.45 cms and 3.52 cms. A pressure transducer was installed at his location in early October 2009 prior to start of wet commissioning. Correlation of the transducer readings to the marks set by the EM was not possible due to the high natural flows in the creek and consequently submergence of the marks (flows were approximately between 15 and 200 cms). During the early stages of wet commissioning it became evident that the calculated flow through the IFR pipe did not correspond with the marks
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set by the EM in March, with the EM marks being more conservative (i.e. IFR flow was estimated at 5cms while the marks indicated 2.5cms). The EM tried to perform additional flow readings in November, but was unable to produce reliable results due to the site conditions. ACILP discussed options to reliably measure and confirm IFR flows with Ken Christison, P.Eng. of North West Hydraulics. On December 3, 2009 Ken performed measurements of the pipe flow at the outlet of the pipe with a Pitot Tube. Those measurements confirmed the theoretically calculated discharge of the IFR pipe (3.0 cms at normal operating water level of 276.0 m). The probe downstream of the intake was then calibrated based on the measurements made by NW Hydraulics at the pipe outlet. The corresponding report is enclosed to this letter. We believe that the measurements taken at the IFR pipe outlet are more precisely then the measurements taken with a propeller type submersible flow meter in a rough cobble/boulder type creek bed such as present in the area downstream of the intake. ACILP is in the process of installing one 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 to impacting the flow through the pipe. The probe downstream of the intake will continue to measure and record the IFR flow; Mile 25 bridge station: This station has an established FDC that was developed over 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. A professional 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. The discharged 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 to lack of water. Once index tests have been performed those results will be used to confirm the discharge through the tailrace.
b. Collection of Stream Channel Morphology Data Stream channel morphology was considered by ACILP during the baseline data collection process; however, it was deemed to be an overall minor factor due to the extensive length of the bypass reach that is contained within the natural granite canyon of Ashlu Creek. Approximately 80%, or 4.4 km of the 5.2 km long bypass reach, is within a bedrock controlled canyon; only the initial length of the bypass reach near the water 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 of sediment that exits from the Ashlu canyon and terminates at the confluence with the Squamish River. Along this delta, Ashlu Creek constantly is changing its form and orientation as it behaves like a low energy, meandering channel compared to the high energy creek in the diversion reach. Storm events frequently cause changes in the delta, and ACILP has witnessed several changes over the period since 2001. DFO personnel, who have constructed a weir and fish habitat off of the Ashlu delta, have
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been cognizant of these changes in the delta as well. Hence, ACILP has not proposed monitoring these natural changes as they are frequent and are influenced by periodic storm events. As a result of this, ACILP identified three main areas of potential change in stream channel morphology: headpond filling, side channel filling at the gravel bar in the Ashlu Canyon (at km 2.0), and downstream of the tailrace. These areas are proposed for monitoring 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 had sent a copy of OEMP (Rev B) to DFO at the time it was submitted to MOE. However, we understand that MOE referred Revision B to DFO for comments and the comments received in your email dated December 18, 2009 may have DFO contribution. Therefore we assume that DFO will not provide additional comments to Revision B directly to ACILP. We understand that MOE may at its discretion continue to engage DFO in the current discussions any may choose to refer Revision C to DFO. Therefore, ACILP does not intend to directly issue future revisions of the OEMP directly to DFO except MOE or DFO advises us to do so. If you have any further questions or comments, please feel free to contact myself at 604-9848600. Sincerely, Innergex Renewable Energy Inc.
Robert Kulka, P.Eng. Construction Manager Cc. (per email only): MEO: Scott Babakaiff, Fish Protection Hydrologist DFO: Vince Busto, P.Eng ACILP: Richard Blanchet, Kelly Boychuk George 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 Canada Habitat and Enhancement Branch, Lower Fraser Area 100 Annacis Parkway North Delta, B.C. V3M 6A2 Attention: Vince Busto, B.A.Sc., P.Eng. Re: Ashlu Creek Green Power Hydroelectric Project Plan to confirm Ramping Rates
Dear Vince; Pursuant to the requirements of DFO Authorization N. 04-HPAC-PA2-000-000530 (the Authorization), 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 areas identified as fish community in the 5 year post construction monitoring plan (Revision A submitted to DFO on May 19, 2009) and marked specific areas in the field that could be impacted by ramping rates. Those are mainly side riffles and pools along gravel banks and similar areas where fish could potentially get stranded if water levels change too rapidly. During commissioning, the diverted flow will be gradually increased and decreased in several steps at the ramping rate suggested in the Authorization. During each step, the EM will survey the marked areas and observe the impact of the ramping. It is the goal to confirm that the suggested ramping rate is adequate for all lower and medium creek flow conditions and that a shorter ramping rate may be adequate for higher flow conditions. ACILP believes that the then established ramping rate will also be adequate to meet requirements of the project approval provided by Transport Canada, Navigable Waters Protection 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 Officer ACILP: Richard Blanchet, Kelly Boychuk EM (Cascade): Mike Nelson, R.P. Bio, Hilary Lindh, R.P. Bio. George Steeves, Independent Engineer MoE
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From: Sent: To: Subject: Babakaiff, Scott C ENV:EX 010 4:11 PM
S. 22
ashlu
Tim, As per your request, Ive reviewed three reports submitted to MOE by the proponent for the Ashlu IPP in two emails dated January 9 & 12 2010: 1. Ashlu Creek Green Power Hydroelectric Project: Response to Comments on Operations Environmental 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 as Kulka (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 this review as NHCL (2009); 3. Ashlu Creek Flow Monitoring During Ramping prepared by Cascade Environmental Resource Group Ltd for Innergex Renewable Energy Inc, dated December 14 2009, 6 pp. Referenced hereafter 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 2010 email); I was not provided the opportunity to review the proposed ramping work prior to its completion, 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) 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 Bill Johnson, RP Bio., of Focus Environmental. However, Kulka (2010) does not commit to address the OEMP deficiencies identified in the email sent to the proponent t that alot of baseline environmental data has been collected since 2001, and suggests that any deficiencies identified in our December 18
Scott Babakaiff, M.Sc. P.Geo. Regional Fish Hydrologist Ministry of Environment Lower Mainland Region 2nd Floor- 10470 152nd Street Surrey, BC, V3R 0Y3 604-930-7121
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From: Sent: To: Cc: Subject: Attachments: Stoddard, Erin M ENV:EX Friday, January 15, 2010 12:20 PM Bennett, Timothy A ENV:EX Willcox, Michael ENV:EX; 'Vince.Busto@dfo-mpo.gc.ca'; 'Francesca.Knight@dfompo.gc.ca'; Babakaiff, Scott C ENV:EX; Barrett, Scott ENV:EX RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan image001.jpg
Tim, IhadaquicklookthroughtheOEMPandsupportScottscommentswithrespecttofishandfishhabitat.Itappears thatScotthasalsoaddressedfishandfishhabitatmonitoringintheJanuary9thInnergexresponse,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 AM To: Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Willcox, Michael ENV:EX; Vince.Busto@dfo-mpo.gc.ca; Francesca.Knight@dfompo.gc.ca Subject: 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 in two emails dated January 9 & 12 2010: 1. Ashlu Creek Green Power Hydroelectric Project: Response to Comments on Operations Environmental 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 as Kulka (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 this review as NHCL (2009); 3. Ashlu Creek Flow Monitoring During Ramping prepared by Cascade Environmental Resource Group Ltd for Innergex Renewable Energy Inc, dated December 14 2009, 6 pp. Referenced hereafter 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 2010 email); I was not provided the opportunity to review the proposed ramping work prior to its completion, 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) interchangeably.
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My review of Kulka (2010), NHCL (2009) and CERG (2009) indicates three general points of concern:
1. Inconsistent IFR provision, with a reasonable likelihood of non-compliance: NHCL
(2009) undertook a series of measurements at the outlet of the IFR pipe, clearly indicating that inadequate delivery of IFR from the pipe can be triggered by accumulations of sediment and LWD in the approach channel. The issue of insufficient IFR provision was resolved once the operators "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 also warn that this requires a "well maintained IFR system". NCHL (2009) suggests that IFR inlet gate could also be operated to manage the IFR release, but warn that "Due to the interaction between the trashrack, inlet gate, and pipe entrance, if is difficult to calculate precise operation of the gate" 2. Commitments made in Kulka (2010) regarding an imminent revision to the OEMP do not address all concerns identified in MOE reviews of previous OEMP drafts.
Kulka (2010) proposes that the OEMP (Revision B dated November 26 2009) recently reviewed by MOE is based on the Monitoring Plan previously (May 18 2009) presented to DFO and indicate that another version (a revision) will incorporate the comments presented by MOE. Kulka (2010) suggests that the next OEMP revision will fully address MOE 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 [20012008] 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 of operation 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 MOE concerns 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 existing equipment & operational assumptions to meet compliance verification needs (see p. 5 of Kulka, 2010). 3. Ramping rates measured instream by CERG (2009) far exceed the DFO default rates
(2.5-5.0 cm/hr): detailed ramping rate study is proposed to be undertaken in late summer and/or early 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" (p.3 of Kulka, 2010). This seems like a reasonable strategy, except that CERG (2009) found that the ramping rates measured at the primary sites of interest resulting from the present operating strategy (zero to full flow diversion in 90 minutes, or 0.3 cms per minute) far exceeds the default rates typically accepted by DFO:
High discharge (10-30 cms) Ramp Up Ramp Down 12 cm/hr n/a (darkness) 24 cm/hr 23.2 cm/hr n/a (darkness) n/a (darkness)
2
Site 1. Twin Bridges 2. Powerhouse 3. km 4.0 4. Mile 25 bridge
Low discharge (0-10 cms) Ramp Up Ramp Down 12 cm/hr 22 cm/hr (up to 240 cm/hr) 47 cm/hr Unknown 16-20 cm/hr n/a (darkness)
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CERG (2009) refers to the operating strategy (0.3 cms per minute) as the 'prescribed' ramping rate, and similar language is used by the proponent in reference to the DFO Authorization, but I do agree with this assertion. Finally, it is apparent that the proponent does not believe they are responsible for delivering a single OEMP that meets both MOE and DFO needs, and they seem unaware that it is their responsibility to jointly address agency review comments & co-ordinate subsequent OEMP drafts (see p.6 of Kulka, 2010). As I described 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.
S22
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:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan
HiScott, Whenyouhaveachance,canyoupleaseletmeknowifyouhaveanycommentsonthematerialsenttousre:the AshluOEMP? Thanks!

TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment
10470152Street,Surrey,BCV3R0Y3 Ph.(604)5825227Fx.(604)5825235 Timothy.Bennett@gov.bc.ca
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Saturday, January 9, 2010 1:46 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson; Mike Nelson Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Hi Tim, Please find attached our response to your comments provided in underneath email. I will try to call you early next week to discuss a path forward, including overall timing and LTC commissioning and operation. Regards and happy New Year, Robert
________________________________________
ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.
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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: Friday, December 18, 2009 3:12 PM To: Robert Kulka Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental 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. StagedischargeratingcurvestheOEMPcommitstocollectingaminimumofthreedischarge 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.Interms ofdatacollection&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. Developmentoframpingrates:Section12.2oftheOEMPproposesthattherampingratesshall notexceed29.0cmsper90minutes.Thisratewillbeestablishedduringthecommissioningprocess oftheplant,andmaybesubjecttodifferentflowconditionsinthecreek.Thisratewasbasedon
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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 rampingrateproposedandthefishvaluespresentinthediversionreach. 4. FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfor datacollectionoranalysisareproposed,despitethebibliographicreferenceinSection16ofthe OEMPtoHatfield&Lewis(2007).TheMOEESDinformationchecklistprovidedintheProvincialIPP 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,apriori agreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.)cannotbe objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis.In theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany diversioninducedchangesinthesebiologicalresponsevariables. 4. DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith textinthebodyoftheOEMP.Forinstance,page3oftheOEMPclearlystates:InthecaseoftheAshlu 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. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated. Forinstance: 1. installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentof 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;
5.
IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE?
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Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff. Regards,
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management 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 any questions. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Wednesday, January 27, 2010 3:26 PM Bennett, Timothy A ENV:EX FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Baseline studies and data 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 Piesold Consulting; 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 no biological or geomorphological data collection/analysis seems to have been undertaken in the diversion reach in the last six years (ie. post-licensing). I reviewed the biological & geomorphological data collection/analysis that was completed prior to licensing (ie. the pile of reports that Robert is sending to you, under the pretence of baseline data) and it is far from adequate in terms of allowing any quantification of post-diversion changes to instream biota. Scott
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Wednesday, January 27, 2010 2:22 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: 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 any questions 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: Sent: To: Cc: Subject: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, November 16, 2009 1:15 PM Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX; Wilson, Greg ENV:EX RE: Ashlu Incident
an artfully crafted understatement... C
Francesca Knight, M.Sc., R.P.Bio. Habitat Biologist Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: 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:EX Subject: 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 along the line...
From: Busto, Vince [mailto:Vince.Busto@dfo-mpo.gc.ca] Sent: Monday, November 16, 2009 11:30 AM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; Knight, Francesca Subject: RE: Ashlu Incident
Tim, Scott, and Francesca

S. 13, S. 16, S22 S. 13, S. 16, S22
We can discuss this during our IPP meeting tomorrow
Vince
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: November 16, 2009 9:48 AM To: Knight, Francesca
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Cc: Busto, Vince; Bennett, Timothy A ENV:EX Subject: RE: Ashlu Incident
Unreal... Isnt the proponent obligated to ensure that the EM is onsite prior to initiating/undertaking such activities? S
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Monday, November 16, 2009 7:56 AM To: Babakaiff, Scott C ENV:EX Subject: FW: Ashlu Incident
...it never ends, C
From: Christine Becker [mailto:cbecker@cerg.ca] Sent: November 15, 2009 12:57 PM To: Robert Kulka; fhebert@innergex.com; gsteeves@ameresco.com; Timothy.Bennett@gov.bc.ca; Knight, Francesca; rblanchet@innergex.com; Busto, Vince Cc: Mike Nelson; Ken McNamara Subject: Ashlu Incident
HiAll, PleasebeadvisedofthefollowingeventsasobservedbytheEMtoday: TheEMarrivedonsitethismorningtodiscoverthatrampingupto10CMhadalreadybeeninitiatedandcompleted priortotheEMsarrival.TheEMobservedthatflowsapproximately150mdownstreamoftheintakewerebelow theminimumflowrequirementof2.4CM.TheEMalsonotedthattheObermeyerweirwasfullyclosedandasa resulttherewaspotentialforfishstrandingdownstreamoftheweir.TheEMimmediatelyadvisedInnergex personneloftheseissuessubsequentlygate1oftheweirwasimmediatelyopenedtoallowflowtopass 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, CA Unit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | FAX: 604 815-0904 cbecker@cerg.ca | www.cascade-environmental.ca 2
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From: Sent: To: Cc: Subject: Attachments: Wilson, Greg ENV:EX Monday, November 16, 2009 1:08 PM 'Knight, Francesca'; Babakaiff, Scott C ENV:EX; 'Busto, Vince'; Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX RE: Ashlu Incident image001.jpg
Doh,sothearsenicstoriesaretrue!Ithinkourguidlinesare5ug/L,butIknownaturalstreamconcentrationsare canbehigher.Whatvalueshavebeenrecordedrecently? Havefishkills/strandingsoccurredaswell? Greg

From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] 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:EX Subject: RE: Ashlu Incident
Hi Greg, thanks very much for your comments; I think you are bang on with your concerns. We are much further along with a defensible management strategy for the arsenic issue, but admittedly, we still don't know what arsenic concentrations will be like over the long-term, during plant operations.
S. 16, S. 13
From: Wilson, Greg ENV:EX [mailto:Greg.Wilson@gov.bc.ca] Sent: November 16, 2009 12:50 PM To: Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EX; Knight, Francesca Cc: Stoddard, Erin M ENV:EX Subject: RE: Ashlu Incident
HeyFolks, Ihavebeenhearingrumblingsfromvarioussources(inandoutofgovernment)regardingmultipleissues,violations andfishkillsassociatedwiththeAshluIPP,soIaskedScottinpassingandIseethereissometruth.

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Pleaserememberthatatthecoreoftheissueisasmallandstrugglingpopulationofsteelhead/rainbowsdirectly affectedbythisIPPandany/allactionsinvolvingflowandwaterqualityaffectsthem. Idontthinksteelhead,asthespeciesmosteffected,gotfaircompensationoriginally(althoughMatthasdonea reallygoodjobonthechannelsandponds),andifthearsenicpoisoningandfishstrandingstoriesaretruethenthe cumulativeeffectscouldbesignificant. PleaseremindtheproponentandtheirEMsofthefollowing: TheAshluisprobablyalreadyunderseededwithjuveniles,asworkdonebyARL(graphbelow)andBCCFoverthe lastfewyearsconstantlyshowsomeofthelowestfrydensitiesintheregion.Parrlivebelowthepowerhouseforup to34yearsbeforesmoltingsothereisalongperiodofvulnerabilitytoconstructionandoperationalimpacts (authorizedornot). ThisreturnseasontotheSquamishasawholewillprobablybereallybad.Itwillbeaboutthelargestspillimpact yearforCheakamusfishresultingfromthe2005CNchemicalspillandIthinkthatisdraggingdowntheSquamish population(peoplecatchCheakamusfishintheSquamish),whichisallontopofaperiodofextremelylowocean survival,andasaresultSquamishsteelheadareclassifiedasanExtremeConservationConcernformanagement.If thereismortality(evenifsmall)thenweshouldlookatthenextmanagementactions.Asthereisalreadyabaitban ontheAshlu,sothenextstepwouldlikelybeananglingclosure.IfyouhaveguidanceoropiniononthisIwould appreciatesomefeedback.SteelheadingseasonontheAshlu,andtherestofthewatershedstartsinafewmonths andtherewillbecrankyanglersabootespeciallyastheytryandfisharoundtheOlympicroadrestrictions,etc.. Couldsomeonepleasekeepmeappraisedonallinstances/actionswhichhavethepotentialtoimpactfishoverwhat theproponentispermitted. Thanksmuchfolks! Cheers, Greg
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From: Babakaiff, Scott C ENV:EX Sent: 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:EX Subject: RE: Ashlu Incident

S. 13, S. 22, S16 S. 22, S. 13, S16
We can discuss this during our IPP meeting tomorrow
Vince
Page 37 FNR-2011-00265 Part 2
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: November 16, 2009 9:48 AM To: Knight, Francesca Cc: Busto, Vince; Bennett, Timothy A ENV:EX Subject: RE: Ashlu Incident
...it never ends, C

CHRISTINE BECKER (NEE CUNLIFFE). B.SC., B.I.T. Cascade Environmental Resource Group Ltd. 4
Page 38 FNR-2011-00265 Part 2
Whistler and Squamish, BC | Whitehorse, YK | San Diego, CA Unit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | FAX: 604 815-0904 cbecker@cerg.ca | www.cascade-environmental.ca
Page 39 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, December 7, 2009 10:56 AM Robert Kulka Busto, Vince; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX; Christine Becker; Ken McNamara; Richard Blanchet 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 have not 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 the identification of areas susceptible to fish stranding. The limits of the pools will be marked and channels designed to link the pools to each other and eventually the main body of the river. The slopes, 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 the channels constructed in the first phase evaluated. Should it be determined there is still potential for stranding, 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 stranding has been mitigated..Clear segregation of the work area from the adjacent stream to ensure no deleterious materials are allowed to enter the watercourse.. Confirmation from DFO and ESD that this is not instream work is required.. My comments are as follows: 1. The works are definitely "instream" and should be conducted during next year's low-risk fisheries work window. For the interim, we may want to consider cracking one of the Obermeyer weir gates such as to allow low flows over the spillway (similar to what we did during the summer headpond filling). I believe you are looking into the possibility of a v-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 for discussion. The general and qualitative nature of Mr. Steeve's recommended spillway fix precludes DFO from offering any substantive comments. 3. Further to comment 2 - please prepare a detailed spillway modification plan for review by DFO and MoE, including a construction management plan to prevent the release of sediment during the works. I have seen a draft modification plan (provided by Cascade) that shows modifications to the pools closest to the weir (upstream), but does not appear to address stranding in the lower pools (just upstream of the confluence with the river). Fish are also stranded in these pools if no water is provided via a crack/v-notch in the Obermeyer, so this area needs to be addressed for the longterm. regards, Francesca
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From: Robert Kulka [mailto:RKulka@innergex.com] Sent: December 4, 2009 10:22 AM To: Knight, Francesca Subject: 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 the improvements in the d/s area of the spillway before we loose access due to snow. In order to proceed I need to know if you consider this work instream or not instream as per my inquiry on November 26 (see underneath). 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 will continue to perform the sampling and will continue to forward sample results to you. Regards, Robert ________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing. Construction Manager Innergex nergie renouvelable - Innergex Renewable Energy
Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2 Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 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 Manager Innergex nergie renouvelable - Innergex Renewable Energy
Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2 Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434 -----Original Message----From: Steeves, George [mailto:gsteeves@ameresco.com] Sent: Thursday, November 26, 2009 2:02 PM To: Robert Kulka Subject: 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, George Sent: Thursday, November 26, 2009 4:57 PM To: timothy.bennett@gov.bc.ca Subject: Leave to Construct - Spillway Apron - Fisheries Improvements (File No 2001264; Licence No. 102203) Tim Please find the above leave to Construct attached. Iam planning on visiting Ashlu on Monday. Any interest in someone coming along/ George
************************************************************************************** NOTE: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are
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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: Sent: To: Cc: Subject: Attachments: 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 the indicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusions regarding 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, which is useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise useless for telling us whether the diversion has influenced the fish population. In addition, there is no method for counting adult 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 are some other short-comings related to methods, but the limited analysis is the biggie. In addition, there is of course nothing proposed for evaluating changes to community structure, but you all know that is my main concern with how invertebrates 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 we would be able to draw any meaningful conclusions about how the altered flow regime affected available habitat types. Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Thursday, January 7, 2010 6:54 PM Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX; Busto, Vince Ashlu long-term monitoirng image001.jpg; image002.jpg; image003.jpg
Page 67 FNR-2011-00265 Part 2

From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Friday, January 8, 2010 4:17 PM Bennett, Timothy A ENV:EX Ashlu OPP
Tim, Ive reviewed the Ashlu IPP Operating Parameters & Procedures (OPP) Report (Revision A) dated October 28 2009, and submitted to MOE on November 24 2009. In short, the basic structure of the OPP report (ie. the Table of Contents) seems reasonable, but additional work is required to address: a) information deficiencies and, b) contradictions between text in the OPP and documents referenced in the Appendices (e.g. Water License, DFO Autorization). As you know, I have a relatively narrow scope in review of OPPs (given my relatively narrow expertise), but what its worth, here is the additional work I recommend: 1. Flow Monitoring (p. 3, 23) including IFR verification (p. 11), ramping (p. 7) and maximum licensed flow diversion (not included in OPP)- much more detail is required regarding development (and maintenance) of calibrated rating curves for each of the stream flow monitoring stations, with explicit commitments regarding data collection, archival and submission (including agency notification in the event of shutdowns or IFR deficiencies within 24 hours) be detailed in the OP&P. For instance: regarding continuous stage measurement and digital data logging, Section 3.2.2.3 of the BC Provincial Hydrometric Standards (2008) recommend collection of a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, a much shorter stage sampling frequency is recommended (say, 10-second), with a 2-minute average for storage in the data logger (and submission to agencies). It is also recommended that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment damage) do not result in lengthy data gaps. For purposes of graphical presentation in annual monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data. These recommendations regarding streamflow data collection, archival and submission apply to verification of compliance with: IFR, ramping and maximum flow diversion. Suffice to say that details regarding verification of IFR compliance as proposed in the OPP (Attention will also be given to confirm IFR flows by visually comparing the IFR probe reading with the benchmark in the creek at the IFR gauging station per Section 3.1) are inadequate. Likewise, the proposed details regarding verification of ramping rate compliance (Section 2.2.2) provide little detail, and proposed locations (250 m and 800 m downstream of the intake) will not necessarily be those that are of greatest interest to DFO & MOE. 2. Ramping (p.7-8)- Also, Im confused by text in Section 2.2.2 of the OPP concluding that The DFO Authorization for Ashlu Creek stipulates a ramping rate of 90 to 120 minutes for full diverted flow of 29 cms but Actual Ramping Rates will be established during the commissioning process. I understand that a ramping study is scheduled to be undertaken during commissioning, but it seems that the proponent believes that (1) the ramping rates have already been established, and (2) there is no need to describe within the OPP any means of verifying ramping rate compliance. I do not agree with this belief. 3. Shutdowns (p.13-15): number, frequency, duration and cause (e.g. per the types listed on p.23 of OPP) should be documented & submitted to MOE annually. Any shutdowns which result in noncompliance of license conditions (e.g. IFR provision, ramping rates) or fish stranding should result
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trigger notification to MOE within 24 hours and mitigative prescriptions (e.g. fish salvage) as needed. 4. Fish Passage at dam (p.18): additional detail regarding specific activities to be undertaken to ensure fish passage at the intake such as frequency & timing of fish ladder inspections, methods for inspection, mitigative strategies, etc. Erin Stoddard provided a bit of verbage on this issue for his review of the Upper Harrison OPPs:
Inspections and maintenance of the intake fishway will be undertaken daily to ensure that fish passage is functional during all expected fish migration periods (e.g. April to June for Rainbow Trout). The DFO Section 35(2) authorization requires passage to remain operational at a minimum from April 15th to May 15th eac year. However, depending on flows, temperature, and associated fish activity at the intake fishway will remain open for longer periods and will be maintained operational throughout the year if considered appropriate or as directed by DFO or MOE. Fish counters will be installed at both the upstream and downstream ends of the fishway to assess its effectiveness and record fish movement activity. Fish mortalities associated with the fishway or intake will be reported to MOE and DFO within 24 hours. Inspections, maintenance, and fish movement, stranding and mortalities will be recorded and reported annually. A small boat will be available at the intake daily to cross the headpond to access the fishway when flows are too high to make crossing of the stream practical or safe downstream of the intake. The Long Term Aquatic Monitoring Program will review the annual reports to assess fish movement activity and the performance of the fishway, and will provide a means for MOE and DFO to determine whether fishway changes or replacement is required.
5. Sediment & LWD throughput past the dam (p.8): Section 2.2.3 of the OPP provides some reasonable detail regarding proposed sediment management at the headpond, but it should also include consideration of Large Woody Debris (LWD) management. Maintenance of LWD passage past the dam is explicitly required in the agency approvals. 6. Fish access into the tailrace (p.4)- have fish been: a. explicitly excluded from the tailrace, or, b. are they allowed unimpeded migration into & out of the tailrace without risk of stranding during emergency shutdowns/ramping, or, c. are there some operational details required in the OPP which prescribe activities to be undertaken by the proponent to ensure a) or b)? Thanks for the opportunity to provide input, and lemme know if you require any supplemental info or detail, Scott
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Non-Compliance Form Compliance and Enforcement Policy and Procedure

Version 2 - May, 2009
Section A: Record of Non-Compliance

Who Completes This Section?
File #: 31010-50/IRP-EP
The program area for the purpose of: 1) Tracking internal divisional response to non-compliance 2) Referring an investigation to the COS, i.e. investigation is not subject to IRP or 3) Requesting a pre-investigation review by the IRT or RMCT The COS for the purpose of: 1) Initiating a pre-investigation review. (This form is not for use by the COS to refer incidents of noncompliance to a program area for potential response. An occurrence report is used for that purpose.)
Date Initiated: June 2, 2011
Initiator: Scott Barrett
Company/Individual: Ministry of Forests, Lands and Natural Resource Operations - Ecosytems Section Address: 10470 152 Street Licence/Approval/Permit #: Date of Non-Compliance: April 20, 2011 Fisheries Act, Water Act
Regulatory requirement contravened: Non-Compliance Decision Matrix:
Environmental, human health or safety - Level of Impact: Level 4 Likelihood of Compliance - Category: Category B Summary: The precise environmental impacts are not entirely understood at this point. However, the potential impacts to fish values in this river are very significant and ongoing. Efforts to address the risks through ongoing engagement with the operators has not been satisfactory.
Please Attach, if applicable:

Photos Correspondence with any/all agencies Permit/Approval/Licence Company/Property searches (BC Online) Inspection Form File Notes/sketch/site map Record of past non-compliance Non-compliance entry in program database
Additional Notes: MFLNRO was sent attached correspondance from the environmental coordinator of Innergex Renewable Energy Inc. regarding a significant fish kill associated with their powerplant operations on the Ashlu River.
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Section B: Purpose of Form

Who Completes This Section? The program area for the purpose of: 1) Tracking internal divisional response to non-compliance 2) Referring an investigation to the COS, i.e. investigation is not subject to IRP or 3) Requesting a pre-investigation review by the IRT or RMCT Note: Program areas that are only printing sections A & B should print and retain only pages 1 and 2. The COS for the purpose of: 1) Initiating a pre-investigation review. (This form is not for use by the COS to refer incidents of noncompliance to a program area for potential response. An occurrence report is used for that purpose.)
Indicate the purpose for completing this form (select one option below only):
1. Recommendation of internal divisional response to non-compliance. Action: Advisory Notes: Initiator: Section Head: Date: Date:
ROUTING: Initiator: Forward sections A & B of this form to your Section Head. 2. Referral to the COS for investigation (i.e. investigation is not subject to the IRP). ROUTING: Initiator: Forward sections A & B of this form to the COS Field Supervisor in location of noncompliance. 3. Request for pre-investigation review. Complete Section C: Request for Pre-Investigation Review
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Section C: Request for Pre-Investigation Review

Who Completes This Section? The initiator (program area staff or CO) for the purpose of requesting a pre-investigation review by the Investigation Review Team (IRT).
Has cross-divisional consultation occurred?

No Why not? Yes With Whom? Tim Bennett, Water Allocation Section Was there consensus? Yes If No, what were the points of disagreement?
Estimated staff resources/ budget requirements

Staff resources (estimated): Financial Resources (estimated):
Has the Investigation already begun?

No Yes, due to exigent circumstances Yes, due to ongoing program support not having been previously anticipated
Date submitted to the IRT via Field Supervisor or Section Head: ROUTING: PROGRAM AREAS: Send to the Section Head who will then form the IRT. COS: Send to the Field Supervisor who will then form the IRT. The IRT must conduct a pre investigation review and make a decision within 15 business days of having received the form.
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Section D: Pre-investigation Review by the IRT

Who Completes This Section? The COS Field Supervisor for the purpose of recording the decision made by the IRT.
The IRT must conduct a pre investigation review and make a decision within 15 business days of having received the form.
Investigation Supported (Check one):

No Rationale for Decision: Action/Direction/Notes: ROUTING: IRT: Advise relevant parties within their division of the IRTs decision. COS Field Supervisor: Notify initiator and update tracking log. COS Admin: File paper copy of Non Compliance Form using the file number found on the form. Yes Action/Direction/Notes: Financial Resources Allocated (by division): Staff Resources Assigned: ROUTING: IRT: Advise relevant parties within their division of the IRTs decision. COS Field Supervisor: Notify initiator, update tracking log and forward the form to the lead investigator. COS Lead Investigator: Attach this form to COORS case. COS Admin: File paper copy of this form using COORS case number (once investigation is completed you will receive the completed copy). Referral is made to the Regional Management Compliance Team (RMCT)
The IRT cannot reach consensus; The IRT is unable to resource the investigation; and/or The investigation is sensitive in nature.
Action/Direction/Notes: Recommended Allocation of Financial Resources (If applicable): Recommended Assignment of Staff (If applicable): ROUTING: IRT: Advise relevant parties within division of the IRTs decision. COS Field Supervisor: Notify COS Operations Manager and update tracking Log.
IRT Members:
COS Field Supervisor: Division Representative Name: Division Representative Name: Division Representative Name: Decision Date (click to update tracking log): Division: EP Division: EP Division: EP
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Section E: Pre-Investigation Review by the RMCT

Who Completes This Section? The COS Operations Manager for the purpose of recording the decision made by the RMCT as a result of a referral made by the IRT for a pre-investigation review. RMCT must conduct a pre investigation review and make decision within 15 business days of receiving the NCF from the IRT.
Investigation Supported (Check one):

No
Rationale for Decision:

ROUTING: RMCT: Advise relevant parties within their division of the RMCTs decision. COS Operations Manager: Notify the COS Field Supervisor. COS Field Supervisor: Notify IRT and initiator and update tracking log. COS Admin: Replace filed paper copy of the form using the file number found on the form.
Yes
Resources Assigned:
Agree with the recommendations by the IRT in Section D. Do not agree with the recommendations by the IRT in Section D. Resources assigned are detailed below. Allocation of Financial Resources: Assignment of Staff:
Notes:
ROUTING: RMCT: Advise relevant parties within their division of the RMCTs decision. COS Operations Manager: Notify Field Supervisor. COS Field Supervisor: Notify initiator and IRT, update tracking log & forward form to lead investigator. COS Lead Investigator: Open COORS case & attach form. COS Admin: Replace filed paper copy of this form using COORS case number (once investigation is completed you will receive the completed copy).
RMCT Members:
COS Operations Manager: Division Representative Name: Division Representative Name: Division Representative Name: Decision Date (click to update tracking log): Division: EP Division: EP Division: EP
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Section F: Investigation Findings and Recommendation(s)

Who Completes This Section? The lead investigator (COS) for the purpose of outlining the investigation findings and recommendations to the IRT/RMCT.
COORS Number: Investigative Team Findings Non-Compliance Decision Matrix: Environmental, human health or safety - Level of Impact: Level 1 Likelihood of Compliance - Category: Category A Summary:
Investigative Team Recommendation(s):

Action: Advisory Notes:
Investigative Team Members:

COS Lead Investigator: Division Representative Name: Division Representative Name: Division Representative Name: Division: EP Division: EP Division: EP
Date submitted to IRT/RMCT for Post Investigation Review (click to update tracking log): ROUTING: COS Lead Investigator Forward form to Field Supervisor. COS Field Supervisor: Convene IRT or if pre-investigation review was conducted by the RMCT, forward this form to the Ops Manager for convening of the RMCT. Update the tracking log.
IRT or RMCT must conduct a post investigation review and make decision within 15 business days of receiving the NCF from the IRT.
Page 75 FNR-2011-00265 Part 2
Section G: Post Investigation Review by the IRT or RMCT

Who Completes This Section? The COS Field Supervisor (IRT) OR the COS Operations Manager (RMCT) for the purpose of recording the results of the post-investigation review. IRT or RMCT must conduct a post investigation review and make a decision within 15 business days of receiving Section F of the Non-Compliance Form.
Recommendation Supported? Rationale: Action Required: Staff Assigned:
Yes
No
IRT/RMCT Members: COS Field Supervisor/Operations Manager: Division Representative Name: Division Representative Name: Division Representative Name: Decision Date (click to update tracking log): Division: EP Division: EP Division: EP
ROUTING: IRT/RMCT: Advise relevant parties within their division of the decision. COS Operations Manager: Notify Field Supervisor of decision. COS Field Supervisor: Notify Investigative Team and update tracking log with decision date and result. COS Admin: Replace paper file with completed version of the form using the COORS case number.
Page 76 FNR-2011-00265 Part 2

From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Wednesday, July 15, 2009 4:30 PM Bennett, Timothy A ENV:EX Biological & IFR monitoring at Ashlu IPP
Tim, A quick question regarding the conditional water license (#102203) for Ashlu IPP: Condition i (1) of the CWL sets the values for the parameter of the minimum IFR. Condition i (2) requires a monitoring program suitable to determine the nature of any impacts of the project on fish & wildlife and, Condition i (3) requires a monitoring program to evaluate the effect of the regulation of works as ordered in number 1 above.
But I have no record of such a monitoring program having been submitted to MOE...do you? Scott
Page 77 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: For your reference. The finished grade on the blasted rock channel downstream Ashlu Obermeyer weir is not acceptable, and is not as was designed. The surface contains deep pocket that will repeatedly trap fish when flows recede from the area. My suggestion to Robert Kulka when I was onsite a few days ago was that the pocket would need to be filled with concrete to and that the grading would need to be established to guide the fish out of the area when flows to the area downstream of the weir decreases. Busto, Vince [Vince.Busto@dfo-mpo.gc.ca] Friday, August 14, 2009 10:43 AM Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX Ashlu Head pond filling test (FW: stranded fish) fish strand 1.JPG; fish strand 2.JPG; fish strand 3.JPG
Vince Busto, B.A.Sc., P.Eng. Habitat and Hydrotechnical Engineer Habitat and Enhancement Branch Lower Fraser River Fisheries and Oceans Canada 100 Annacis Parkway, Unit 3 Delta, BC V3M 6A2 Government of Canada
| | | | | | |
Ingnieur de l'habitat et de lhydrotechnique Protection et mise en valeur des habitats Le bas Fraser Pches et Ocans Canada 100 Annacis Parkway, Unit 3 Delta (C.-B.) V3M 6A2 Gouvernement du Canada
Telephone/Tlphone 604-666-8281 Facsimile / Tlcopieur 604-666-6627 E-mail Vince.Busto@dfo-mpo.gc.ca
-----Original Message----From: Knight, Francesca Sent: August 11, 2009 6:38 PM To: Busto, Vince Subject: stranded fish Hi VInce...here are some fish photos from Ashlu. Photo 1 is from one pool (one fish); photos 2 and 3 are of two fish in one pool. C
Page 78 FNR-2011-00265 Part 2
Page 79 FNR-2011-00265 Part 2
Page 80 FNR-2011-00265 Part 2
Page 81 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Friday, September 4, 2009 3:14 PM Bennett, Timothy A ENV:EX Neuman, Ross ENV:EX; Willcox, Michael ENV:EX FW: Biological & IFR monitoring at Ashlu IPP
Hi Tim, This was the email I referenced during our conference call chats earlier this week. DFO (Vince) mentioned that he doesnt have a record of their monitoring program either...so it seems unlikely that the proponent has submitted one. Scott
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Wednesday, July 15, 2009 4:30 PM To: Bennett, Timothy A ENV:EX Subject: Biological & IFR monitoring at Ashlu IPP
Tim, A quick question regarding the conditional water license (#102203) for Ashlu IPP: Condition i (1) of the CWL sets the values for the parameter of the minimum IFR. Condition i (2) requires a monitoring program suitable to determine the nature of any impacts of the project on fish & wildlife and, Condition i (3) requires a monitoring program to evaluate the effect of the regulation of works as ordered in number 1 above.
But I have no record of such a monitoring program having been submitted to MOE...do you? Scott
Page 82 FNR-2011-00265 Part 2
Page 83 FNR-2011-00265 Part 2
Page 84 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Saturday, October 24, 2009 7:00 PM Clark, John Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX FW: Ashlu penstock water release image001.jpg
Hi John, this is regarding an IPP proponent who is intending to release 2,000,000L of drainage water to the Ashlu River in Squamish. T arsenic, and I was just informed S. 13, S. 16 of the plan last night I wanted to inform you, and I will keep you posted. I h he release of water without consultation with the province and Environment Canada. The release is set for tomorrow. I'll keep you posted. regards, Francesca
From: Knight, Francesca Sent: Sat 10/24/2009 10:47 AM To: Robert Kulka; Busto, Vince; Mike Nelson Cc: cbecker@cerg.ca; Hilary Lindh Subject: Ashlu penstock water release
Hello everyone, Mike and I discussed the water quality of the penstock water (currently being held in the tailrace). There are a couple of areas of concern:
1. LEPH and HEPH concentrations are moderately high; LEPH = 360 ppb and HEPH = 1300 ppb, and there is a sheen on the water. While there is no ambient regulatory criteria for either compound, the CSR for (I think) HEPH is 5000 ppb. The water HEPH concentration is high for my liking. Mike and I talked about a plan to pump water from beneath the surface, and collect the surface water with sheen last. Conversely, the surface water could be pumped to ground first, then the water in the tailrace could be released last. This may work. 2. The arsenic concentration in the water is too high, in my opinion, for release. The BC ambient water quality guideline for arsenic is 5 ppb, and the contaminated sites regulation criteria is 50 ppb; the measured concentration in the tailrace is 140 ppb. Background arsenic was measured at 1 ppb.While this site does not fall under the jurisdiction of the CSR, S13, S16 criteria. Mike was considering the po have to release per unit time (based on river discharge) to achieve a concentration that's close to the ambient criteria (5 ppb). Without knowing water hardness and TOC concentation, it's hard for me to comment on the potential toxicity of the water in the Ashlu receiving environment, but if consider just the absolute concentration, the literature indicates that 140 ppb is sufficient to cause toxicity to some types of aquatic organisms. Chessy
Page 85 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Saturday, October 24, 2009 11:18 PM Knight, Francesca RE: Ashlu penstock water release image001.jpg
Nice work...Saturday night and all! Seriously: kudos for the dedication, Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Sat 24/10/2009 6:59 PM To: Clark, John Cc: Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX Subject: FW: Ashlu penstock water release Hi John, this is regarding an IPP proponent who is intending to release 2,000,000L of drainage water to the Ashlu River in Squamish. The water exceeds the Contaminated Sites Regulation criteria for arsenic, and I was just informed of the plan last night. I wanted to inform you, and I will S. 13, S. 16 keep you posted. I h he release of water without consultation with the province and Environment Canada. The release is set for tomorrow. I'll keep you posted. regards, Francesca
1. LEPH and HEPH concentrations are moderately high; LEPH = 360 ppb and HEPH = 1300 ppb, and there is a sheen on the water. While there is no ambient regulatory criteria for either compound, the CSR for (I think) HEPH is 5000 ppb. The water HEPH concentration is high for my liking. Mike and I talked about a plan to pump water from beneath the surface, and collect the surface water with sheen last. Conversely, the surface water could be pumped to ground first, then the water in the tailrace could be released last. This may work. 2. The arsenic concentration in the water is too high, in my opinion, for release. The BC ambient water quality guideline for arsenic is 5 ppb, and the contaminated sites regulation criteria is 50 ppb; the measured concentration in the tailrace is 140 pp S13, S16 fall under the jurisdiction of the CSR, criteria. Mike was considering the possibility of dilution, but I don't know what volume of water you would have to release per unit time (based on river discharge) to achieve a concentration that's close to the ambient criteria (5 ppb).
Page 86 FNR-2011-00265 Part 2
Without knowing water hardness and TOC concentation, it's hard for me to comment on the potential toxicity of the water in the Ashlu receiving environment, but if consider just the absolute concentration, the literature indicates that 140 ppb is sufficient to cause toxicity to some types of aquatic organisms. Chessy
Page 87 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Sunday, October 25, 2009 6:55 PM Babakaiff, Scott C ENV:EX RE: Ashlu penstock water release image001.jpg
thanks, put a damper on the riding though... C
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: Sat 10/24/2009 11:18 PM To: Knight, Francesca Subject: RE: Ashlu penstock water release
Nice work...Saturday night and all! Seriously: kudos for the dedication, Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Sat 24/10/2009 6:59 PM To: Clark, John Cc: Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX Subject: FW: Ashlu penstock water release Hi John, this is regarding an IPP proponent who is intending to release 2,000,000L of drainage water to the Ashlu River in Squamish. The water exceeds the Contaminated Sites Regulation criteria for arsenic, and I was just informed of the plan last night. I wanted to inform you, and I will S. 13, S. 16 keep you posted. I h he release of water without consultation with the province and Environment Canada. The release is set for tomorrow. I'll keep you posted. regards, Francesca
1. LEPH and HEPH concentrations are moderately high; LEPH = 360 ppb and HEPH = 1300 ppb, and there is a sheen on the water. While there is no ambient regulatory criteria for either compound, the CSR for (I think) HEPH is 5000 ppb. The water HEPH concentration is high for my liking. Mike and I talked about a plan to pump water from beneath the surface, and collect the surface water with sheen last. Conversely, the surface water could be pumped to ground first, then the water in the tailrace could be released last. This may work.
Page 88 FNR-2011-00265 Part 2
2. The arsenic concentration in the water is too high, in my opinion, for release. The BC ambient water quality guideline for arsenic is 5 ppb, and the contaminated sites regulation criteria is 50 ppb; the measured concentration in the tailrace is 140 pp S. 16, S. 13 fall under the jurisdiction of the CSR, criteria. Mike was considering the po have to release per unit time (based on river discharge) to achieve a concentration that's close to the ambient criteria (5 ppb). Without knowing water hardness and TOC concentation, it's hard for me to comment on the potential toxicity of the water in the Ashlu receiving environment, but if consider just the absolute concentration, the literature indicates that 140 ppb is sufficient to cause toxicity to some types of aquatic organisms. Chessy
Page 89 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Monday, October 26, 2009 1:19 PM 'Busto, Vince'; Bennett, Timothy A ENV:EX RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
And still no OEMP.

From: Busto, Vince [mailto:Vince.Busto@dfo-mpo.gc.ca] Sent: Monday, October 26, 2009 1:08 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Subject: Recent issues (FW: Ashlu settling pond sediments) Gentlemen, my short list of recent significant issues related to Ashlu: 1) Left bank sluiceway trapping of fish in rock pools during dewatering 2) Settling pond contamination (see below) 3) High arsenic concentrations in the water impounded in the penstock Vince Busto, B.A.Sc., P.Eng. Habitat and Hydrotechnical Engineer Habitat and Enhancement Branch Lower Fraser River Fisheries and Oceans Canada 100 Annacis Parkway, Unit 3 Delta, BC V3M 6A2 Government of Canada
| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature, concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature. In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria.
1
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In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 23, 2009 12:10 PM To: Knight, Francesca Subject: RE: Ashlu settling pond sediments Hello Francesca, As per my voicemail from earlier today: I saw Matt and Sam on site this morning and they are basically finished with what can be done at this time without the test results of your samples and your recommendations what to do with the material. They would need your feedback in order to carry on with the work. I am on site all day today and I would be happy to relay your feedback to Matt and Sam so they can continue to work. You can reach my via email or at the powerhouse under 604.898.8287. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, October 15, 2009 10:32 AM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments Hi Robert, you are correct, Cascade does not need to take another sample, and you will receive copies of the results. regards,
2
Page 91 FNR-2011-00265 Part 2
Francesca
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 14, 2009 5:44 PM To: Knight, Francesca Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments Hello Francesca; I was at the work site yesterday afternoon and Sam showed me the areas of concern. As per your email, Cascade had taken a sample of the material in the past and I had sent them a note last night to inspect the area and take another sample if found necessary (see attached email). Since you have taken a sample today I understand there is no need for Cascade to take another sample at this time. I would appreciate if you could copy to me your future email to Mike with sample results for our information and records. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, October 14, 2009 5:10 PM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: Ashlu settling pond sediments Hello Robert, I went on site to the old settling pond this afternoon (that was used for disposal of tunnel drilling material), which is being recontoured and vegetated for habitat. Sam had some concerns about the odour and appearance of the material, so I obtained sample containers and went to the work area. My observations of the sediments are: 1. hydrogen sulphide odour, possibly due to exposure of aqueous sediments to oxygen if the pond had been drained 2. hydrocarbon odour and slight sheen, as well as black patches within the drier material, possibly indicating oil staining Without sediment chemistry data, I am not comfortable using this material as aquatic habitat substrate and/or wetland bench substrate.
3
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I spoke with Mike Nelson this afternoon, and he confirmed that sediments have recently been tested for metals, so I will only request a sulphide and hydrocarbon analysis on these samples (pending my review of recent analytical results, which Mike just sent to me). Also, he is sending me bioassay results... that will be very useful if a recent pond sample was tested. I will drop the samples off tomorrow morning, and let you and Mike know the results. regards, Francesca
Page 93 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Babakaiff, Scott C ENV:EX Monday, October 26, 2009 1:33 PM 'Busto, Vince'; Bennett, Timothy A ENV:EX 'Knight, Francesca' RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
Im not certain, but I dont think so.

From: Busto, Vince [mailto:Vince.Busto@dfo-mpo.gc.ca] Sent: Monday, October 26, 2009 1:31 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: Knight, Francesca Subject: RE: Recent issues (FW: Ashlu settling pond sediments) Do they have a leave to commence power generation?
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: October 26, 2009 1:19 PM To: Busto, Vince; Bennett, Timothy A ENV:EX Subject: RE: Recent issues (FW: Ashlu settling pond sediments)
And still no OEMP.

| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments
1
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Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature, concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature. In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria. In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
________________________________________
Page 95 FNR-2011-00265 Part 2
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, October 15, 2009 10:32 AM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments Hi Robert, you are correct, Cascade does not need to take another sample, and you will receive copies of the results. regards, Francesca
________________________________________
3
Page 96 FNR-2011-00265 Part 2
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, October 14, 2009 5:10 PM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: Ashlu settling pond sediments Hello Robert, I went on site to the old settling pond this afternoon (that was used for disposal of tunnel drilling material), which is being recontoured and vegetated for habitat. Sam had some concerns about the odour and appearance of the material, so I obtained sample containers and went to the work area. My observations of the sediments are: 1. hydrogen sulphide odour, possibly due to exposure of aqueous sediments to oxygen if the pond had been drained 2. hydrocarbon odour and slight sheen, as well as black patches within the drier material, possibly indicating oil staining Without sediment chemistry data, I am not comfortable using this material as aquatic habitat substrate and/or wetland bench substrate. I spoke with Mike Nelson this afternoon, and he confirmed that sediments have recently been tested for metals, so I will only request a sulphide and hydrocarbon analysis on these samples (pending my review of recent analytical results, which Mike just sent to me). Also, he is sending me bioassay results... that will be very useful if a recent pond sample was tested. I will drop the samples off tomorrow morning, and let you and Mike know the results. regards, Francesca
Page 97 FNR-2011-00265 Part 2

From: Sent: To: Subject: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, November 2, 2009 11:57 AM Babakaiff, Scott C ENV:EX Ashlu issue
S. 16 Hi Scott, the proponent is wanting to discharge water from the penstock/tailrace that has been held since the Inspector's . I have water chemistry from this new proposed discharge, which confirmed two things: S. 16 1 the worst of the material was discharged on Sunday 2 flushing water is fairly clean (no CSR or BC WQG exceedances). Not sure I can keep the from discharging clean water, with a requirement of course for continued regular sampling of the discharge. Do you think Water Stewardship would want to wait until we have an OEMP submitted, which coul water? S16 and I a S16
I have asked Environment Canada where they sit on new discharge, but have not heard anything back yet. C
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From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Monday, November 2, 2009 12:00 PM 'Knight, Francesca' RE: Ashlu issue
Good questions, Francesca. As you may suspect, Ive got an opinion, but Tim Bennett is really the right person to provide advice going forward. In terms of their Sunday discharge, are there no retro-spective actions that could be initiated by DFO/WSD? Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Monday, November 2, 2009 11:57 AM To: Babakaiff, Scott C ENV:EX Subject: Ashlu issue
S. 16 Hi Scott, the proponent is wanting to discharge water from the penstock/tailrace that has been held since the Inspector's d. I have water chemistry from this new proposed discharge, which co things: S. 16 1. the worst of the material was discharged on Sunday 2. flushing water is fairly clean (no CSR or BC WQG exceedances). Not sure I can keep the from discharging clean water, with a requirement of course for continued regular sampling of the discharge. Do you think Water Stewardship would want to wait until we have an OEMP submitted, which coul address WQ monitoring for penstock flushing discharge, prior to allowing them to discharge more flushing water? S16 and I a S16
Page 99 FNR-2011-00265 Part 2

From: Sent: To: Subject: ...it never ends, C Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, November 16, 2009 7:56 AM Babakaiff, Scott C ENV:EX FW: Ashlu Incident

CHRISTINE BECKER (NEE CUNLIFFE). B.SC., B.I.T. Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YK | San Diego, CA Unit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | FAX: 604 815-0904 cbecker@cerg.ca | www.cascade-environmental.ca
Page 100 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, November 16, 2009 9:48 AM 'Knight, Francesca' 'Busto, Vince'; Bennett, Timothy A ENV:EX RE: Ashlu Incident
...it never ends, C
HiAll, PleasebeadvisedofthefollowingeventsasobservedbytheEMtoday: TheEMarrivedonsitethismorningtodiscoverthatrampingupto10CMhadalreadybeeninitiatedandcompleted priortotheEMsarrival.TheEMobservedthatflowsapproximately150mdownstreamoftheintakewerebelow theminimumflowrequirementof2.4CM.TheEMalsonotedthattheObermeyerweirwasfullyclosedandasa resulttherewaspotentialforfishstrandingdownstreamoftheweir.TheEMimmediatelyadvisedInnergex personneloftheseissuessubsequentlygate1oftheweirwasimmediatelyopenedtoallowflowtopass downstreamoftheweir,andrampingwasreversedtobringflowsinthecreekbackuptoambientconditions.

1
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CascadehasrequesteddetailedrampingdatafromInnergexpersonnelfortherampingactivitythatoccurredtoday.
Page 102 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, November 16, 2009 11:53 AM 'Busto, Vince'; Bennett, Timothy A ENV:EX; 'Knight, Francesca' Stoddard, Erin M ENV:EX; Wilson, Greg ENV:EX RE: Ashlu Incident

S. 13, S16, S22 S. 13, S16, S22
Vince
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: November 16, 2009 9:48 AM To: Knight, Francesca Cc: Busto, Vince; Bennett, Timothy A ENV:EX Subject: RE: Ashlu Incident
...it never ends, C
Francesca Knight, M.Sc., R.P.Bio. Habitat Biologist Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur
1
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Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada

Page 104 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Gents, Ive reviewed Revision B of the Operations Environmental Management Plan for the Ashlu Creek project (dated November 2009) as submitted by Innergex. The document is hereafter referenced simply as the OEMP since there is no authorship or bibliographic detail included. The absence of any explicit authorship is notable: there is little evidence that the OEMP has been composed by a licensed professional (e.g. RP Bio) with experience in the development or implementation of a monitoring program intending to fulfill agency needs. In short, the OEMP is typical for a preliminary draft, but it is troubling that completion of project construction & commissioning is imminent. Regardless, I have several primary concerns with the OEMP: 1. Few commitments to follow commonly-accepted guidelines for data collection & analysis, despite a proposal that monitoring details meet the requirements of DFO and MOE (p. 6 of the OEMP). I suggest many details proposed in the OEMP are seemingly arbitrary and do not reference any guidelines or standards typically referenced by Provincial or Federal agencies. For instance: 1. Stage-discharge rating curves- the OEMP commits to collecting a minimum of three discharge measurements and warns that ...it is unlikely that flows will be able to be measured above 20% of mean annual discharge. There are clear and well-established guidelines for developing stagedischarge rating curves (e.g. LWBC Hydrometric Guidelines; B.C. Provincial Hydrometric Standards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric% 20Standards%20V1.0,%20March%2012,%202009.pdf) that the proponent is recommended to meet. 2. Reporting of stream flow data: the OEMP commits to collect to collect flow data on a continuous basis, typically in 15-minute intervals and promises that data will be recorded...and can be provided to onsite DFO and/or MOE staff...for compliance purposes...flow data will be reported quarterly. I suggest there is no need to submit data to review agencies more frequently than once per year, but agencies must be informed within 24 hours of any non-compliance (e.g. IFR provision, ramping rates), and the proponent must resolve the issue of non-compliance immediately. In terms of data collection&logging, I note that the BC Provincial Hydrometric Standards (Section 3.2.2.3) recommends a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, particularly those with the diversity of fish values in the Ashlu diversion reach, I would recommend a much shorter stage sampling frequency (say, 10-second), with a 2-minute average for storage in the data logger (and submission to agencies). I would also recommend that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment damage) do not result in lengthy data gaps. For purposes of graphical presentation in monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data. 3. Development of ramping rates: Section 12.2 of the OEMP proposes that the ramping rates shall not exceed 29.0 cms per 90 minutes. This rate will be established during the commissioning process of the plant, and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991.... The OEMP provides some detail regarding proposed methods for establishing ramping rates during commissioning, but I would suggest that such protocol (and such interim rates like 29 cms per 90 minutes) should be established and scientifically-justified by an experienced professional, with reference to established agency criteria (e.g. DFOs default hourly ramping rates of 2.5 cm & 5.0 cm for fry & juveniles) or recommended guidelines. Finally, I suggest that the commitment within Section 14 of the OEMP to submit the ramping rate report six months after commissioning represents an inappropriate risk to fish & fish habitat given the rapid interim ramping rate proposed and the fish values present in the diversion reach. 4. Fish Abundance (Section 7) & Invertebrate Density (Section 8): no methodological guidelines for data collection or analysis are proposed, despite the bibliographic reference in Section 16 of the OEMP to Hatfield & Lewis (2007). The MOE-ESD information checklist provided in the
1
Babakaiff, Scott C ENV:EX Tuesday, December 1, 2009 4:49 PM Bennett, Timothy A ENV:EX XT:Busto, Vince DFO EAO:IN; Stoddard, Erin M ENV:EX; Barrett, Scott ENV:EX Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan image001.jpg
Page 105 FNR-2011-00265 Part 2
Provincial IPP Guidebook also provides supplemental guidance for OEMP development. It is my understanding that the baseline biological data collected in recent years did not follow any particular protocol, but was undertaken by several different biologists in different locations, using different methods. As such, it is imperative that all baseline data be collated and assessed by a professional biologist with experience in the relevant specialization (ie. fisheries biology, macroinvertebrate biology), and compiled for assessment regarding its adequacy as a baseline to assess future changes that may be attributable to operation of the IPP facility. On this note...
2. No baseline data or power analysis: the adequacy of the monitoring details proposed in the OEMP (e.g.
duration and frequency of sampling, expected natural variability, sample sizes, methods of analysis, a priori agreement on ecologically-acceptable thresholds of dependent variables, corrective/compensatory measures to be adopted upon threshold exceedance, monitoring program budgets, etc. ) cannot be objectively considered without preliminary analysis of baseline data, including statistical power analysis. In the absence of such analyses, particularly for the biological data described in Sections 6&7 of the OEMP, I have little confidence in the adequacy of pre-diversion baseline data described in the OEMP to assess any diversioninduced changes in these biological response variables.
3. Details of monitoring commitments tabulated in the Appendix of the OEMP do not seem congruent with text in the body of the OEMP. For instance, page 3 of the OEMP clearly states: In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. However, monitoring proposed for some components (e.g. biological components from Tables 3-5 of the OEMP) have been copied verbatim from the guidelines (which, incidentally, are not referenced correctly) and subsequent case study (Trout Creek), so it is unclear what aspects of the monitoring criteria will or will not be undertaken per the OEMP. 4. Pre-diversion activities which may require several months to complete have yet to have been initiated. For instance: 1. installation of the four pressure transducers (per Section 4.2.1 of the OEMP) and development of associated rating curves for water flow (Section 4) and instream flow (Section 11) monitoring; 2. Collection of stream channel morphology data (per Section 10 of the OEMP). This component of the OEMP is particularly ill-defined: there are no explicit guidelines or standards referenced, and I also question the proposed benefits of completing repeat surveys at a few transects to assess whether the IFR is affect any of the fish habitat as was originally predicted. Assessment of changes in channel morphology related to project operations (e.g. flow diversion, changes in sediment and LWD transport rates and volumes, etc.) is crucial, but should be considered more holistically using lowlevel air photos and longitudinal survey profiles. Again, it is recommended that an professional experienced with development of channel monitoring programs (ie. a fluvial geomorphologist or river engineer) be tasked with developing the study design and undertaking the work prior to final commissioning; I suggest that the examples Ive provided in my comments above (ie. the For Instances) do not represent the full suite of deficiencies in this OEMP; they were simply the most obvious shortfalls within my area of expertise. A more complete suite of review comments may be available through consultation with other ESD staff (ie. Erin Stoddard & Scott Barrett), WSD staff (e.g. Jim Davies) or our Federal counterparts (e.g. Vince Busto & Francesca Knight). Suffice to say that alot of work needs to be done on this OEMP before it will meet the standards established by recentlycommissioned projects. It is unfortunate that this proponent has delayed submission of the draft OEMP to mere weeks prior to their anticipated commissioning. Scott Scott Babakaiff, M.Sc. P.Geo. Regional Fish Hydrologist Ministry of Environment Lower Mainland Region 2nd Floor- 10470 152nd Street Surrey, BC, V3R 0Y3 604-930-7121

From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM
2
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To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management 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 any questions. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Page 107 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, October 26, 2009 6:13 PM Babakaiff, Scott C ENV:EX; Busto, Vince; Bennett, Timothy A ENV:EX RE: Recent issues (FW: Ashlu settling pond sediments) IMGP5286.jpg; image001.jpg
Hi guys, I went up to the site today, and did not fully appreciate until today just how much more water is scheduled for release. The release of the first 2,000,000L was necessary to accommodate drainage of the penstock, which is full. The release of the "first flush" from the penstock (the 2,000,000L) was completed this morning. Cascade Environmental has recommended that they keep with release of 120L/s over the tailrace spillway. The problem with this is twofold: 1. We don't have any water chemistry for this water; won't have that until tomorrow. Is the first flush of high arsenic loading over, or will the water still be picking up high concentrations of arsenic? S. 13, S. 22 that the CSR does not apply! I am not sure the appropriate.
On the upside, the TSS is lower than the initial flushing water... TSS on that water as 65 mg/L. Cascade measured turbidity as a field surrogate for TSS, and it's 13, which is indicative of a lower TSS, I would think. So, hopefully a lower metals loading... Chessy Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: October 26, 2009 1:33 PM To: Busto, Vince; Bennett, Timothy A ENV:EX Cc: Knight, Francesca Subject: RE: Recent issues (FW: Ashlu settling pond sediments)
Im not certain, but I dont think so.

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And still no OEMP.

| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature, concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature. In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria. In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
Page 109 FNR-2011-00265 Part 2
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2
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Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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Page 113 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Busto, Vince [Vince.Busto@dfo-mpo.gc.ca] Monday, October 26, 2009 1:08 PM Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Recent issues (FW: Ashlu settling pond sediments) image001.jpg; Ashlu settling pond.pdf
Gentlemen, my short list of recent significant issues related to Ashlu: 1) Left bank sluiceway trapping of fish in rock pools during dewatering 2) Settling pond contamination (see below) 3) High arsenic concentrations in the water impounded in the penstock Vince Busto, B.A.Sc., P.Eng. Habitat and Hydrotechnical Engineer Habitat and Enhancement Branch Lower Fraser River Fisheries and Oceans Canada 100 Annacis Parkway, Unit 3 Delta, BC V3M 6A2 Government of Canada
| | | | | | |
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________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser
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Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
3
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From: Sent: To: Cc: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Tuesday, October 27, 2009 2:18 PM Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX Busto, Vince RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
Hi guys, Vince and I have issued a direction to the proponent to cease discharging any more water from the tailrace. Without water chemistry data, I don't think it's prudent to continue with the release. I also placed a call to Stephanie Warriner; I imagine you might be speaking with her group, but I wanted to give her the heads up. The way we wrote the direction, the proponent cannot resume discharge until the WQ meets BC and CCME WQGs (at point of discharge) and other agencies having jurisdiction (province and Environment Canada) have consented to the release. regards, Chessy Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: October 27, 2009 12:18 PM To: Busto, Vince; Babakaiff, Scott C ENV:EX Cc: Knight, Francesca; Steeves, George; Mike Nelson Subject: RE: Recent issues (FW: Ashlu settling pond sediments)
HiAll, AshludoesNOThavealeavetocommenceoperation;anditwouldbeanoffenceforthemtodivertandusewater forpowergenerationwithoutthatleave. Priortoissuingthatleave,IwouldrequiresubmissionoftheOEMPandotherwantotherlooseendstiedupfrom myperspective,Ihaventhadthetimetocheckwhatthoseotherlooseendsareyet;andImnotawarethatAshlu hasaskedforthatleave. Regards,

Page 118 FNR-2011-00265 Part 2
And still no OEMP.

| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature, concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature.
Page 119 FNR-2011-00265 Part 2
In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria. In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, October 15, 2009 10:32 AM
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To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments Hi Robert, you are correct, Cascade does not need to take another sample, and you will receive copies of the results. regards, Francesca
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, October 14, 2009 5:10 PM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: Ashlu settling pond sediments Hello Robert,
Page 121 FNR-2011-00265 Part 2
I went on site to the old settling pond this afternoon (that was used for disposal of tunnel drilling material), which is being recontoured and vegetated for habitat. Sam had some concerns about the odour and appearance of the material, so I obtained sample containers and went to the work area. My observations of the sediments are: 1. hydrogen sulphide odour, possibly due to exposure of aqueous sediments to oxygen if the pond had been drained 2. hydrocarbon odour and slight sheen, as well as black patches within the drier material, possibly indicating oil staining Without sediment chemistry data, I am not comfortable using this material as aquatic habitat substrate and/or wetland bench substrate. I spoke with Mike Nelson this afternoon, and he confirmed that sediments have recently been tested for metals, so I will only request a sulphide and hydrocarbon analysis on these samples (pending my review of recent analytical results, which Mike just sent to me). Also, he is sending me bioassay results... that will be very useful if a recent pond sample was tested. I will drop the samples off tomorrow morning, and let you and Mike know the results. regards, Francesca
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From: Sent: To: Cc: Subject: Attachments: Robert Kulka DFO has reviewed the Leave to Construct - Generating Equipment Commissioning, dated October 20th, 2009, and written by George Steeves, P.Eng.. DFO notes that the the leave to construct is conditional upon four conditions, the third being, "Confirmation of the results of the water quality testing of the tunnel/penstock flushing water." As you know the testing showed high levels of arsenic, and DFO has responded by issuing a Direction pursuant to section 38(6) of the Fisheries Act, which requires Innergex to "cease and desist" discharging water containing deleterious substances or water of unknown quality into fish habitat. The section 38(6) was issued today. I would be surprised to learn that George Steeves, P.Eng., supported the release of a deleterious substance in to fish habitat. In my opinion, I believe you may have misinterpreted the intent of the third condition in the "Leave to Construct", dated October 20th, 2009. Busto, Vince [Vince.Busto@dfo-mpo.gc.ca] Tuesday, October 27, 2009 2:06 PM Robert Kulka; Mike Nelson; Knight, Francesca; Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
| | | | | | |
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 27, 2009 1:20 PM To: Mike Nelson; Knight, Francesca; Busto, Vince; Scott.Babakaiff@gov.bc.ca; Bennett, Timothy A ENV:EX Cc: Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com Subject: RE: Recent issues (FW: Ashlu settling pond sediments) Importance: High Ashlu Creek Investments Limited Partnership (ACILP) provides the following clarification with regards to our current activities: Independent Engineer George Steeves issues the Leave to Construct - Generating Equipment Commissioning on October 20th and we commenced commissioning on October 24. I just talked to George on the phone and he confirmed that the LTC allows diversion of water for the purpose of commissioning the generating equipment and George left a message with Tim Bennett to that effect. This LTC is limited for a duration of 30 days. In order to commence operation, an LTC for operation is required. We are in the process of applying for this LTC and supporting documents have been sent to George for review (those include the Operation Environmental Management Plan and the Operating Parameters and Procedures). We are working closely with George to ensure that the LTC is in place prior to commencement of operation and ACILP would under not circumstances commence operation without the LTC issued.
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I trust this provides the necessary clarification to understand that ACILP is acting diligently and in close communication and cooperation with the Independent Engineer as well as the Environmental Monitor. Please contact me if you require any additional information or clarification. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Tuesday, October 27, 2009 12:19 PM To: Francois Hebert; Robert Kulka Subject: FW: Recent issues (FW: Ashlu settling pond sediments)
FYI
MIKE NELSON | R.P. BIO. | PRINCIPAL Cascade Environmental Resource Group Ltd. Unit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 MOB: 604 815-9973 | TEL: 604 815-0901 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: October-27-09 12:18 PM To: Busto, Vince; Babakaiff, Scott C ENV:EX Cc: Knight, Francesca; Steeves, George; Mike Nelson Subject: RE: Recent issues (FW: Ashlu settling pond sediments)

From: Busto, Vince [mailto:Vince.Busto@dfo-mpo.gc.ca] Sent: Monday, October 26, 2009 1:31 PM
2
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To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: Knight, Francesca Subject: RE: Recent issues (FW: Ashlu settling pond sediments) Do they have a leave to commence power generation?
And still no OEMP.

| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature, concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature. In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you
3
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an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria. In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, October 15, 2009 10:32 AM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments
4
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Hi Robert, you are correct, Cascade does not need to take another sample, and you will receive copies of the results. regards, Francesca
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, October 14, 2009 5:10 PM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: Ashlu settling pond sediments Hello Robert, I went on site to the old settling pond this afternoon (that was used for disposal of tunnel drilling material), which is being recontoured and vegetated for habitat. Sam had some concerns about the odour and appearance of the material, so I obtained sample containers and went to the work area. My observations of the sediments are: 1. hydrogen sulphide odour, possibly due to exposure of aqueous sediments to oxygen if the pond had been drained
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2. hydrocarbon odour and slight sheen, as well as black patches within the drier material, possibly indicating oil staining Without sediment chemistry data, I am not comfortable using this material as aquatic habitat substrate and/or wetland bench substrate. I spoke with Mike Nelson this afternoon, and he confirmed that sediments have recently been tested for metals, so I will only request a sulphide and hydrocarbon analysis on these samples (pending my review of recent analytical results, which Mike just sent to me). Also, he is sending me bioassay results... that will be very useful if a recent pond sample was tested. I will drop the samples off tomorrow morning, and let you and Mike know the results. regards, Francesca
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From: Sent: To: Cc: Subject: Attachments: Importance: Robert Kulka [RKulka@innergex.com] Tuesday, October 27, 2009 1:20 PM Mike Nelson; Knight, Francesca; Busto, Vince; Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg High
Ashlu Creek Investments Limited Partnership (ACILP) provides the following clarification with regards to our current activities: Independent Engineer George Steeves issues the Leave to Construct - Generating Equipment Commissioning on October 20th and we commenced commissioning on October 24. I just talked to George on the phone and he confirmed that the LTC allows diversion of water for the purpose of commissioning the generating equipment and George left a message with Tim Bennett to that effect. This LTC is limited for a duration of 30 days. In order to commence operation, an LTC for operation is required. We are in the process of applying for this LTC and supporting documents have been sent to George for review (those include the Operation Environmental Management Plan and the Operating Parameters and Procedures). We are working closely with George to ensure that the LTC is in place prior to commencement of operation and ACILP would under not circumstances commence operation without the LTC issued. I trust this provides the necessary clarification to understand that ACILP is acting diligently and in close communication and cooperation with the Independent Engineer as well as the Environmental Monitor. Please contact me if you require any additional information or clarification. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
FYI
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: October-27-09 12:18 PM To: Busto, Vince; Babakaiff, Scott C ENV:EX
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Cc: Knight, Francesca; Steeves, George; Mike Nelson Subject: RE: Recent issues (FW: Ashlu settling pond sediments)

And still no OEMP.

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From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 23, 2009 12:10 PM To: Knight, Francesca Subject: RE: Ashlu settling pond sediments
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Hello Francesca, As per my voicemail from earlier today: I saw Matt and Sam on site this morning and they are basically finished with what can be done at this time without the test results of your samples and your recommendations what to do with the material. They would need your feedback in order to carry on with the work. I am on site all day today and I would be happy to relay your feedback to Matt and Sam so they can continue to work. You can reach my via email or at the powerhouse under 604.898.8287. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 14, 2009 5:44 PM To: Knight, Francesca Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: RE: Ashlu settling pond sediments Hello Francesca; I was at the work site yesterday afternoon and Sam showed me the areas of concern. As per your email, Cascade had taken a sample of the material in the past and I had sent them a note last night to inspect the area and take another sample if found necessary (see attached email). Since you have taken a sample today I understand there is no need for Cascade to take another sample at this time. I would appreciate if you could copy to me your future email to Mike with sample results for our information and records.
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Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Page 133 FNR-2011-00265 Part 2

From: Sent: To: Subject: Steeves, George [gsteeves@ameresco.com] Thursday, October 22, 2009 6:47 PM Robert Kulka Re: Ashlu - Generating Equipment Commissioning (File No. 2001264;Licence No. 102203)
You are good to go. George Sent wirelessly from my BlackBerry device on the Bell network. Envoy sans fil par mon terminal mobile BlackBerry sur le rseau de Bell. -----Original Message----From: Robert Kulka <RKulka@innergex.com> Date: Thu, 22 Oct 2009 21:07:21 To: Steeves, George<gsteeves@ameresco.com> Subject: RE: Ashlu - Generating Equipment Commissioning (File No. 2001264; Licence No. 102203) Hello George, Upon review of the conditions of the LTC I am uncertain what is in detail needed under the "Water Diversion Plan". My short version would be as follows: 1) The IFR flow will be provided at all times through the IFR bypass valve installed within the sluiceway. The valve's capacity at 100% opening is 3.0cms. The valve will be 100% open at the beginning of the commissioning process. If water levels and plant test performance allow to divert all but the IFR flows from the creek, the IFR valve will be calibrated based on the benchmark established by the EM during the March 11 head pond filling (the bench mark is a permanent marker attached to bedrock near the location of the IFR measuring pressure gage, approximately 250m downstream of the intake). The EM will be present during the calibration of the IFR flows. 2) Ramping rates as per the DFO Authorization have been programmed into the powerhouse control system. The adjustable valves of the Energy Dissipation System (EDS) will open and close proportionally in order to meet the ramping rates. Turbine flows will be ramped during normal start up and shut down and the ramping during a load rejection trip will be provided through the EDS system. The EM will be present during the ramping and measure actual water level changes in the creek as per the attached memo, dated October 15, 2009. Please advise if this wording meets the requirements of the diversion plan and if not, what other level and detail of information is required. A template of a plan might be helpful to understand this issue at hand. Your prompt response would be appreciated in order to accommodate our commissioning schedule. Therefore I allow myself to mark this message as important and request a read receipt to understand that you have received this email. Regards, Robert ________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing. Construction Manager Innergex nergie renouvelable - Innergex Renewable Energy Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2 Phone : 604 984.8600 * Fax : 604 984.8699 Cell.: 778 227.0434 -----Original Message----From: Steeves, George [mailto:gsteeves@ameresco.com] Sent: Wednesday, October 21, 2009 2:22 PM To: timothy.bennett@gov.bc.ca; Robert Kulka Subject: Ashlu - Generating Equipment Commissioning (File No. 2001264; Licence No. 102203)
Page 134 FNR-2011-00265 Part 2
Tim Please find attached the Leave to Construct for the generating equipment installation for Ashlu. I have attached a sampling of the documents submitted. George ************************************************************************************** NOTE: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are 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. **************************************************************************************
************************************************************************************** NOTE: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are 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. **************************************************************************************
Page 135 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Dear Vince Busto, We provide the following summary: 1) The LTC for commissioning allows diversion of water for the purpose of flushing and commissioning; 2) Penstock/tunnel was flushed on October 21. All water was contained in the tail race and no water was discharged into the creek; 3) The EM took water samples of the flushing water and tested in accordance with the third condition of the LTC. The results were provided to DFO by the EM; 4) DFO expressed concerns regarding As values, Al values and LEPH, HEPH, and ph value; 5) ACILP discussed with the EM how to manage those values and address DFOs concerns. Ph value was addressed by using a CO2 bubbler. LEPH, and HEPH by skimming the surface. Other values were managed by dilution with additional penstock water and controlled release of the tail race water into the creek. Release rates were gradually ramped up from 0.08cms, 0.12cms, 0.50cms, and 1.00cms. Each step was authorized by the EM; 6) The EM continuously measured turbidity, ph and other values. The EM took a second sample of tail race water on October 25 and we are currently awaiting the results of this sample (expected by the end of today). A third and fourth sample were taken on October 26 and October 27 respectively; 7) The EM advised ACILP this morning, October 27 at 11:30am, to cease water release until receipt of second sample result. ACILP closed all valves and effectively stopped discharge into the creek at 11:36am; 8) In the interim we are complying with the Inspectors Direction as delivered to myself around 2:00pm today. The results of the second sample will be forwarded to DFO upon receipt. ACILP believes that it has complied with all conditions of the LTC, including containing and testing of flushing water, waiting for test results, development of a plan with the EM upon receipt of test results, and then controlled release of water into the creek in accordance with the plan and ongoing sampling and measurements by the EM while doing so. We have requested from EM to produce a report outlining the rational behind the decisions made and records taken. We expect this report to be available by the end of today and it will be provided to you promptly. Please advise if you require any additional information or records in the interim or after receipt and review of the report. Regards, Robert Kulka Robert Kulka [RKulka@innergex.com] Tuesday, October 27, 2009 3:58 PM Busto, Vince; Mike Nelson; Knight, Francesca; Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Busto, Vince [mailto:Vince.Busto@dfo-mpo.gc.ca] Sent: Tuesday, October 27, 2009 2:06 PM To: Robert Kulka; Mike Nelson; Knight, Francesca; Scott.Babakaiff@gov.bc.ca; Bennett, Timothy A ENV:EX Cc: Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com Subject: RE: Recent issues (FW: Ashlu settling pond sediments) Robert Kulka
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DFO has reviewed the Leave to Construct - Generating Equipment Commissioning, dated October 20th, 2009, and written by George Steeves, P.Eng.. DFO notes that the the leave to construct is conditional upon four conditions, the third being, "Confirmation of the results of the water quality testing of the tunnel/penstock flushing water." As you know the testing showed high levels of arsenic, and DFO has responded by issuing a Direction pursuant to section 38(6) of the Fisheries Act, which requires Innergex to "cease and desist" discharging water containing deleterious substances or water of unknown quality into fish habitat. The section 38(6) was issued today. I would be surprised to learn that George Steeves, P.Eng., supported the release of a deleterious substance in to fish habitat. In my opinion, I believe you may have misinterpreted the intent of the third condition in the "Leave to Construct", dated October 20th, 2009.
| | | | | | |
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: October 27, 2009 1:20 PM To: Mike Nelson; Knight, Francesca; Busto, Vince; Scott.Babakaiff@gov.bc.ca; Bennett, Timothy A ENV:EX Cc: Francois Hebert; Richard Blanchet; Christine Becker; gsteeves@ameresco.com Subject: RE: Recent issues (FW: Ashlu settling pond sediments) Importance: High Ashlu Creek Investments Limited Partnership (ACILP) provides the following clarification with regards to our current activities: Independent Engineer George Steeves issues the Leave to Construct - Generating Equipment Commissioning on October 20th and we commenced commissioning on October 24. I just talked to George on the phone and he confirmed that the LTC allows diversion of water for the purpose of commissioning the generating equipment and George left a message with Tim Bennett to that effect. This LTC is limited for a duration of 30 days. In order to commence operation, an LTC for operation is required. We are in the process of applying for this LTC and supporting documents have been sent to George for review (those include the Operation Environmental Management Plan and the Operating Parameters and Procedures). We are working closely with George to ensure that the LTC is in place prior to commencement of operation and ACILP would under not circumstances commence operation without the LTC issued. I trust this provides the necessary clarification to understand that ACILP is acting diligently and in close communication and cooperation with the Independent Engineer as well as the Environmental Monitor. Please contact me if you require any additional information or clarification. Regards, Robert
________________________________________
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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
FYI
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: October-27-09 12:18 PM To: Busto, Vince; Babakaiff, Scott C ENV:EX Cc: Knight, Francesca; Steeves, George; Mike Nelson Subject: RE: Recent issues (FW: Ashlu settling pond sediments)

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And still no OEMP.

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Page 139 FNR-2011-00265 Part 2
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2
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Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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Page 142 FNR-2011-00265 Part 2

From: Sent: To: Subject: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, November 2, 2009 1:44 PM Babakaiff, Scott C ENV:EX RE: Ashlu issue
there are possibly some enforcement actions we can take specifically regarding Sunday's discharge, but I may be on thin ice to prevent them from discharging clean water. C
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: November 2, 2009 12:00 PM To: Knight, Francesca Subject: RE: Ashlu issue
Good questions, Francesca. As you may suspect, Ive got an opinion, but Tim Bennett is really the right person to provide advice going forward. In terms of their Sunday discharge, are there no retro-spective actions that could be initiated by DFO/WSD? Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Monday, November 2, 2009 11:57 AM To: Babakaiff, Scott C ENV:EX Subject: Ashlu issue
S16 Hi Scott, the proponent is wanting to discharge water from the penstock/tailrace that has been held since the Inspector's d. I have water chemistry from this new proposed discharge, which c things: S16 1 the worst of the material was discharged on Sunday 2 flushing water is fairly clean (no CSR or BC WQG exceedances). Not sure I can keep the from discharging clean water, with a requirement of course for continued regular sampling of the discharge. Do you think Water Stewardship would want to wait until we have an OEMP submitted, which coul address WQ monitoring for penstock flushing discharge, prior to allowing them to discharge more flushing water? S16 S16 and I a
Francesca Knight, M.Sc., R.P.Bio. Fisheries and Oceans Canada / Pches et Ocans Canada
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Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
Page 144 FNR-2011-00265 Part 2

From: Sent: To: Subject: Steeves, George [gsteeves@ameresco.com] Thursday, October 22, 2009 6:47 PM Robert Kulka Re: Ashlu - Generating Equipment Commissioning (File No. 2001264;Licence No. 102203)
You are good to go. George Sent wirelessly from my BlackBerry device on the Bell network. Envoy sans fil par mon terminal mobile BlackBerry sur le rseau de Bell. -----Original Message----From: Robert Kulka <RKulka@innergex.com> Date: Thu, 22 Oct 2009 21:07:21 To: Steeves, George<gsteeves@ameresco.com> Subject: RE: Ashlu - Generating Equipment Commissioning (File No. 2001264; Licence No. 102203) Hello George, Upon review of the conditions of the LTC I am uncertain what is in detail needed under the "Water Diversion Plan". My short version would be as follows: 1) The IFR flow will be provided at all times through the IFR bypass valve installed within the sluiceway. The valve's capacity at 100% opening is 3.0cms. The valve will be 100% open at the beginning of the commissioning process. If water levels and plant test performance allow to divert all but the IFR flows from the creek, the IFR valve will be calibrated based on the benchmark established by the EM during the March 11 head pond filling (the bench mark is a permanent marker attached to bedrock near the location of the IFR measuring pressure gage, approximately 250m downstream of the intake). The EM will be present during the calibration of the IFR flows. 2) Ramping rates as per the DFO Authorization have been programmed into the powerhouse control system. The adjustable valves of the Energy Dissipation System (EDS) will open and close proportionally in order to meet the ramping rates. Turbine flows will be ramped during normal start up and shut down and the ramping during a load rejection trip will be provided through the EDS system. The EM will be present during the ramping and measure actual water level changes in the creek as per the attached memo, dated October 15, 2009. Please advise if this wording meets the requirements of the diversion plan and if not, what other level and detail of information is required. A template of a plan might be helpful to understand this issue at hand. Your prompt response would be appreciated in order to accommodate our commissioning schedule. Therefore I allow myself to mark this message as important and request a read receipt to understand that you have received this email. Regards, Robert ________________________________________ ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing. Construction Manager Innergex nergie renouvelable - Innergex Renewable Energy Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2 Phone : 604 984.8600 * Fax : 604 984.8699 Cell.: 778 227.0434 -----Original Message----From: Steeves, George [mailto:gsteeves@ameresco.com] Sent: Wednesday, October 21, 2009 2:22 PM To: timothy.bennett@gov.bc.ca; Robert Kulka Subject: Ashlu - Generating Equipment Commissioning (File No. 2001264; Licence No. 102203)
Page 145 FNR-2011-00265 Part 2
Tim Please find attached the Leave to Construct for the generating equipment installation for Ashlu. I have attached a sampling of the documents submitted. George ************************************************************************************** NOTE: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are 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. **************************************************************************************
************************************************************************************** NOTE: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are 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. **************************************************************************************
Page 146 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Saturday, October 24, 2009 6:59 PM Robert Kulka Clark, John; Busto, Vince; Babakaiff, Scott C ENV:EX; Mike Nelson; Bennett, Timothy A ENV:EX release of penstock discharge image001.jpg
Hello Robert, It is my understanding from speaking with Mike Nelson that you plan to discharge the penstock drainage tomorrow morning. This water is presently contained within the tailrace, and I believe the volume is estimated at 2,000 m3 (2,000,000 L). I have expressed my concerns regarding the proposed discharge to the Ashlu River, given that the arsenic concentration (140 ppb) exceeds the Contaminated Sites Regulation for arsenic (50 ppb). While the CSR typically does not apply on this site, I suppose that's not to say that it can't. The decision to proceed with the discharge on such short notice precludes me from any communication with my collleagues in the provincial government (Water Stewardship Division, or Contaminated Sites). I would suspect that given the arsenic concentration in the water, the province would like to be informed and provide some direction as to whether the water can be discharged at a given diluation ratio, or whether the solids should be captured and disposed of on land. Also, I would refer the proposal to Environment Canada. DFO does not support this release of the penstock drainage water, and if you decide to proceed tomorrow morning (or at any other time without due process), understand that this is at your own risk. Based on my evaluation of the WQ results, I think the most responsible solution is to allow the solids to settle out, then vacuum them from the tailrace. The TSS concentration is fairly high (65 mg/L); I suspect that the arsenic concentration is correlated with TSS. The dissolved arsenic fraction is 43 ppb; above the provincial ambient WQ criteria, but below the CSR. Removal of the solids will likely reduce the arsenic concentration. If you need to reach me, you can email or call me on my cell phone at Francesca
S22
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From: Sent: To: Cc: Subject: Attachments: Busto, Vince [Vince.Busto@dfo-mpo.gc.ca] Monday, October 26, 2009 1:31 PM Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Knight, Francesca RE: Recent issues (FW: Ashlu settling pond sediments) image001.jpg
Do they have a leave to commence power generation?
And still no OEMP.

| | | | | | |
From: Knight, Francesca Sent: October 23, 2009 6:08 PM To: 'Robert Kulka' Cc: Gidora, Sam; Steve Rochetta (Steve.Rochetta@gov.bc.ca); Foy, Matthew; 'Mike Nelson'; Busto, Vince Subject: RE: Ashlu settling pond sediments Hi Robert, I got the sediment sample results back today (please see attached).I took two samples, and got "hits" on both; sulphide concentrations are high in both samples at 30 and 53 ppm. There is no regulatory criteria for this compound, but toxicity is observed at 2-5 ppm, give or take, so I believe the concentrations are too high to safely proceed with use of the material now. In addition, one sample has elevated HEPH (heavy extractable petroleum hydrocarbons) at 540 ppm. There is a contaminated site regulation criteria for this suite of compounds; it's 1000 ppm. Keep in mind though, that the CSR is not in effect on this site; the CSR is only used to regulate contaminated sites, and the criteria in the regulation are typically quite a bit higher than concentrations that are believed to be acceptable in the ambient environment (in other words, indicative of a healthy environment, rather than defining a contaminated environment). There is no ambient environmental criteria for HEPH, but in looking at the toxicity literature,
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concentrations < 1000 ppm are known to cause adverse effects in aquatic biota. I think the concentration of 540 ppm is sufficient to warrant concern if we were to begin using the pond as a habitat feature. In addition, there is one PAH (polcyclic aromatic hydrocarbon) that just meets the provincial ambient water quality guidelines (the guidelines also contain some sediment quality standards). The compound is naphthalene, and the criteria is 0.01 ppm. This is the concentration that the province deems protective of the environment. To give you an idea of how much higher the CSR standards are, naphthalene CSR criteria is 0.47 ppm...but like I said, the CSR does not apply on this site. The site's aim should be to meet safe ambient environmental concentrations, rather than contaminated site regulation criteria. In summary, I don't it would be wise to incorporate the pond sediments into any habitat feature/function at this time. I think the best thing to do with the pond is to leave it for a year, aerate the soil and let it dry out over the summer, and re-test at the end of the summer. The sulphides problem should be gone, and the hydrocarbon issue may be as well, but we should re-test for the hydrocarbons. Let me know if this solution works, and if anyone else has recommendations, please feel free to communicate those to the group. regards, Chessy
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

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________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, October 14, 2009 5:10 PM To: Robert Kulka Cc: Mike Nelson; Busto, Vince; Foy, Matthew; Gidora, Sam Subject: Ashlu settling pond sediments
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Hello Robert, I went on site to the old settling pond this afternoon (that was used for disposal of tunnel drilling material), which is being recontoured and vegetated for habitat. Sam had some concerns about the odour and appearance of the material, so I obtained sample containers and went to the work area. My observations of the sediments are: 1. hydrogen sulphide odour, possibly due to exposure of aqueous sediments to oxygen if the pond had been drained 2. hydrocarbon odour and slight sheen, as well as black patches within the drier material, possibly indicating oil staining Without sediment chemistry data, I am not comfortable using this material as aquatic habitat substrate and/or wetland bench substrate. I spoke with Mike Nelson this afternoon, and he confirmed that sediments have recently been tested for metals, so I will only request a sulphide and hydrocarbon analysis on these samples (pending my review of recent analytical results, which Mike just sent to me). Also, he is sending me bioassay results... that will be very useful if a recent pond sample was tested. I will drop the samples off tomorrow morning, and let you and Mike know the results. regards, Francesca
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From: Sent: To: Cc: Subject: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Monday, October 26, 2009 6:41 PM Robert Kulka Busto, Vince; Babakaiff, Scott C ENV:EX; Mike Nelson; Bennett, Timothy A ENV:EX RE: release of penstock discharge
Hello everyone, one more note on the use of dilution of the discharge. While it is established that the Contaminated Sites Regulation does not apply at this site, we have used the CSR to give us an indication of whether the arsenic concentration should be a matter of concern. Given that the measured concentration did exceed the CSR aquatic life standard, I think we can all be in agreement that this concentration is a concern. The decision was made to release the water, with the rationale that dilution would be sufficient to render the water of little to no risk to aquatic life. I think it's really important to get feedback from the Environmental Management Branch on the acceptability of this method. My understanding around the use of dilution is that the BC ambient WQ guideline (5 ppb) has to be met at the point where the discharge reaches waters that support aquatic life. The Ashlu undoubtedly supports aquatic life just below the tailrace spillway. However, the proposed dilution will likely still not reach the 5 ppb guideline just below the spillway; in other words, there is likely a need to discuss the point of compliance. Chessy
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From: Sent: To: Cc: Subject: Attachments: Robert, Just a short note to acknowledge receipt of the Ashlu OEMP (Revision B) and to inform you that I've completed my review of it, and have emailed my review to reps from the primary decision-making agencies (ie. DFO & MOE-WSD). Scott Babakaiff, Scott C ENV:EX Wednesday, December 2, 2009 10:35 AM Robert Kulka; Bennett, Timothy A ENV:EX XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Stoddard, Erin M ENV:EX RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan image001.jpg
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Fri 27/11/2009 3:03 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management 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 any questions. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Thursday, December 10, 2009 3:13 PM Willcox, Michael ENV:EX; Stoddard, Erin M ENV:EX; Bennett, Timothy A ENV:EX XT:Busto, Vince DFO EAO:IN RE: 2001264 - Ashlu - 091116 BB-Ashlu EM to 15 Nov 09....
Gents, The Nov.15-22 2009 IEM report documents repeated incidents of fish stranding during the commissioning/testing of the Ashlu IPP during the week of Nov 15-22 2009. It seems that some stranding was related to non-provision of the IFR. I dont know if WSD or DFO were previously informed of these events by the IEM, but the report was just (two days ago) posted by Mike Willcox, and it seems a little late for any onsite investigation. There seem to have been several incidents in recent weeks at the Ashlu IPP, and Im wondering if there has been any formal warning given to the proponent/construction company. Are we yet at a point in the compliance matrix that would justify involvement of the COS or FOs? Scott
From: Willcox, Michael ENV:EX Sent: Tuesday, December 8, 2009 11:16 AM To: Babakaiff, Scott C ENV:EX; Barrett, Scott ENV:EX; Stoddard, Erin M ENV:EX; Bennett, Timothy A ENV:EX Subject: FW: 2001264 - Ashlu - 091116 BB-Ashlu EM to 15 Nov 09.... SharePoint Document Library: 2001264 - Ashlu http://sharepoint.env.gov.bc.ca/ipp/2001264%20%20Ashlu
The subject report documents a low instream flow incident.

_____________________________________________ From: Lower Mainland Region IPP Sharepoint Site [mailto:Dave.Donovan@gov.bc.ca] Sent: Tuesday, December 8, 2009 10:06 AM To: Willcox, Michael ENV:EX Subject: 2001264 - Ashlu - 091116 BB-Ashlu EM to 15 Nov 09.... SharePoint Document Library: 2001264 - Ashlu http://sharepoint.env.gov.bc.ca/ipp/2001264%20%20Ashlu
Lower Mainland Region IPP Sharepoint Site
091116 BB-Ashlu EM to 15 Nov 09.... has been added

Modify my alert settings | View 091116 BB-Ashlu EM to 15 Nov 09.... | View 2001264 - Ashlu | Mobile View
Last Modified 12/8/2009 10:03 AM by Mike Nelson
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From: Sent: To: Cc: Subject: Attachments: Barrett, Scott ENV:EX Thursday, December 17, 2009 4:43 PM Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX; Babakaiff, Scott C ENV:EX RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan image001.jpg
HiTim, IhaventreviewedtheOEMPhoweverIhavereviewedScottscomments.ItseemsthatScotthaswellreviewedthe issuesthatIwouldfocusonintermsofstudydesignfortheinvertebratemonitoring.Ireallydontthinkitis necessaryformetoreiteratetheconcernsthathehasprovided. Ifyouand/orScottrequireanyspecificclarifications,Illbehappytoprovidethem. Scott

From: Bennett, Timothy A ENV:EX Sent: Friday, December 11, 2009 2:58 PM To: Barrett, Scott ENV:EX; Stoddard, Erin M ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan
HiScottandErin, FurthertoScottscommentsbelow,canyoupleaseletmeknowifyouintendtoreviewandprovidecommentson theOEMPforAshlu? Ifyoudo,pleaseconfirmwhenyoucouldprovideyourcomments. Thanks!

From: Babakaiff, Scott C ENV:EX Sent: Tuesday, December 1, 2009 4:49 PM To: Bennett, Timothy A ENV:EX Cc: XT:Busto, Vince DFO EAO:IN; Stoddard, Erin M ENV:EX; Barrett, Scott ENV:EX Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Gents, Ive reviewed Revision B of the Operations Environmental Management Plan for the Ashlu Creek project (dated November 2009) as submitted by Innergex. The document is hereafter referenced simply as the OEMP since there is no authorship or bibliographic detail included. The absence of any explicit authorship is notable: there is little evidence that the OEMP has been composed by a licensed professional (e.g. RP Bio) with experience in the development or implementation of a monitoring program
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intending to fulfill agency needs. In short, the OEMP is typical for a preliminary draft, but it is troubling that completion of project construction & commissioning is imminent. Regardless, I have several primary concerns with the OEMP: 1. Few commitments to follow commonly-accepted guidelines for data collection & analysis, despite a proposal that monitoring details meet the requirements of DFO and MOE (p. 6 of the OEMP). I suggest many details proposed in the OEMP are seemingly arbitrary and do not reference any guidelines or standards typically referenced by Provincial or Federal agencies. For instance: 1. Stage-discharge rating curves- the OEMP commits to collecting a minimum of three discharge measurements and warns that ...it is unlikely that flows will be able to be measured above 20% of mean annual discharge. There are clear and well-established guidelines for developing stagedischarge rating curves (e.g. LWBC Hydrometric Guidelines; B.C. Provincial Hydrometric Standards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric% 20Standards%20V1.0,%20March%2012,%202009.pdf) that the proponent is recommended to meet. 2. Reporting of stream flow data: the OEMP commits to collect to collect flow data on a continuous basis, typically in 15-minute intervals and promises that data will be recorded...and can be provided to onsite DFO and/or MOE staff...for compliance purposes...flow data will be reported quarterly. I suggest there is no need to submit data to review agencies more frequently than once per year, but agencies must be informed within 24 hours of any non-compliance (e.g. IFR provision, ramping rates), and the proponent must resolve the issue of non-compliance immediately. In terms of data collection&logging, I note that the BC Provincial Hydrometric Standards (Section 3.2.2.3) recommends a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, particularly those with the diversity of fish values in the Ashlu diversion reach, I would recommend a much shorter stage sampling frequency (say, 10-second), with a 2-minute average for storage in the data logger (and submission to agencies). I would also recommend that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment damage) do not result in lengthy data gaps. For purposes of graphical presentation in monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data. 3. Development of ramping rates: Section 12.2 of the OEMP proposes that the ramping rates shall not exceed 29.0 cms per 90 minutes. This rate will be established during the commissioning process of the plant, and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991.... The OEMP provides some detail regarding proposed methods for establishing ramping rates during commissioning, but I would suggest that such protocol (and such interim rates like 29 cms per 90 minutes) should be established and scientifically-justified by an experienced professional, with reference to established agency criteria (e.g. DFOs default hourly ramping rates of 2.5 cm & 5.0 cm for fry & juveniles) or recommended guidelines. Finally, I suggest that the commitment within Section 14 of the OEMP to submit the ramping rate report six months after commissioning represents an inappropriate risk to fish & fish habitat given the rapid interim ramping rate proposed and the fish values present in the diversion reach. 4. Fish Abundance (Section 7) & Invertebrate Density (Section 8): no methodological guidelines for data collection or analysis are proposed, despite the bibliographic reference in Section 16 of the OEMP to Hatfield & Lewis (2007). The MOE-ESD information checklist provided in the Provincial IPP Guidebook also provides supplemental guidance for OEMP development. It is my understanding that the baseline biological data collected in recent years did not follow any particular protocol, but was undertaken by several different biologists in different locations, using different methods. As such, it is imperative that all baseline data be collated and assessed by a professional biologist with experience in the relevant specialization (ie. fisheries biology, macroinvertebrate biology), and compiled for assessment regarding its adequacy as a baseline to assess future changes that may be attributable to operation of the IPP facility. On this note... duration and frequency of sampling, expected natural variability, sample sizes, methods of analysis, a priori agreement on ecologically-acceptable thresholds of dependent variables, corrective/compensatory measures to be adopted upon threshold exceedance, monitoring program budgets, etc. ) cannot be objectively considered without preliminary analysis of baseline data, including statistical power analysis. In the absence of such analyses, particularly for the biological data described in Sections 6&7 of the OEMP, I have little confidence in the adequacy of pre-diversion baseline data described in the OEMP to assess any diversioninduced changes in these biological response variables.
2. No baseline data or power analysis: the adequacy of the monitoring details proposed in the OEMP (e.g.
3. Details of monitoring commitments tabulated in the Appendix of the OEMP do not seem congruent with text in the body of the OEMP. For instance, page 3 of the OEMP clearly states: In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and
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were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. However, monitoring proposed for some components (e.g. biological components from Tables 3-5 of the OEMP) have been copied verbatim from the guidelines (which, incidentally, are not referenced correctly) and subsequent case study (Trout Creek), so it is unclear what aspects of the monitoring criteria will or will not be undertaken per the OEMP. 4. Pre-diversion activities which may require several months to complete have yet to have been initiated. For instance: 1. installation of the four pressure transducers (per Section 4.2.1 of the OEMP) and development of associated rating curves for water flow (Section 4) and instream flow (Section 11) monitoring; 2. Collection of stream channel morphology data (per Section 10 of the OEMP). This component of the OEMP is particularly ill-defined: there are no explicit guidelines or standards referenced, and I also question the proposed benefits of completing repeat surveys at a few transects to assess whether the IFR is affect any of the fish habitat as was originally predicted. Assessment of changes in channel morphology related to project operations (e.g. flow diversion, changes in sediment and LWD transport rates and volumes, etc.) is crucial, but should be considered more holistically using lowlevel air photos and longitudinal survey profiles. Again, it is recommended that an professional experienced with development of channel monitoring programs (ie. a fluvial geomorphologist or river engineer) be tasked with developing the study design and undertaking the work prior to final commissioning; I suggest that the examples Ive provided in my comments above (ie. the For Instances) do not represent the full suite of deficiencies in this OEMP; they were simply the most obvious shortfalls within my area of expertise. A more complete suite of review comments may be available through consultation with other ESD staff (ie. Erin Stoddard & Scott Barrett), WSD staff (e.g. Jim Davies) or our Federal counterparts (e.g. Vince Busto & Francesca Knight). Suffice to say that alot of work needs to be done on this OEMP before it will meet the standards established by recentlycommissioned projects. It is unfortunate that this proponent has delayed submission of the draft OEMP to mere weeks prior to their anticipated commissioning. Scott Scott Babakaiff, M.Sc. P.Geo. Regional Fish Hydrologist Ministry of Environment Lower Mainland Region 2nd Floor- 10470 152nd Street Surrey, BC, V3R 0Y3 604-930-7121

From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management 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 any questions. Regards, Robert
________________________________________
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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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Ashlu Creek Hydroelectric Power Project Operations Environmental Management Plan
Revision B
November 2009
Ashlu Creek Investments Limited Partnership 303-38 Fell Avenue North Vancouver, BC V7P 3S2
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Ashlu Creek Hydroelectric Power Project Operational Environmental Management Plan
Revision B November 26, 2009
Abstract
In July 2006, the Ministry of Environment (MOE) issued Ashlu Creek Investments Limited Partnership Conditional Water License #102203 on Ashlu Creek near Squamish B.C. Conditions of the water license included a maximum diverted flow of 29.0 m3/s and the completion of an Operational Environmental Monitoring Plan (OEMP) to evaluate the effect of the regulation of works. In July 2006, the Department of Fisheries and Oceans (DFO) issued authorization #04-HPCAPA2-000-000530. Conditions of this authorization include a year round Instream Flow Requirement (IFR) of 2.42 m3/s. A draft (Revision A) of the Five Year, Post-Construction Aquatic Monitoring Program Revision A was submitted to DFO in May 2009. A follow-up letter was sent to DFO in October 2009 with description of the specific plan to confirm ramping rates. As of November 27, 2009, comments have not been received from DFO. In addition, Approval #8200-T-10595.2 issued by Transport Canadas Navigable Waters Protection Division (NWPD) requires the IFR to range between 16 m3/s and 32 m3/s during twelve (12) weekends between May and September. The OEMP outlines the biotic and physical monitoring parameters to be monitored during both pre and post construction of the Ashlu Creek Hydroelectric Project. The purpose of the OEMP is to provide early warning of impending change in key variables and provide an opportunity to mitigate any change through alterations of operating procedures. The goal of the OEMP is to ensure resource values potentially affected by power production are not adversely compromised over the life of the facility.
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Table of Contents Abstract........................................................................................................................... i Table of Contents ...........................................................................................................ii List of Figures ...............................................................................................................iv List of Tables .................................................................................................................iv 1.0 2.0 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 Introduction......................................................................................................... 1 Study Area........................................................................................................... 1 Monitoring Components .................................................................................... 2 Headpond ............................................................................................................. 3 Intake/Weir ........................................................................................................... 3 Mile 25 Bridge....................................................................................................... 4 Gravel Bar in Ashlu Canyon ................................................................................. 4 Gustafson (Bend) Creek ....................................................................................... 4 Powerhouse/Tailrace/Switchyard ......................................................................... 4 Double Bridges ..................................................................................................... 4 Fish Compensatory Habitat .................................................................................. 4 Transmission Line ................................................................................................ 6
4.0 Water Flow .......................................................................................................... 6 4.1 Monitoring Locations ............................................................................................ 6 4.2 Monitoring Approach and Analysis ....................................................................... 6 4.2.1 Electronic Pressure Transducers............................................................... 6 4.2.2 Visual Staff Gauges ................................................................................... 7 4.3 Reporting .............................................................................................................. 7 5.0 5.1 5.2 5.3 6.0 6.1 6.2 6.3 7.0 7.1 7.2 7.3 8.0 8.1 8.2 8.3 Water Quality ...................................................................................................... 7 Monitoring Locations ............................................................................................ 8 Monitoring Approach and Analysis ....................................................................... 8 Reporting .............................................................................................................. 8 Water Temperature............................................................................................. 9 Monitoring Locations ............................................................................................ 9 Monitoring Approach and Analysis ....................................................................... 9 Reporting .............................................................................................................. 9 Fish Abundance and Biomass Density (Fish Community)........................ 10 Monitoring Locations .......................................................................................... 10 Monitoring Approach and Analysis ..................................................................... 10 Reporting ............................................................................................................ 11 Invertebrate Abundance and Biomass Density ............................................. 12 Monitoring Locations .......................................................................................... 12 Monitoring Approach and Analysis ..................................................................... 12 Reporting ............................................................................................................ 13
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9.0 Compensatory Fish Habitat Efficacy .............................................................. 13 9.1 Monitoring Locations .......................................................................................... 13 9.2 Monitoring Approach and Analysis ..................................................................... 13 9.2.1 Fish Ladder.............................................................................................. 13 9.2.2 Rearing Fish Compensation .................................................................... 13 9.3 Reporting ............................................................................................................ 14 10.0 Stream Channel Morphology........................................................................... 14 10.1 Monitoring Locations .......................................................................................... 15 10.2 Monitoring Approach and Analysis ..................................................................... 15 10.3 Reporting ............................................................................................................ 15 11.0 Instream Flow Requirement............................................................................. 15 11.1 Monitoring Locations .......................................................................................... 15 11.2 Monitoring Approach and Analysis ..................................................................... 16 11.2.1 Requirements under DFO........................................................................ 16 11.2.2 Requirements under TC / NWPD............................................................. 16 11.3 Reporting ............................................................................................................ 17 12.0 Ramping ............................................................................................................ 17 12.1 Monitoring Locations .......................................................................................... 17 12.2 Monitoring Approach and Analysis ..................................................................... 17 12.3 Reporting ............................................................................................................ 18 13.0 Footprint Impact Verification........................................................................... 19 13.1 Monitoring Locations .......................................................................................... 19 13.2 Monitoring Approach and Analysis ..................................................................... 19 13.3 Reporting ............................................................................................................ 19 14.0 15.0 Reporting........................................................................................................... 19 Exclusions......................................................................................................... 20
16.0 References ........................................................................................................ 20 16.1 General References ........................................................................................... 20 16.2 Project-Specific References ............................................................................... 20
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List of Figures
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations ........... 5
List of Tables
Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9 Table 10 Water Flow ............................................................................................................... 23 Water Quality............................................................................................................ 23 Water Temperature .................................................................................................. 24 Fish Abundance and Biomass Density..................................................................... 24 Invertebrate Abundance and Biomass Density ........................................................ 25 Compensation Fish Habitat Efficacy......................................................................... 25 Stream Channel Morphology.................................................................................... 26 Instream Flow Requirement ..................................................................................... 26 Flow Ramping .......................................................................................................... 27 Footprint Impact Verification..................................................................................... 27
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1.0
Introduction
The post-construction and operational impacts of the Ashlu Creek Hydroelectric Power Project (the Project) on the aquatic environment of Ashlu Creek will be monitored to ensure compliance with the environmental standards and agreements made with MOE and DFO during the permitting process for the Project. This Five Year, Post-Construction Monitoring Program (the Program) proposes the technical methods that will be used for data collection and presentation to DFO under the Projects Fisheries Authorization (04-HPAC-PA2-000-000530) dated July 31, 2006. The post-construction monitoring period, as described in the Fisheries Authorization, is five (5) years from the date of commercial operation of the Project, which is the date when construction is substantially completed and the Project begins to generate electricity for sale to BC Hydro, which based on an expected Commercial Operation Date (COD) of December 2009, is anticipated to be the period from January 2010 to December 2014.
2.0
Study Area
Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a south-easterly direction to its confluence with the Squamish River, approximately 20 km north of the Town of Squamish, B.C. It is a fifth order stream with a length of approximately 34 km and a drainage area of 324 km2. The catchment area of Ashlu Creek at the proposed intake location is 295 km2. The mean annual flow in Ashlu Creek at the intake site is estimated to be 27.1 m3/s (per Knight Pisolds February 2004 report). Ashlu Creek has been gauged intermittently since 1991 and consequently longer term flow records were synthesized from data obtained from a nearby Water Survey of Canada gauging station on the Elaho River. The lowest mean monthly discharges of 3 m3/s to 5 m3/s occur in winter (December to March), while the highest mean monthly discharges of 60 m3/s to 65 m3/s occur in the summer (June and July). The Ashlu Creek Aquatic Environmental Assessment Report (September 2002) and the Aquatic Environmental Addendum (April 2004) by Sigma Engineering described the fish and fish habitat in detail. It is summarized following in the context of the six distinct reaches of the creek. Reach 1 begins at Ashlu Creeks confluence with the Squamish River and extends up 2.8 km upstream to the upstream end of the double bridge island. This reach has a low gradient, highly productive side channels, and comprises primarily riffle habitat. Chinook, coho, chum, pink, and sockeye salmon, winter run steelhead, coastal cutthroat and rainbow trout, and Dolly Varden char were found in this reach. Reach 2 is the cascade section of the creek, with gradients ranging from 4 to 8%, several small falls, and riffle-chute habitat. It extends 2.7 km from the top end of the double bridge island up
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to the natural island in the middle of the Ashlu Canyon. This reach provides little to no spawning or rearing habitat due to the high velocity and minimal in-stream cover. An adult steelhead was found at the start of the reach at low flows in November 2001, and several smaller migratory fish were found at the top end of the reach at low flows in April 2002. A natural fish barrier is located in Reach 2 at approximately 0.8 km upstream of the double bridges; anadromous fish migration ends at the canyon. Reach 3 is located entirely within a vertical walled canyon from the natural island to a 6 m high waterfall. The habitat is continual rapid-chute with many waterfalls up to 2 m in height. Instream cover is minimal and banks are steep, providing little overstream cover. No fish were located in this reach. Reach 4 has low gradient and good fish habitat, with a mixture of riffles, glides and pools, and abundant in-stream cover. It extends 6.5 km upstream from the 6 m high water fall, past the proposed project intake, up to near the confluence with Pykett Creek. Within the creek there are several islands, creating side and back channels, and the substrate is primarily gravels and boulders. Numerous rainbow trout were caught on all sampling dates. Reach 5 extends from near Pykett Creek to 3.5 km upstream of the confluence of Tatlow Creek. It has similar habitat to Reach 4, with low gradient, abundant cover, a mixture of riffles, glides and pools, and several side channels. Fish were caught throughout the lower reach. Reach 6 is characterized by high velocities and steep slopes in a narrow, confined channel. It extends from Reach 5 up to the headwaters of Ashlu Creek. There is minimal cover in the reach, the flows are cascades and riffles, and the substrate is mainly bedrock and boulder. No fish were located in this reach. Steelhead fry were stocked in the upper reaches (Reaches 4, 5 and 6) of Ashlu Creek by the Fisheries Branch of Ministry of Environment, Lands and Parks (MoELP) from 1978 to 1997, and residual populations of these steelhead/rainbow trout inhabit the reaches above the Ashlu Canyon.
3.0
Monitoring Components
The Program comprises two types of monitoring: compliance monitoring and biotic response monitoring. Compliance monitoring measures water use to ensure that Ashlu Creek Investments Limited Partnership (the Proponent) is complying with the conditions of MOEs Conditional Water License, including water quantity, quality and temperature, and DFO/MOEs habitat compensation works to ensure that they are physically stable and performing adequately. Biotic response monitoring addresses the complexity of the biological response to flow conditions, and the monitoring program will measure the effect of flow releases on target ecological resources (i.e. fish populations, fish habitat, and invertebrate abundance).
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To reduce the natural variation in Ashlu Creek, time of year and flow range at the time of sampling will be standardized to the extent possible. Field studies will be planned to target a specific flow within a practical calendar period rather than aiming solely for a particular calendar date each year. The approached developed by Hatfield and Lewis (2007) for Independent Power Projects (IPPs) in British Columbia follows a quantitative, site effectiveness monitoring with a beforeafter control-impact (BACI) approach. Under this approach, control sites (i.e. portions of Ashlu Creek or reaches without water withdrawal) are monitored simultaneously with impact sites (i.e. reaches with water withdraw) for a predetermined period both before and after project implementation. Typically, the control sites are upstream of the Project area, and impact sites are within the diversion reach of the Project. In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. The Program consists of monitoring the following aquatic components: 1. 2. 3. 4. 5. 6. 7. 8. 9. Water flow; Water quality; Water temperature; Fish abundance and biomass density; Invertebrate abundance and biomass density; Compensation fish habitat efficacy; Stream channel morphology; Instream Flow Requirement; Flow ramping; and
10. Footprint impact verification. The key areas where these monitoring components will be performed are described below and are shown on Figure 1. All locations are referenced to the distance along the Ashlu Forest Service Road (Ashlu FSR) originating from the Squamish River Bridge. 3.1 Headpond The headpond is located approximately 9 km along the Ashlu FSR and is directly upstream of the intake and weir. When the headpond is filled to its normal operating elevation of 276.0 metres, it will extend approximately 400 metres upstream of the intake and weir. 3.2 Intake/Weir The intake and weir are located approximately 9 km along the Ashlu FSR and are directly downstream of the headpond. The intake comprises a fixed concrete structure and earthfill dam
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with sluice and intake gates; the weir comprises a fixed concrete sill and an inflatable, rubber, Obermeyer weir. The fish ladder is located within the intake/weir structures. 3.3 Mile 25 Bridge The Mile 25 Bridge is located approximately 7 km along the Ashlu FSR and crosses Ashlu Creek just upstream of the Ashlu Canyon. The bridge was built by previous logging companies who worked within Tree Farm License 38 area where Ashlu Creek is located. There is a fork in the Ashlu FSR just 100 metres prior to reaching the Mile 25 Bridge, and this fork leads to the intake, weir and headpond areas. 3.4 Gravel Bar in Ashlu Canyon The gravel bar in the Ashlu Canyon is located approximately 5.5km along the Ashlu FSR and is not accessible from the road. The area is defined at a widening of the Ashlu Canyon where the flow energy of the stream decreases and forms a large gravel bar. Both upstream and downstream of this location are narrow, bedrock canyons. 3.5 Gustafson (Bend) Creek Gustafson (or Bend) Creek is located approximately 4.4km along the Ashlu FSR and is an intermittent stream. In the winter and early spring, Gustafson Creek typically acts as a conduit for avalanches that cross the Ashlu FSR. Immediately downhill of Gustafson Creek is a steep section of the Ashlu FSR. 3.6 Powerhouse/Tailrace/Switchyard The powerhouse and tailrace are located approximately 2.8km along the Ashlu FSR. The powerhouse comprises a fixed concrete building with turbines and generators within, and the tailrace comprises a fixed concrete pool and overflow sill into Ashlu Creek. The powerhouse and tailrace are located immediately downstream of the mouth of the narrow Ashlu Canyon. Adjacent to both structures is the electrical switchyard, and slightly uphill is the tunnel portal and adjoining penstock (buried beneath the Ashlu FSR). 3.7 Double Bridges The double bridges are located approximately 2.5km along the Ashlu FSR and cross Ashlu Creek in two places. Like the Mile 25 Bridge, these bridges were built by previous logging companies who worked within the Tree Farm License 38 area. The double bridges mark the area where Ashlu Creek changes to a wide, low energy, meandering stream. This location is generally known to be the upstream limit for salmon spawning in Ashlu Creek. 3.8 Fish Compensatory Habitat The fish compensatory habitat is located approximately 1.5 to 2km along the Ashlu FSR and covers the area to the north and south of the FSR, including along the transmission line right-ofway. This area also connects DFOs small intake and fish habitat ponds and channels that were
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established in the late 1990s. The fish compensatory habitat comprises a network of narrow, low energy streams and pools that criss-cross the transmission line right-of-way and enter into the forested area on the Ashlu Creek delta.
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations
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3.9 Transmission Line The transmission line begins at the electrical switchyard and extends for approximately 3km to the BC Hydro switch beside the Squamish River Bridge. The transmission line parallels the Ashlu Forest Service Road and crosses over Ashlu Creek at the double bridges.
4.0
Water Flow
The primary objective of water flow monitoring is to provide accurate, real time instantaneous flow data in the most practical manner that meets the requirements of DFO and MOE. Monitoring flows will allow verification of the instream flow release (IFR) in the stream at these critical locations for compliance with DFOs Fisheries Authorization provision for minimum flow release. 4.1 Monitoring Locations A total of four (4) hydrometric stations will be installed at the intake (two), Mile 25 Bridge, and at the powerhouse/tailrace. At each station, an electronic pressure transducer will be utilized, and will measure the water level in the headpond and the water level in Ashlu Creek downstream of the intake, within the diversion reach, and downstream of the tailrace. A total of four (4) visual staff gauges will be installed alongside the electronic pressure transducers to provide visual references of the water levels. The staff gauges will allow regulatory agency personnel to evaluate instream flow conditions independent of project operations at any time. 4.2 4.2.1 Monitoring Approach and Analysis Electronic Pressure Transducers At the headpond, a pressure transducer will be installed to continually measure the elevation of the water upstream of the rockfill weir and concrete structures. A second pressure transducer will be installed at a suitable location downstream of the rockfill weir and concrete structures to measure the total IFR, which includes flows from the IFR pipe, fish ladder, sluiceway, emergency spillway, seepage under the structures and overflow from the Obermeyer weir. At the Mile 25 Bridge, located approximately 2 km downstream of the headpond, an existing pressure transducer will continue to measure the elevation of the water within the diversion reach. This station has a proven flow discharge curve which was established during the development phase of the project and has been maintained on a regular basis. It is envisioned that this information will be converted from water depth to flow and be posted onto a publicly accessible web site for recreation users to observe. At the Mile 25 Bridge location, the water level in the diversion reach will be a combination of the IFR plus inflows from tributaries downstream of the weir, seepage from underneath the
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various structures, and any flow releases from the fish ladder, sluiceway and emergency spillway. The hydrometric stations will be installed according to RISC protocols (1998). 4.2.2 Visual Staff Gauges The visual staff gauges will be located near the electronic pressure transducers so that the water level readings from the transducers correlate to the staff gauges. The staff gauges will typically be aluminium strips with calibrated markings (in centimetres) on them, and will be mounted to a stationary object (i.e. rock outcrop, bridge abutment).
A minimum of three (3) discharge measurements, well distributed over the range of discharge flows, will be manually measured to establish the initial rating curves for Ashlu Creek in the diversion and downstream reaches. Due to the significant amount of natural flow in Ashlu Creek, it is unlikely that flows will be able to be measured above 20% of Mean Annual Discharge (MAD) of the full stream flow (27 m3/s) in Ashlu Creek. Once the flow rating curve is established, the water level data collected from the electronic pressure transducers can be converted to flow values. 4.3 Reporting The flow data will be collected on a continuous basis, typically in 15 minute reading intervals, and will be converted to flows for reporting purposes. The data will be recorded and available to the plant operator on a real time basis. The Proponents plant operator can provide on-site DFO and/or MOE staff with the instantaneous water level and flow data for compliance purposes. The headpond data will also be collected on a continuous basis but at a higher frequency as this information is transmitted to the powerhouse for the overall flow control from the intake. The flow passing through the turbines in the powerhouse can be accurately measured through a turbine efficiency test that will be completed during commissioning of the Project. This tests will provide measured data on turbine flow output that can be correlated with tunnel/penstock pressures and then used to develop a program that can convert real time energy and pressure measurements into flows. Flow data will be reported quarterly. summarized in Table 1. Details of the water flow monitoring program are
5.0
Water Quality
The primary objective of water quality monitoring is to monitor for potential impacts of the Project on the stream by collecting and comparing water quality samples taken upstream of the intake and headpond areas of influence (the Control Samples), and within the diversion reach and downstream of the tailrace (Impact Samples).
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5.1 Monitoring Locations Water quality samples will be collected from four (4) locations; i) upstream of the headpond (upstream by 100 to 200 metres and downstream of Pokosha Creek), ii) upstream of the powerhouse/tailrace in the mouth of Ashlu canyon, iii) directly from within the tail race weir, and iv) at or near the double bridges on the Ashlu delta. The double bridge location will likely correspond with one of the pre-project water quality data collection locations; the other two locations will be new locations. 5.2 Monitoring Approach and Analysis Samples taken upstream of the headpond will provide baseline water quality prior to any water reaching, and being influenced by, the intake structure. Samples taken upstream of the powerhouse will represent the most changed water conditions as the water will have flown entirely down the diversion reach at this point. Samples taken from within the tail race weir will reflect any changes to the water quality due to its passage through the water conveyance system, and in particular the tunnel. Samples taken at the double bridge site will reflect the mixed water quality of the diversion reach and discharged water back into the stream from the tunnel/penstock. Water quality samples at all sample locations will be collected semi-annually, which is coincident with low flow events at the beginning and end of the fish growing season, which occurs in April and October, when there is the greatest potential for there to be impacts from the Project on water quality. Water quality samples at the tail race will be collected quarterly to more frequently monitor Acid Drain Rock and metals leaching from the tunnel rock. Water quality parameters most likely to be affected by the project operations include total suspended solids (TSS) and total gas pressure (TGP). Samples will be collected and sent to a certified laboratory for analysis; dissolved oxygen and TGP data will be collected in-situ with portable meters. Dissolved oxygen, turbidity, total suspended solids (TSS), specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate and metals will also be analysed. 5.3 Reporting TSS and TGP values will be compared from the three sampling locations to compare and contrast any changes between the values of the Control and Impact Samples. Also, the baseline study values will also be presented to compare and contrast with sample results from the double bridge sample location. Dissolved oxygen, turbidity, TSS, specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate, and metals will also be compared. TGP is expected to decrease in the diversion and downstream reaches following project operation, based on the fact that flow reductions in the diversion reach will decrease the entrainment of air in pools and the potential for increases in dissolved gas. This prediction will
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be confirmed by comparing the results of the Year 1 study with the baseline data; should the predictions be confirmed, then TGP sampling will be terminated after Year 1. Water quality results will be reported annually. Details of the water quality monitoring program are summarized in Table 2.
6.0
Water Temperature
The primary objective of water temperature monitoring is to observe any potential significant changes in water temperature and the effect of water diversion during operations on water temperatures in the diversion reach and the Ashlu delta. The secondary objective is to observe the water temperatures in the new fish compensatory habitat areas, which are somewhat independent of the ambient water temperature of Ashlu Creek due to the change in stream characteristics for creek into the habitat areas.(i.e. high vs. low energy streams). 6.1 Monitoring Locations Water temperature will be monitored at five (5) stream locations: within the headpond, in the diversion reach at the Mile 25 Bridge, at the powerhouse/ tailrace discharge area, and near the double bridges. A fifth location, which is not on Ashlu Creek, will be in the new fish compensatory habitat on the Ashlu delta. 6.2 Monitoring Approach and Analysis Water temperature data will be collected using stand-alone water temperature sensors or with water level data collection from electronic pressure transducers (as per Section 1). The sensor in the headpond and will be combined with the headpond water level sensor, and will measure the water temperature of the inflowing water from the non-impacted reaches upstream of the Project. The existing water temperature sensor at the Mile 25 Bridge will continue to measure the water temperature within the diversion reach. The sensor installed within the tailrace will measure the temperature of the diverted water from the intake as its passed through the tunnel/penstock and discharged from the powerhouse. The sensor near the double bridges will measure the water temperature of the mixed water from the powerhouse discharge and the flows in the diversion reach. The sensor in the new fish compensatory habitat will monitor the overall temperatures of the slow moving water as it passes through the shallow channels and pools (see Section 6 for details). Water temperature data will be collected in 15 minute intervals (when the sensor is combined with an electronic pressure transducer for measuring water levels) or in two hour intervals (for stand-alone sensors) and will be downloaded quarterly (for the electronic pressure transducers) and semi-annually (for the stand-alone temperature transducers). 6.3 Reporting
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Water temperature data will be reviewed to determine if any temperature issues are present (i.e. biologically significant differences between baseline and operating temperature regimes). The measured temperatures will be compared to the temperature database from the environmental baseline study to observe whether the diverted flow has any affect on the streams overall water temperature. The new measurements may be used to potentially predict and calculate extreme conditions to provide more accurate estimates of temperatures during extreme conditions, which may not be observed in the first few years of monitoring. The frequency of temperature monitoring may be reduced or terminated after five (5) years from the project commissioning should the measurements show that temperature changes are insignificant under the Projects operations and the predicted future conditions. Water temperature results will be reported annually. monitoring program are summarized in Table 3. Details of the water temperature
7.0
Fish Abundance and Biomass Density (Fish Community)
The primary objective of fish abundance and biomass density (also known as fish community) monitoring is to determine whether the fish populations decrease in the diversion reach during Project operations. The target species for monitoring of fish abundance and biomass will be rainbow trout, which were encountered in the upper end of the diversion reach; the secondary target species will be coho salmon, encountered at the lower end of the diversion reach. Rainbow trout were primarily observed upstream of the Mile 25 Bridge, although some were found in the Ashlu Canyon as they were washed down each year, and were survivors of a stocking program carried out by the Ministry of Environment in the 1980s in the upper reaches of Ashlu Creek. Coho salmon were observed in the lower end of the diversion reach (approximately 300 metres upstream of the powerhouse and tailrace location).While this short length of stream was used primarily for rearing and not spawning, it will be included in the monitoring program. The area downstream of the double bridges is known salmon spawning habitat. 7.1 Monitoring Locations The fish community will be monitored in four (4) reaches: one (1) "control" reach located upstream of the headpond on an undisturbed section of Ashlu Creek and three (3) impact reaches within the diversion reach. The control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek. The impact reaches will be at or near the Mile 25 bridge, in Ashlu Canyon along the gravel bar/side channel, and upstream of the powerhouse/tailrace area at the mouth of the Ashlu canyon. 7.2 Monitoring Approach and Analysis To observe the potential affects of the Project on fish, the following fish characteristics will be
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monitored and measured: Presence/absence; Distribution; Population density; Condition (health); and Age structure.
Rainbow trout abundance and density will be monitored at the upper monitoring locations (i.e. headpond, Mile 25 bridge, gravel bar) whereas coho salmon abundance and density will be monitored at the lower location (i.e. powerhouse/tailrace) only as coho salmon are limited to this reach due to the cascade at approximately 500 metres further upstream of the powerhouse/tailrace location. Within this lower reach, rainbow trout may also be encountered as they may be seasonally washed down through the Ashlu canyon to this location. Due to the low conductivity of Ashlu Creek, electrofishing has not typically been the most effective method for fish sampling, and therefore fish sampling will be primarily performed using Gee Traps. The Gee Traps will comprise fine mesh nets capable of barring rainbow trout fry and coho salmon. A minimum of five (5) replicate sample sites will be established in each of the control and impact reaches. Impacts of the headpond, caused by backwatering of the stream channel upstream of the water intake and weir, will also be monitored. Fish abundance sampling will be performed during project operations and the results comparing the observed densities in the baseline study to determine if the headpond has encouraged or displaced fish. Due to the greater depth of the headpond than the pre-project creek, angling will be used as the primary method of fish detection. During the fish abundance sampling, abundance in fish habitats approximately 100 m upstream and downstream of the intake (i.e. within the headpond and downstream of the IFR and fish ladder flow releases) will be evaluated by snorkelling and/or Gee Traps (or electrofishing, if possible) to determine fish quantity, species type and size class. Captured fish will be identified (type and species), body weight and fork length measured, and scale samples of adult taken for age identification prior to being returned to the stream. In addition, notes of the sampling area, its usability as habitat, and the water temperature and conductivity on the day of sampling will also be collected. 7.3 Reporting Based on the fish captured using the various methods, the presence/absence, distribution, population density, condition (health) and age structure of the fish will be reported. The same sampling sites will be used each year to allow paired comparisons of the fish capture in statistical tests and thereby increase statistical reliability as the program is performed over the five year period. The sampling sites will be georeferenced, photographed, and marked in the
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field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The headpond/IFR data will be used to evaluate the relative use of the headpond and habitat downstream of the intake structures by rainbow trout, and will provide evidence of any blockage to upstream movement. Fish abundance and biomass density results will be reported annually. Details of the fish abundance and biomass density monitoring program are summarized in Table 4.
8.0
Invertebrate Abundance and Biomass Density
The primary objective of invertebrate abundance and biomass density monitoring is to test whether invertebrates decrease in the diversion reach during Project operations. 8.1 Monitoring Locations Invertebrate abundance and biomass density will be monitored in three (3) locations: two (2) "control" reach located upstream and downstream of the Project, and one (1) impact reach within the diversion reach. The upper control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek; the lower control reach will be at or near the double bridges. The impact reach will be within the proposed diversion reach at or near the gravel bar in the Ashlu canyon. In addition, the sampling sites will be located in representative habitat in the downstream half of a riffle section, and to the extent possible, nets will be set in areas with water velocities of 0.2 to 0.4 m/sec. 8.2 Monitoring Approach and Analysis Abundance and distribution of macroinvertebrates in the drift will be characterized through the use of drift samplers, which are vertically fixed nets that are suspended in the water column. The samplers will be installed with rebar, set in the current and left to "fish" for a period. Drift samplers will be fixed plankton-type drift nets (30 x 30 cm mouth) with 250 m mesh to retain invertebrates of most importance to fish. Drift will be sampled in the daytime to reflect prey abundances available to fish and will be deployed for a sufficient period to gather an adequate drift sample (typically two hours, but may be shorter, depending on drift conditions. Two (2) replicate samples will be collected at each site on each sampling day according to the methods for collection and analysis of invertebrate drift as presented in Hatfield and Lewis (2007). Sites will be sampled at least once during the main growing season, usually May through September when the fish abundance surveys are being performed and during low to moderate flows. If additional samples are collected, the sampling dates will be separated by at least one (1) month. One (1) sample should be taken during base flow conditions; the other
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sample should be taken within the growing season prior to the period of lowest flows. Captured macroinvertebrates will be identified by type and species, as well as abundance (quantity). In addition, the sampling area and the water temperature on the day of sampling will also be noted.
8.3 Reporting Based on the macroinvertebrates captured, the presence/absence, type and species, quantity and population density will be reported. The same sampling sites will be used each year to allow paired comparisons of the macroinvertebrates capture in statistical tests and thereby increase statistical reliability as the program is performed over the required period. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The monitoring of invertebrate drift organism abundance and biomass density will be measured up to twice per year. Details of the invertebrate abundance and biomass density monitoring program are summarized in Table 5.
9.0
Compensatory Fish Habitat Efficacy
The primary objective of compensatory fish habitat efficacy monitoring is to monitor the performance of project mitigation and compensation habitats, which will be evaluated following project commissioning after one (1) and five (5) years of operation. 9.1 Monitoring Locations Compensatory fish habitat efficacy will be monitored at two (2) locations: the fish ladder, at the intake and weir area, and the new fish compensation habitat on the Ashlu delta. 9.2 9.2.1 Monitoring Approach and Analysis Fish Ladder The efficacy of rainbow trout passage past the water intake will be evaluated qualitatively by an inspection of the fish ladder each year during the period of rainbow trout movement (typically in April/May). The fish ladder will be examined, and measurements of depths and velocities at key locations within the ladder will be taken to provide information on the flow conditions and on the discharge through the ladder. Periodic observations will be made to check on fish passage either in the ladder or at the staging area below the ladder. 9.2.2 Rearing Fish Compensation Mitigation and compensation habitat for the Project was created on the Ashlu delta
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primarily for coho salmon, with secondary works for rainbow trout/steelhead, as directed by DFO and MOE. The compensatory fish habitat for coho salmon comprises a series of new channels, pools and the interconnection of existing, intermittent channels along the Ashlu flood plain into the existing DFO developed pools and channels created in the late 1990s. Construction of the new habitat was supervised by an on-site DFO representative in June 2007 and May 2008, with overview by the Environmental Monitor and Proponent to assist in the channel and pool layouts. Once the compensatory habitat was built in 2007, occasional visits were made to review the conformance with the design specifications, and to ensure post-construction inspection to ensure adherence to the original compensation plan for the Project. In 2008, some modifications were performed to optimize flows, and additional channels and pools were independently added on by DFO to interconnect to Buck Creek, located further north on the Ashlu delta. The compensatory fish habitat for rainbow trout/steelhead comprised several triangulated debris jams (i.e. root wad and log structures) that were installed in 2007 by MOEs representative in and around the original DFO habitat as well as along the north bank of Ashlu Creek. Additional work was carried out in 2008 to fine-tune this habitat work, and was carried out under supervision of DFOs representative. The fish compensatory habitat will be examined, and measurements of depths and velocities at key locations within the streams and pools will be taken to provide information on the flow conditions and discharge through the system. Periodic observations will be made to check on fish utilization in the channels and pools. Utilization of the fish ladder and compensatory habitat will be through observations and photographs. 9.3 Reporting Coho salmon presence/absence, and the physical integrity, stability and erosion of the new habitat channels will be noted for the compensatory habitat, whereas rainbow trout presence/absence only will be noted for the fish ladder. Temperature will be monitored in the fish compensation habitat using a single continuous recorder, as described in Section 3. This sensor will be located in the large pool or in the adjacent large culvert located on the north side of the existing Forest Service Road and at the base of Buck Mountain. Details of the compensatory fish habitat efficacy monitoring program are summarized in Table 6.
10.0 Stream Channel Morphology

The primary objective of compensatory fish habitat efficacy monitoring is to assess any potential impacts that the Project has on channel stability and sediment conditions during operations.
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10.1 Monitoring Locations Stream channel morphology will be monitored at three (3) locations: in the headpond, the diversion reach at the gravel bar in the Ashlu canyon, and at or near the double bridges (downstream of the powerhouse/tailrace). 10.2 Monitoring Approach and Analysis To determine whether there are any changes in the stream channel morphology during Project operations, data will be collected prior to project completion to provide a baseline data set, and either (a) after a large flood event (the first 1 in 10-year event or greater event as determined by hydrology at the point of diversion) or (b) at the end of five (5) years of post-construction monitoring, whichever comes first. During operations, periodic observations will be made to identify any changes to the habitat in the diversion reach over time in the designated areas. Transects will be carried out to measure the quantity of change of the stream channel shape and size. These transects will allow for a comparison of the changing stream channel and will aid in assessing whether the IFR is affecting any of the fish habitat as was originally predicted. For the headpond, transects will likely not be achievable due to the depth of the headpond; as an alternative, bathometry may be used to map the profile of the headpond. At the headpond, the change in the bathometry profile of the base of the headpond will allow the rate of sediment infilling to be determined. In the diversion reach, the transect measurements will show how often the gravel bar side channel is wetted and used by rainbow trout. At the double bridges, the transect measurements will show if the channel profiles are changing on gradual basis during operations or if the channel profiles change only after large flood events as is currently the pre-Project case. 10.3 Reporting Transect cross sections and headpond bathometry profiles will be presented, as well as a description of any changes to these sections and their apparent affect on fish habitat. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. The stream channel morphology results will be reported annually. Details of the stream channel morphology monitoring program are summarized in Table 7.
11.0 Instream Flow Requirement

The primary objective of monitoring water flows is to ensure the instream flow requirements (IFRs) are met. 11.1 Monitoring Locations
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The primary gauge for IFR measurement is at the first suitable location downstream of the intake which is the transition from a relatively flat gravel and boulder field into a bedrock canyon, approximately 250 m downstream of the intake. A pressure transducer level probe is installed in this location and connected to the intake control building by a teck cable suitable for direct burial. The water level is measured on a continuous basis and relayed to the powerhouse control system in real time. A water level benchmark corresponding with the 2.42 m/s IFR required under the DFO Authorization has been established in March 2009 and will serve as a visual reference to calibrate the level probe. A secondary gauge for backup and calibration purposes is installed in the diversion reach at the Mile 25 Bridge location. Approximately 10% of the flows measured at this location are attributed to a small tributary between intake and this location. Therefore, the IFR immediately downstream of the intake is approximately 90% of the flow measured at this location. The secondary station is powered by a solar panel with battery backup and direct radio link to the powerhouse. The station also provides data required under the DFO Authorization and houses a kayaker warning system as required by NWPD. 11.2 Monitoring Approach and Analysis IFRs for this project are defined in the Authorization issued by DFO and the Approval issued by NWPD. It is noted that when the two documents call for different minimum flows at the same time, the higher flow will be released. 11.2.1 Requirements under DFO DFO Authorization 04-HPAC-PA2-000-000530 sets the minimum IFR at 2.42 m/s year around with no seasonal adjustments required. This flow is primary provided through a 30 inch bypass pipe has been installed as part of the sluiceway structure. The center inlet elevation of the pipe is 272.0 meters, while the normal operating water level is 276.0. The inlet is protected by a coarse trash rack and the inflow can be controlled by a manually actuated knife valve. The IFR valve will be calibrated to the required minimum flow during the commissioning of the plant. Because the water level in the head pond will remain nearly unchanged during normal operation, it is not expected that the valve requires adjustments during the operational phase of the project. The sluiceway flap gate acts as a backup system to meet the IFR in case the 30 inch pipe is not providing the required flows or is shut down for maintenance and repair works. The capacity of the flap gate is approximately 3 m/s at normal head pond operating water level. 11.2.2 Requirements under Transport Canada / Navigable Waters Protection Division Approval #8200-T-10595.2 issued by NWPD calls for instream flow releases to accommodate recreational use of the creek through kayakers during specific days and times as follows if pre-booked by kayakers:
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Four weekends (Saturdays and Sundays) in May and eight weekends (Saturday and Sundays) in August and September for a total of 24 days and on each of those days between 9am and 6pm Flow release to range between 16 m/s and 32 m/s. Amounts of actual release to be coordinated between ACILP and the kayakers.
An online booking system is being developed to meet the spring 2010 kayaking season. The system will allow kayakers to book flow release days within the windows described above and select their preferred release rate within the required range. Flows for kayaking purposes will be primarily released and controlled through the sluiceway. 11.3 Reporting All data, raw and analyzed will be made available to the regulatory agencies throughout the season. Monitoring of stream flows will be maintained throughout the life of the project and may be used with other effectiveness and compliance monitoring programs. Details of the IFR monitoring program are summarized in Table 8.
12.0 Ramping
The primary objective is to assess the efficacy of Proponents proposed ramping rate. 12.1 Monitoring Locations Ramping will be monitored at three (3) locations: in the diversion reach immediately downstream of the water intake and weir and at the gravel bar within Ashlu canyon, and downstream of the diversion reach at the double bridges. 12.2 Monitoring Approach and Analysis During commissioning, normal operation, start ups, normal shut downs and emergency shut downs, the ramping rates shall not exceed 29.0 m3/sec per 90 minutes. This rate will be confirmed during the commissioning process of the plant and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991 when a dedicated hydrometric station was first established on the stream. Ramping rates will be monitored during commissioning of the Project to measure water level change rates and their resulting changes to fish habitat (i.e. dewatering of side channels and the potential stranding of fish). During project commissioning, the efficacy of this rate will be tested by ramping down at the specified rate and measuring the resulting water level change in the sensitive habitats in the diversion reach and further downstream where all of the diverted and IFR flows converge. The ramping rate test will occur when fry and juvenile rainbow trout are present. If the Project is
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commissioned when fry and juveniles are not present (i.e. January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present. Once determined, the ramping rate will be used throughout the operation of the Project. To monitor the effect of ramping during Project commissioning, temporary (or permanent) water level gauges will be installed at the key sites, and will consist of a manual gauge plate (approximately 60 cm in height) fixed to the bank, large boulder, large woody debris or hammered in the stream bed. In addition, the water level data measured by the electronic transducers at the hydrometric stations (installed as per Section 1) will also be collected. The habitat and water levels at the monitoring locations will be observed and measured by a biologist, who will be stationed at each monitoring station during the ramping test, to document any incidences of fish stranding. The biologist will collect the baseline habitat data and visually observe for any fish presence/absence. Habitat data will include dominant stream cover types, substrate composition and a general description, including GPS coordinates. A photo monitoring station will be established at each site, and photos will be collected (and repeated) at each of the cross-sections measured. Drawings of each site showing the location of photo monitoring stations and gauge locations will be prepared. The sites will be monitored at the beginning and end of each ramping commissioning test to document the extent of flooding and collected habitat measurements. At each site, the wetted widths and wetted lengths of any isolated pools will be measured along with measurements of water level changes from the staff gauges. Temporary cross-sectional pins will be set in the ground to identify the locations where wetted widths and lengths are to be collected pre-and post-ramping. Where wetted areas become dry post-ramp, substrate will be excavated by hand and overturned to confirm fish presence/absence. Any fish found will be captured, enumerated by species and age class, and their reason for stranding will be recorded (i.e. fish isolated in a pool or habitat was dewatered). Following project commissioning, the water level sensors hydrometric stations (as installed in Section 1) will record water level changes annually for one (1) to five (5) years in the diversion reach. 12.3 Reporting Photos of each key monitoring site at specific flows will be provided for each of the monitoring stations. Cross-sections of each monitoring site will be prepared and will show the stream profiles, water level changes and gauge locations from the transect measurements. In addition, a description of the dominant stream cover types and substrate composition will accompany the cross-sections. The ramping results will be reported within six months after Project commissioning is completed. Details of the ramping monitoring program are summarized in Table 9.
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13.0 Footprint Impact Verification

The primary objective of footprint impact verification is to assess and quantify whether the asbuilt Project footprint impacts aquatic and riparian habitats. 13.1 Monitoring Locations Footprint impact verification will be measured at the intake and weir, powerhouse, tailrace, switchyard, portions of the access roads (leading down to the intake, powerhouse, switchyard) and portions of the transmission line, as these areas are located instream and/or within the riparian zone of Ashlu Creek. 13.2 Monitoring Approach and Analysis Impacts on aquatic and riparian habitat will be verified through direct on-site measurements. The physical dimensions of each right-of-way or clearing that impacts a riparian zone or an aquatic habitat will be measured in the field and documented with photographs. For aquatic habitat, the bed material will be described in the impact zones (i.e. concrete, rip-rap), while for riparian habitat, the condition of the reseeding/replanting will be documented. The monitoring of the effectiveness of re-vegetation will take place for one (1) year following the completion of construction and late in the growing season, when a full season of growth will be evident. Successful replanting will be evidenced by a survival rate of 80% of the stock; if more than 20% of the planted stock dies over one year, replanting will be required. Replanting of lost vegetation should occur within eight months of disturbance, with stock planted during the fall and spring to ensure the greatest likelihood of survival. Once planted, brushing around seedlings may be required to remove competing vegetation and additional erosion control may be required to stabilize vegetation on steep, erodible soils and ensure long-term vegetation success. 13.3 Reporting The effectiveness of the re-vegetation and any replanting requirements will be documented so that they can be planned and completed the following year during the growing season. The footprint impact verification results will be reported annually. Details of the footprint impact verification monitoring program are summarized in Table 10.
14.0 Reporting
The objectives, methods, results and recommendations for changes to and/or additional monitoring will be provided in annual or more frequent reports, depending on the component of interest. The timing of reporting for the monitoring programs will vary by component, however annual reports will be prepared for all, except those components that only require a one-time study (documented in a single report) or those that require more frequent monitoring.
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All baseline monitoring data will be compiled in a report for agency review by March 31, 2010 following the year in which project construction is complete. In each year following this, an annual report will be submitted to DFO and MOE that documents the findings of the previous year's study. After five (5) years of post-project monitoring, a summary report will be completed that evaluates the need for additional monitoring. Section 8 (ramping) will be reported on within six (6) months of the completion of commissioning tests during which the ramping rate will be tested and refined. Section 9 (footprint impact verification) will be reported on by March 31, 2011 of the year following the completion of construction or earlier if the mitigation of disturbed areas has been completed. Annual reporting of project components will be standard for each component. All reports will be certified by an appropriately qualified professional registered biologist as required.
15.0 Exclusions
Post-construction monitoring of Harlequin Ducks and Grizzly Bears will be carried out and reports issued to Environment Canada and the MOE, respectively, as per their regulatory permitting requirements. Therefore, these species have not been included in the Program.
16.0 References
16.1 General References
Hatfield, T. and A.F. Lewis. 2007 (draft). Guidelines for the collection and analysis of data on fish and fish habitat in small steep streams. Prepared by Ecological Research Ltd. and Ecofish Research Ltd. for the BC Ministry of Environment, Surrey BC. Lewis, A., T. Hatfield, B. Chilibeck, and C. Roberts. 2004. Assessment methods of aquatic habitat and instream flow characteristics in support of application to dam, divert, or extract water from streams in BC. Ministry of Water, Land, and Air Protection, and the Ministry of Sustainable Resource Management, Victoria, BC. 101 pp. LWBC 2004. Hydrological Guidelines for Waterpower Projects, October 2004. Completed by the Surrey Regional Office, Land and Water Management Division, Suite 200-10428 153rd Street, Surrey, BC V3R 1E1. 20 pp. RISC. 1998a. Manual of Standard Operating Procedures for Hydrometric Surveys in British Columbia. Prepared for the Resource Inventory Standards Committee. Roper, B.B., J.L. Kershner, E. Archer, R. Henderson, and N. Bouwes. 2002. An evaluation of physical stream habitat attributes used to monitor streams. J. Am. Water Resource Assoc. 38: 1637 1646. 16.2 Project-Specific References
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Ashlu Creek Green Power Project Fish Ladder Design Modifications. Prepared by Ashlu Creek Investments Limited Partnership. March 3, 2008. Ashlu Creek Green Power Project Construction Environmental Management Plan Revision J. Prepared by Sigma Engineering Ltd. and modified by Ledcor Power Inc. November 8, 2006 (updated from original May 2004). Authorization for Works or Undertakings Causing the Harmful Alteration, Disruption or Destruction of Fish Habitat and Destruction of Fish (Authorization No. 04-HPAC-PA2000-000530). Prepared by Fisheries and Oceans Canada. July 31, 2006. 2005 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by TRC Biological Ltd. September 1, 2005. Ashlu Creek Project South Side Channel Short-Term Compensation. Prepared by Ledcor Power Inc. February 28, 2005. Ashlu Creek Project Denil Fishway Design Proposal. February 3, 2005. Prepared by Ledcor Power Inc.
Ashlu Creek IPP Compensation for Steelhead Trout. Ministry of Water, Land and Air Protection to Fisheries and Oceans Canada. November 25, 2004. CEAA Screening Report Ledcor Power Inc.s Proposed Run-of-River Hydro Project on Ashlu Creek, BC. Prepared by Department of Fisheries and Oceans, Habitat and Enhancement Branch, Major Projects Review Unit (Vancouver, B.C.). October 18, 2004. Ashlu Creek Project Species at Risk Summary letter. Sigma Engineering Ltd. October 8, 2004. Ashlu Creek Project - Response to Environment Canada September 10, 2004 Letter. Prepared by Ledcor Power Inc. October 7, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering. September 2004 (updated from March 2004). Ashlu Creek Project Flow Ramping Rate Amendment. Prepared by Ledcor Power Inc. May 28, 2004. Ashlu Creek Run-of-River Power Project. Prepared by Fisheries and Oceans Canada. April 21, 2004. Ashlu Creek Power Project Species at Risk. Prepared by Sigma Engineering. June 7, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering Ltd. April 13, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering Ltd. March 18, 2004. Ashlu Creek Water Power Project Wildlife Addendum to the Ashlu Creek Development Plan. Prepared by Sigma Engineering Ltd. January 9, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering. April 13, 2004. Ashlu Creek Project Flow Ramping Rate Recommendation. Prepared by Ledcor Power Inc.
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March 29, 2004. Ashlu Creek Updated Hydrology Report. Prepared by Knight Pisold Consulting. February 25, 2004. Ashlu Creek Power Project - Wildlife Addendum to the Development Plan. Prepared by Sigma Engineering. November 28, 2003 Ashlu Creek Project Minimum Flow Recommendation. Prepared by Ledcor Power Inc. November 21, 2003. Ashlu Creek Hydroelectric Hydrology Report. Prepared by Sigma Engineering Ltd. October, 2002.
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Table 1. Objective Description Criteria Location Duration
Methods Sample area Units Sensitivity/accuracy Sample no.
Frequency Timing Measure constraints Analytical test
Water flow To ensure compliance with flow releases. Water level pressure sensors and manual flow discharge measurements. Flow discharge measurements over a range of flows (between 10% and 200% MAD). In the headpond; downstream of the intake structures; at the Mile 25 Bridge; downstream of powerhouse/tailrace. Headpond stage monitoring for the life of the project. Discharge measurements may be terminated when biotic response monitoring is complete five (5) years after project commencement provided that headpond stage has been shown to accurately measure channel flow in the diversion reach. Continuous pressure transducers; calibrated with manual velocity meters. Headpond; in stream channel downstream of intake, Mile 25 Bridge, downstream of powerhouse/tailrace. 3 Water level in mm and flow in m /s. +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors, three (3) measurements. 15 second scan and two (2) minute log for headpond sensor; 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a (compliance monitoring).
Table 2. Objective Description
Water quality To test whether water quality changes in the diversion reach during operations. Dissolved oxygen, total gas pressure (TGP), turbidity, total suspended solids (TSS) , specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, and nitrate Pre-construction (2 years) Upstream of headpond (control reach), in diversion reach (impact reach), and downstream of diversion reach. Two (2) year baseline and five (5) year post-construction mean. In-situ data collection (water quality meters) and sample collections for laboratory analysis. Spot locations in upstream reach above influence of headpond; in stream channel in diversion reach upstream and above influence of tailrace; at double bridges and downstream of tailrace return water. Varies by parameter. Varies by parameter. One (1) site in each sample area, three (3) per sampling event. Semi-annually Pre-construction: during typical flows of each season; post-construction: low flow periods near the beginning and end of the growing season Select sites avoiding sites immediately downstream of significant local inflow BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data normalization tests
Criteria Location Duration Methods Sample area
Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
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Table 3. Objective Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Water temperature To assess whether water temperature changes in the diversion reach due to the diversion of water during operations. Temperature. Pre-construction (2 years) maximum, minimum and mean in critical periods. Headpond, diversion reach, at powerhouse/tailrace, double bridges (downstream of tailrace), new fish compensatory habitat areas. Two (2) year pre-construction baseline and five (5) year post-construction. Continuous temperature recorders (may be incorporated with water level sensors) Fixed locations in headpond, diversion reach, powerhouse/tailrace, double bridges (downstream of tailrace), in new fish compensatory habitat areas. Degrees Celsius. +/- 0.1 deg. C One (1) sensor in each location. Hourly. Continuous (15 minutes with incorporated water level sensor; 2 hours for standalone sensor). Select site away from temperature edge effects; avoid sites that dewater in low flow. BACI: express in appropriate format for issues. For fish rearing: degree days in growing season, days >18, >20, <1.
Fish abundance and biomass density To test whether fish abundance decreases in the diversion reach during operations. Number of fish by species and life stage per unit area; body weight and fork length of all fish captured; scale samples of adult fish; area of sampling; usability of habitat; temperature and conductivity. Pre-construction (2 years) mean. Upstream of headpond (control); headpond, diversion reach at Mile 25 Bridge, diversion reach in Ashlu Canyon, diversion reach below cascade in Ashlu Canyon (impact). Two (2) year pre-construction baseline and five (5) year post-construction mean. (a) Gee Traps; (b) angling; (c) snorkelling; (d) electrofishing; (e) on-site measurement of fork length and weight; (f) scale collection; (g) lab analysis of age; photo documentation of site; measure depth, velocity and substrate in enclosure to quantify usability (see Hatfield and Lewis 2007). 2 2 Minimum 100 m per site: greater area required if fish density <0.1 fish/m . no. fish/m2; g/m2 +/- 0.1 g 10 total; five (5) in control reach; five (5) in each section of impact reach. Annually. Late growing season (August to October). Conduct when flows are between 10 and 20% MAD; water clarity >30 cm; and water temperature >= 7 deg. C; release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI: normalize data and use ANOVA or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests.
Criteria Location
Duration Methods
Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
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Table 5. Objective Description Criteria Location Duration Methods
Invertebrate abundance and biomass density To test whether invertebrates decrease in the diversion reach during operations. Number and biomass of invertebrates by per unit flow; diversity. Pre-construction (minimum 1 year) mean. Upstream of headpond (control); diversion reach at gravel bar in Ashlu canyon and at double bridges (impact). Minimum one (1) year pre-construction baseline and one (1) year post-construction. (a) drift net samples fish for hours; (b) taxamonic id to genera or family; (c) photo documentation of site; (d) measure depth and velocity and discharge to quantify flow (see Hatfield and Lewis 2007). Drift net sampler (30 cm x 30 cm mouth, 100 cm length); 250 m mesh. No. and biomass of invertebrates per # of taxamonic. +/- 1 Three (3) in total; two (2) in control reach and one (1) in impact reach At least once per year in the growing season (May to September); twice preferred, if practical, and separated by one month. Under base flow conditions in the rainbow trout growing season. Conduct when flows are between 10 and 20% MAD; water m3/s; and water temperature traps placed in downstream half of riffles. BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests. Compensation fish habitat efficacy To evaluate the performance of compensation habitats in compensating for lost habitat, and the effectiveness of migration. Measurement of habitat dimensions, evaluation of habitat quality through physical parameter measurements (stability, erosion), and monitoring of water level and temperature. Confirmation of fish use of compensation habitats through juvenile and adult fish observations. Examine fish ladder annually and comment on condition and apparent efficacy using fish abundance data for inference. Should habitat characteristics change such that habitat suitability is reduced, the compensation habitats will be restored as necessary. Intake (fish ladder) and compensation habitat on Ashlu delta. Up to five (5) years post-construction. Evaluation will be done by observation of fish presence/absence. Water temperature and level measurements will generally follow the guidance in Tables 1 and 3. Fish ladder and compensation habitat.
2 2 2 no. fish/ m ; g/m , deg. C, m , water level in mm
Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
+/- 0.1 g; +/- 0.1 deg. C, +/- 2 mm (water level) Two (2) samples of fish abundance in compensation habitat; single survey of fish ladder use. Fish abundance and density annually; physical characteristics when the compensation habitat is completed, after one (1) and five (5) years of operation Year round for temperature and level for compensatory habitat only; fish observations in late growing season for coho salmon (August to October) for compensatory habitat; fish observations in rainbow trout migration season (April/May). Conduct when flows are between 10 and 20%, water clarity >30 cm; and water temperature release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI design or variant: integrate with impact and control measures taken in other areas.
Measure constraints Analytical test
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Table 7. Objective
Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Stream channel morphology To assess project impacts on channel stability and sediment conditions during operations in the headpond area, the diversion reach, and downstream of the powerhouse/tailrace Substrate surveys through transect surveys; photo transect survey points. Pre-construction and post-construction, following 1:10 year flood event or for five (5) years, whichever comes first. Headpond; in the diversion reach at the gravel bar in Ashlu canyon; at the double bridges. Pre-operational and after 1:10 year flood event or after five years, whichever comes first. Transect surveys in diversion and downstream reaches; bathometry topographical survey in the headpond. n/a n/a n/a Detailed transect survey: one (1) transect in diversion reach and one (1) at double bridges; bathymetry survey at headpond. Once pre-project, once after 1:10 year flood event or after 5 years, whichever comes first. Post-freshet: transects after large flood event (1:10 year flood). n/a n/a
Table 8. Objective Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Instream Flow Requirement To ensure compliance with the specified instream flow requirement. Water level pressure sensors and manual flow discharge measurements. 2.42 m3/s year round or 16 m3/s to 32 m3/s if pre-booked during 4 weekends in May and 8 weekends in August and September. Approximately 250m downstream of the intake structure Life of the project. Continuous pressure transducer n/a cm staff gauges; m3/s - discharge +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors. 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a
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Flow Ramping Assess the efficacy of prescribed ramping rates. Monitor ramping rates, survey for fish stranding. 15 m3/s per hour proposed rate when fry and juvenile fish are present. In diversion reach: immediately downstream of the intake/weir; the gravel bar and side channel in Ashlu canyon; downstream of diversion reach at double bridges. During project commencement to establish ramping rates. Ramp down and measure the resulting water level change in sensitive habitats in diversion reach and below diversion reach; observe sensitive habitats for fish stranding. Spot locations in sensitive habitats in diversion reach and below diversion reach. m3/s per hour (or equivalent cm/hr); number of stranded fish. +/- 2 mm Variable. During project commissioning. When fry and juvenile fish are present; if a project is commissioned when fry and juveniles are not present (January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present (worst case conditions). n/a n/a
Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
Measure constraints Analytical test
Footprint impact verification Quantify as-built footprint impact areas and characteristics. Measure extent and magnitude of impact of project structures on instream and within riparian zones. Ground measures and characteristics laid out in impact assessment reports. Intake, weir, powerhouse, tailrace, switchyard, access roads, transmission line. One time measurement following project construction. Measurements on the ground and/or from aerial photos based of the overlap of project structures and work areas: evaluation of magnitude of effect based on impact assessment criteria. Document instream bed characteristics and riparian condition. Document success of re-vegetation and replant areas. Ground measurement of impacted riparian or instream areas, supported with length and width measurements of individual sites. m2 +/- 10% n/a One time measurement. One year after construction, when mitigation of disturbed areas has been completed. n/a n/a
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From: Sent: To: Subject: Stoddard, Erin M ENV:EX Monday, April 12, 2010 12:22 PM Babakaiff, Scott C ENV:EX Ashlu OEMP Version C
DidwegetaversionCofthisOEMPsignedbyaprofessionalyet? Thanks. Erin
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From: Sent: To: Subject: Stoddard, Erin M ENV:EX Monday, April 12, 2010 12:22 PM Babakaiff, Scott C ENV:EX Ashlu OEMP Version C
DidwegetaversionCofthisOEMPsignedbyaprofessionalyet? Thanks. Erin
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From: Sent: To: Cc: Subject: Attachments: Nikl, Lee [Lee_Nikl@golder.com] Tuesday, April 13, 2010 12:09 PM Knight, Francesca; Robert Kulka Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Francois Hebert; Brian Patjas; Steve Moir RE: ALGAL TOXICITY TESTS TM 0413_10 - Algal Tox Test Results.pdf; image001.jpg
Chessy, Attachedisthefinalizedmemowithlaboratoryreportsattached.Pleasecallifyouhaveanyquestions. Regards, Lee

Lee Nikl (M.Sc., R.P.Bio.) | Principal / Senior Environmental Scientist | Golder Associates Ltd. 500 - 4260 Still Creek Drive, Burnaby, British Columbia, Canada V5C 6C6 T: +1 (604) 296 4200 | D: +1 604 297 2016 | F: +1 (604) 298 5253 | C: +1 778 231 6636 | E: Lee_Nikl@golder.com | www.golder.com
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From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: April 12, 2010 7:23 AM To: Nikl, Lee; Robert Kulka Cc: Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Francois Hebert; Brian Patjas; Steve Moir Subject: RE: ALGAL TOXICITY TESTS
thanks Lee, I'll wait for the finalized memo. Chessy
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From: Nikl, Lee [mailto:Lee_Nikl@golder.com] Sent: April 9, 2010 5:05 PM To: Robert Kulka; Knight, Francesca Cc: Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Francois Hebert; Brian Patjas; Steve Moir Subject: RE: ALGAL TOXICITY TESTS
Chessy, TheunsigneddraftdocumentinRobertsemaildoesnothavethelabdataattachedtoitatthispointasIam awaitingthefinalQA/QCreviewedreportfromNautilusEnvironmental.OnceIhavethat,Iwillfinalizethememo andincludethelabreportsasattachments.Intheinterim,ifyouwouldlikethetoxtestingresultsortheMaxxam analyticalreport,letmeknowandIwillsendthosetoyou.Feelfreetocallmeifyouhaveanyquestions. Regards, Lee

From: Robert Kulka [mailto:RKulka@innergex.com] Sent: April 9, 2010 4:22 PM To: Francesca.Knight@dfo-mpo.gc.ca Cc: Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Nikl, Lee; Francois Hebert; Brian Patjas; Steve Moir Subject: FW: ALGAL TOXICITY TESTS
HelloFrancesca, Wereceivedthisafternoonthesampleresultsofthepenstock/tunnelflushingwaterandadraftTechnicalMemo fromLeeNikl.InsummarythememosupportsdischargeoftunnelwaterwithAsconcentrationsupto80ppb(Total Metals)basedonbioassaytestconductedwithtunnelwater. Thestatusisasfollows: Tunnelflushwater(currentlyretainedinthetailrace,approximately800CM): Turbidity:22.3NTU PH:10.45 TotalMetalsAs:59.9ppb DissolvedMetalsAs:35.7ppb
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BasedontheWaterQualityManagementPlan(November2009)andsupplementalTechMemo(today)Iplanthe following(withMikeNelsoninsupportofthisapproach): NeutralizePHvalueoftunnelflushwatercurrentlycontainedinthetailracebyuseofCO2bubblerto9.0or less(startedat3pm) Dischargetunnelflushwateratflowofapproximately0.02cmsintocreek;currentlycreekflowisapproximately 10cms:theobtaineddilutionratioistherefore1:500.Requiredtimetodischargeisapproximately12hours; Commencepenstock/tunnelfilling(at10%ofavailableflowattheintake:expectedduration36hours).Take sampleofnewpenstock/tunnelwater,rushtoVancouverwithexpectedresultstomorrow(Saturday),say 2pm.Commencediversion/operationsubjecttoresultofthissample,completionoftunnelfilling,completion oftailracedraining,andofcourseavailableflowsattheintake;mostlikelyallthiscouldfalltogetherSundayin theam. FYI:HeadpondfillingcommencedyesterdaymorningandisongoingwithCascadebeingpresentonsite.Headpond isnowapproximately70%full. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Nikl, Lee [mailto:Lee_Nikl@golder.com] Sent: Friday, April 09, 2010 12:31 PM To: Robert Kulka Subject: ALGAL TOXICITY TESTS
Robert, Iattachforyourconsiderationadraftofthetechnicalmemorandum.Onceyouhavehadachancetoreadthis, pleasegivemeacall. IdonotyethavethefinalresultsfromNautilussoitwillneedtoremainasadraftforthetimebeing. Regards, Lee

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying of this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work
Page 195 FNR-2011-00265 Part 2
product may not be relied upon.
Page 196 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Wednesday, April 14, 2010 7:47 PM Babakaiff, Scott C ENV:EX RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C image001.jpg
OK, I have to finish tomorrow... I have been writing for about the last two hours, almost because i had done my review of version B, then had to start all over tonight.. S. 22
S22 S. 22
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: Wed 4/14/2010 10:40 AM To: Knight, Francesca; Busto, Vince Cc: Bennett, Timothy A ENV:EX; Stoddard, Erin M ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
Wow, I hadnt noticed that you & Vince were not provided copies of Revision C. It seems that the proponent has not got the message that the monitoring plan will be referenced by both MOE & DFO. There is alot in Revision C that will benefit from your review...as you can see from my review, I did not address Water Quality or macroinvert stuff, and I dont believe anyone else from MOE will be providing that input. Erin will be providing review of the fish stuff shortly. Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, April 14, 2010 10:33 AM To: Babakaiff, Scott C ENV:EX Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Hey Scott, I was planning on writing my comments this week; could you send me revision C please...looks like my latest is revision B, thanks! C
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thursday, March 18, 2010 4:41 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson
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Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
HelloTim, AttachedisRevisionCoftheOEMP.AlsoattachedisacoverletteroutliningthehistoryoftheOEMP,ourre applicationforLTCOperation,andcurrentstatusoftheproject(shutdownfortunnelrepairs).Asealedandsigned copyoftheOEMPwillbesentpermailtoyouearlynextweek. Pleasecontactmeifyouhaveanyquestions.Regards, Robert
________________________________________
http://www.innergex.com/logo.jpg
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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From: Sent: To: Cc: Subject: Attachments: Knight, Francesca [Francesca.Knight@dfo-mpo.gc.ca] Wednesday, April 14, 2010 11:56 AM Babakaiff, Scott C ENV:EX Busto, Vince RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C image001.jpg
OMG! I have definitely not seen this, it's so annoying! thanks for sending (I think). C
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: April 14, 2010 10:40 AM To: Knight, Francesca; Busto, Vince Cc: Bennett, Timothy A ENV:EX; Stoddard, Erin M ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
Wow, I hadnt noticed that you & Vince were not provided copies of Revision C. It seems that the proponent has not got the message that the monitoring plan will be referenced by both MOE & DFO. There is alot in Revision C that will benefit from your review...as you can see from my review, I did not address Water Quality or macroinvert stuff, and I dont believe anyone else from MOE will be providing that input. Erin will be providing review of the fish stuff shortly. Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, April 14, 2010 10:33 AM To: Babakaiff, Scott C ENV:EX Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Hey Scott, I was planning on writing my comments this week; could you send me revision C please...looks like my latest is revision B, thanks! C
Page 199 FNR-2011-00265 Part 2
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thursday, March 18, 2010 4:41 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Friday, May 14, 2010 3:53 PM Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX RE: RESPONSE REQUIRED: Ashlu ramping and fish ladder operations
Immediateresponse:IappreciatethatRoberthassummarizedthevariousfindings&efforts fromthevariousbiologiststoaddressyourenquiry,butIwouldprefertoseethe detailedreports(ie.theEcofishworkconfirmingthatthepresentrampingratesdonot createchangesinstageinexcessof2.5cm/houratthegaugeimmediatelydownstreamof theintake)notsimplyRobert'sinterpretationofthatwork. OriginalMessage From:Bennett,TimothyAENV:EX Sent:Friday,May14,20103:37PM To:Stoddard,ErinMENV:EX;Babakaiff,ScottCENV:EX Subject:FW:RESPONSEREQUIRED:Ashlurampingandfishladderoperations Importance:High Yourthoughts,gentlemen? TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment 10470152Street,Surrey,BCV3R0Y3 Ph.(604)5825227Fx.(604)5825235 Timothy.Bennett@gov.bc.ca OriginalMessage From:RobertKulka[mailto:RKulka@innergex.com] Sent:Friday,May14,20102:49PM To:Bennett,TimothyAENV:EX Cc:Knight,Francesca;vince.busto@dfompo.gc.ca;AdamLewis;MikeNelson;Richard Blanchet;FrancoisHebert Subject:RE:RESPONSEREQUIRED:Ashlurampingandfishladderoperations Importance:High HiTim, Attachedisourreplytoyouremail.Pleasecontactmeifyouhaveanyquestions. Regards, Robert ________________________________________ ROBERTJ.KULKA,P.Eng.,Dipl.Wirt.Ing. ConstructionManager InnergexnergierenouvelableInnergexRenewableEnergy Suite30338FellAvenue NorthVancouver,BritishColumbiaV7P3S2 Phone:604984.8600*Fax:604984.8699 Cell.:778227.0434 OriginalMessage
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From:Bennett,TimothyAENV:EX[mailto:Timothy.Bennett@gov.bc.ca] Sent:Thursday,May13,20107:21AM To:RobertKulka;RichardBlanchet Cc:Knight,Francesca;vince.busto@dfompo.gc.ca Subject:RESPONSEREQUIRED:Ashlurampingandfishladderoperations Importance:High <mailto:s@ecofishresearch.com> HiRobert, ThankyouforyouremailofMay9,2010regardingtheobservednoncompliancewith specifiedrampingratesattheAshlufacility,onMay8,2010. Iunderstandthatrampingratesonthatdate(May8,2010)werehigherthanDFOguidance of2.5cm/hour,andalsoresultedinfishstrandingandsalvageactivities.Youare remindedthatyourauthorization(Leave)tocontinuecommissioningactivities,issuedby theIndependentEngineeranddatedApril30,2010,wassubjecttoanumberofconditions including: 1)...toprovideaworkplanandscheduleforfacility(e.g.,bypassspillway) modificationstopreventfishstrandinginthebypassweirspillway,tothesatisfaction oftheAssistantRegionalWaterManager,within30days.Intheinterim,commissioning activitiesshouldbeundertakeninsuchawayastominimizethepotentialforfish stranding;and, 2)Commissioningactivitiesmustnotresultinrampingrateswithinthestreamthat exceedDFOguidance,i.e.,DFO'sdefaulthourlyrampingratesof2.5cm/hr. Itdoesnotcurrentlyappearthatthesetwoconditionshavebeenadheredto.Ialso understandthattherewilllikelybefurther,imminentrampingeventsasadditionalflows arereleasedforkayakersinMay,asrequiredbyyourTransportCanadaApproval. Youareherebyadvisedthatyourauthorizationtocontinuecommissioningwillberevoked ifduecareisnotundertakentominimizethepotentialforfishstrandingand/orthe specifiedrampingratesarenotadheredto. IalsounderstandthattheEnvironmentalMonitor(EM)fortheprojecthasraisedconcerns regardingfishpassageviathefishladderintheprevioustwoweeklyenvironmental monitoringreports(#201004,20105),andthesehavenotbeenaddressedtodate.Those concernspertaintotheconfigurationoftheIFRpipeoutletandfishladderentranceway, andseveralproblemsarebelievedtocontributetothissituation,including: theIFRpipereleasesflowsalmostontopofthefishladderentrance,likely creatingahydraulicbarrier/deterrentforfishtryingtoenterthefishladder; theentrancetothefishladderisnotwelldesignedtoencouragefishtoenter; Cascadehasrecommendedriprapplacedattheentrancetocreatemoreofadefinedchannel thatcanguidefishtotheentrance;and,
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anallegedreductionofflowsinthefishladderduringlowriverflows,whenall oftherequiredIFRisbeingconveyedviatheIFRpipeandtheproponent/operatorhas concernsoverlosingtoomuchwaterthroughthefishladder. DFOstaffhaveindicatedthatthisisprimespawningseasontimeforrainbowtomigrateup abovetheheadpondforspawning;andthat,currently,thisisnotpossible.Adequate flowsneedtopassthroughthefishladder,andpassinglesswaterthroughtheIFRpipe mayreducetheeffectofthehydraulicbarrier/deterrent.Youmayconsiderreducing (redirecting)IFRflowsfromtheIFRpipesuchthatthefishladdercanreceivemoreflow. Theladdershouldbeabouthalffull,andtheEMwillbeabletodirectproponentasto adequatevolume.Alternatively,thefishladderinletcouldhavetobereconfigured relativetothelocationoftheIFRpipeoutlet.Finally,DFOhassuggestedthat dependingonwhetherthefishladderinletrequiressubstantialrefittingtoavoidtheIFR flows,theinletmayneedtobeenhancedwithripraptobetterguidefishthefishladder entrance. Basedontheabove,Iamrequestingthatyoucompletethefollowingwithin48hoursof thisemail(i.e.,priortotheendofday,onFridayMay15,2010): 1)ProvidewrittenconfirmationtotheAssistantRegionalWaterManagerofyour understandingofyourrequirementtoundertakeplantcommissioningandflowdiversionsin suchawayastoensurethatfisharenotstrandedandrampingratesdonotexceed2.5 cm/hour,andyourintenttoadheretothisrequirement; 2)ImplementinconsultationwiththeEM,andprovidedetailson,measuresto ensureandmonitorthatfishpassageviathefishladdercanoccur.Thesemeasurescould includephysicalmodificationsand/orreleaseofadditionalflows,ordiversionofflows fromtheIFRpipe,tothefishladder,insuchawaythatthenet,requiredIFRreleaseis accomplishedandfishpassageisnothindered. Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactme. Regards, TimBennett,P.Eng., AssistantRegionalWaterManager WaterStewardshipDivision
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, April 5, 2010 12:06 PM Mike Nelson; Bennett, Timothy A ENV:EX gsteeves@ameresco.com; Knight, Francesca RE: Inquiry re Ashlu IFR flows
Can compliance of the IFR be verified via provision of continuous streamflow data within the diversion reach from the past few months?
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Mon 05/04/2010 10:36 AM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Knight, Francesca Subject: RE: Inquiry re Ashlu IFR flows Tim, I am not aware of any non-compliances. When the head pond is full, the IFR is released automatically through the IFR pipe. Also, the head pond has been empty since March 1 due to cleaning of gravel from the tunnel; so 100% of the river was released last month. We've been taking weekly samples from the river and from the tunnel seepage for arsenic and related parameters. We'll be filing a report on that shortly. The plan is to refill the head pond either tomorrow of Wednesday, holding back a maximum of 10% of the Ashlu's flow and then start the tunnel flushing procedure according to the protocol. We'll resume weekly reporting during this work. Cheers, MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 - 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca -----Original Message----From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: April-05-10 10:14 AM To: Mike Nelson Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com Subject: RE: Inquiry re Ashlu IFR flows
Hi Mike, We've received inquiries regarding whether Ashlu is releasing its IFR requirement. Can you (or George) please confirm if you are aware of any non-compliances with the IFR requirement (i.e., dates when the plant may not have been releasing the required flows)? Also, can you please confirm the status of the plant? I understand it still undergoing commissioning (via George's latest extension), but how often are either of you or delegates onsite to monitor this? thanks, Tim Bennett
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From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Thu 25/03/2010 11:50 AM To: Bennett, Timothy A ENV:EX Subject: FW: 413 Ashlu water quality results
Don't know if you have been getting this chain or not - your name was spelled wrong - too many mms
Mike Nelson, R.P.Bio. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 - 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca <mailto:lnelson@cerg.ca> | www.cascade-environmental.ca <http://www.cascade-environmental.ca/>
From: Mike Nelson Sent: March-25-10 9:52 AM To: 'Knight, Francesca'; timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Nikl, Lee Cc: Christine Becker; Busto, Vince; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX; 'Robert Kulka' Subject: RE: 413 Ashlu water quality results
Chessy,, Further to our phone conversation this morning, please find attached the water quality measurements taken from the discharge of the tunnel, and from the roadside ditch (into which the discharge flowed at the time of sampling). Based on these results (arsenic concentration of 15.6 ppb (total) and 14.6 ppb (dissolved)) and our conversation, I have advised Robert Kulka that he can resume discharging the tunnel seepage water into the ditch. Water quality samples will be taken this afternoon, tomorrow morning, and on Monday to confirm arsenic levels. In addition, Innergex will install a board to direct the tributary flows into the main flows of the Ashlu, away from the shallow riffle along the right bank. This temporary measure will be removed when the tunnel seepage discharge cease in 7 - 10 days.
Water Quality samples were also taken yesterday from the tailrace, where the tunnel seepage has been directed since Tuesday. The results expected tomorrow. If the arsenic levels are less than 50 ppb, then the established protocol will be used for disposal; if the arsenic concentrations are higher than 50 pbb, then an appropriate disposal methodology will have to be developed. Cheers,
Mike Nelson, R.P.Bio. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 - 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3
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TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca <mailto:lnelson@cerg.ca> | www.cascade-environmental.ca <http://www.cascade-environmental.ca/>
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: March-23-10 9:22 AM To: Mike Nelson; timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Nikl, Lee Cc: Christine Becker; Busto, Vince; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX Subject: RE: 413 Ashlu water quality results
Hello everyone, Mike, thanks for taking the lead on reviewing the guidance in the water quality protocol... what you are citing below is my recollection. Given that the dissolved concentration is so high, and that this period of discharge coincides with fry emergence, I think the best course of action is to halt the discharge until Lee has a chance to work up a rationale / plan for handling this water. This may include some tox testing (rainbow trout and Daphnid, for example). I have no way of knowing what the total quantity of water for discharge would be, but Lee will be able to get a handle on that through talking with Robert and Mike. Let me know how you want to proceed. Chessy ________________________________
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: March 22, 2010 5:03 PM To: timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Knight, Francesca Cc: Christine Becker Subject: FW: 413 Ashlu water quality results Tim et al., During the commissioning exercises at their Ashlu facility, Innergex has been experiencing some issues with material in the tunnel becoming mobilized. They have drained the tunnel to inspect it and are releasing the approximately 10 l/s of water seeping from the tunnel into the roadside ditch (about 300m in length)that eventually flows into a tributary of the Ashlu and then the Ashlu itself. Water samples collected last week, and reported today indicate that arsenic levels are elevated (0.085 mg/l dissolved and 0.097 mg / total) in the seepage waters. The Golder water quality management plan to deal with this issues (November 8,
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2009), called for a 0.050 mg/l (50ug/l) to be adopted as the maximum discharge concentration. It also states that "in the event that there are minor exceedances of the 50 ug/l total arsenic limit, the dissolved arsenic concentrations should be evaluated by a qualified professional (QP) to determine if the arsenic concentration observed is appropriate for discharge". As the 50 ug/l level is being exceeded, we have suggested to Innergex that the seepage should be contained until further water quality sampling shows the concentrations have dropped to this value, or until they have the water quality results evaluated by Lee Nikl of Golder (or other QP they retain). Note that Robert Kulka (Innergex) has spoken to Lee Nikl about this matter, but as of yet I have not received anything in writing from Lee (likely tomorrow).
At present the water is not being contained, and is flowing as stated above; Innergex are reluctant to collect the waters in the tailrace, as the tailrace is being used to ventilate the ongoing works in the tunnel. The seepage waters may not be an issue, however, as the Ashlu's discharge is now approximately 15 cms, which would amount to a dilution ratio of about 1,500 to 1. If you would like us to take further steps at this time, please advise. Cheers,
Mike Nelson, R.P.Bio. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 - 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca <mailto:lnelson@cerg.ca> | www.cascade-environmental.ca <http://www.cascade-environmental.ca/>
From: Christine Becker Sent: March-22-10 12:43 PM To: 'Robert Kulka' Cc: Mike Nelson; 'Knight, Francesca' Subject: 413 Ashlu water quality results
Hi Robert, In my last email I attached the sediment pond sampling results as well as the water quality results for the tunnel seepage at the portal. I have reviewed the water quality results from the portal ditch and it looks like there is an issue with dissolved arsenic (0.085 mg/L), which exceeds the WQ guidelines of 0.005 mg/L. I repeated the sampling last week to include a location at the outlet of the ditch as well as a hydrocarbon analysis.
I would strongly suggest that you pump the seepage to a contained location until we receive the most recent sample results (expected this week) to prevent elevated arsenic levels from reaching Ashlu Creek. Chessy, do you have any further comments at this time?
Regards,
christine becker (nee cunliffe). B.sc., b.i.t. Cascade Environmental Resource Group Ltd.
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Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 - 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | FAX: 604 815-0904 cbecker@cerg.ca <mailto:lnelson@cerg.ca> | www.cascade-environmental.ca <http://www.cascade-environmental.ca/>
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From: Sent: To: Cc: Subject: Attachments: Rochetta, Steve J ENV:EX Tuesday, April 6, 2010 9:16 AM McGuire, Jennifer ENV:EX; Bennett, Timothy A ENV:EX; Barrett, Scott ENV:EX Babakaiff, Scott C ENV:EX; George, Greg ENV:EX; Stoddard, Erin M ENV:EX; Nietvelt, Cliff ENV:EX FW: CAMPBELL'S BIG LIE - PREPARE FOR SHOCK AND ANGER! image001.jpg; image002.jpg; DSC05484.JPG
ThiswasforwardedtomebytheSquamishStreamkeepers,pleasenotethepicturesoftheAshlu. MOEmayhavetoanswersomequestionsregardingthisissue.Iwasouttothissite3weeksagoandtheweirwasnt installed,nowthereappearstobeverylittle(no)waterinthereachbelowtheintake.Thissectionhasrainbowtrout andcharalsosalmoninthelowestpartofthereach.Itwouldbeverydifficultforfishoranyotherwaterusing creaturetosurvivethesewaterlevels. Cheers,Steve

S22 From: Sent: Wednesday, March 31, 2010 9:05 PM S22 Cc: Sub BIG LIE - PREPARE FOR SHOCK AND ANGER!
Begin forwarded message:
----- Or ----Fro S22 To: S22 Sen rch 31, 2010 2:53 PM Subject: Fw: cAMPBELL'S BIG LIE - PREPARE FOR SHOCK AND ANGER!
RAFE HERE What you will see with the attachments to this note will, I guarantee, outrage you!
The premier and his pals in the energy theft game going on with so-called "run of river" projects, told us that no river would be ruined and that the fish would be safe. Courtesy of Tom Rankin of Save Our Rivers Society [www.saveourrivers.ca] the attached photos, recently taken, will show you just how deceitful how Campbell and his so-called Environment Minister are, for there is the Ashlu near Squamish showing the amount of water coming into the river from the tunnel. using the original channel between the weir and the powerhouse
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A trickle! A bullhead couldn't survive in it! How many fish do you suppose can now reside in the Ashlu, once a gem? I don't, admittedly, have a long fuse but I can't remember when I was so sad and angry as when I saw these pictures. Please pass this on and asked recipients to do the same. and, when this government and the private power boys make their sweetheart deals, and piously tell us that this is "green power, let our cry be REMEMBER THE ASHLU!!!
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From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Tuesday, April 6, 2010 9:26 AM McGuire, Jennifer ENV:EX; Barrett, Scott ENV:EX FW: IFR flow data
FYI OriginalMessage From:RobertKulka[mailto:RKulka@innergex.com] Sent:Monday,April5,201011:01PM To:Bennett,TimothyAENV:EX;mnelson@cerg.ca;Babakaiff,ScottCENV:EX Cc:gsteeves@ameresco.com;Francesca.Knight@dfompo.gc.ca;Berardinucci,JuliaFENV:EX; RichardBlanchet Subject:Re:IFRflowdata HelloTim, IwillgotoAshlutomorrowandwilldownloadthedatafromthecontrolsystem.Itwill takemeafewhourstoconvertthedataandperformatleastsomepreliminaryquality control.Iwilltrymybesttoissuesomethingtomorrowafternoon.Itrustthat formattingandlayoutcouldbecompromisedinordertospeeduptheprocess. Regards, Robert SentusingBlackBerry OriginalMessage From:Bennett,TimothyAENV:EX<Timothy.Bennett@gov.bc.ca> To:MikeNelson<mnelson@cerg.ca>;Babakaiff,ScottCENV:EX<Scott.Babakaiff@gov.bc.ca>; RobertKulka CC:gsteeves@ameresco.com<gsteeves@ameresco.com>;Knight,Francesca <Francesca.Knight@dfompo.gc.ca>;Berardinucci,JuliaFENV:EX <Julia.Berardinucci@gov.bc.ca> Sent:TueApr0601:22:392010 Subject:RE:IFRflowdata HiMike,Robert; Thanksforfollowingupwiththis. Pleaseprovideallavailableflowdataassoonaspossible,andanexpectedtimelineasto whenwecouldreceivethisinformation. Pleasesendtoallrecipientsofthisemail. Regards, TimBennett AssistantRegionalWaterManager ________________________________
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From:MikeNelson[mailto:mnelson@cerg.ca] Sent:Mon05/04/20101:36PM To:Babakaiff,ScottCENV:EX;Bennett,TimothyAENV:EX;RobertKulka Cc:gsteeves@ameresco.com;Knight,Francesca Subject:RE:InquiryreAshluIFRflows Scott, Iwasafraidyouweregoingtosaythat(justkidding). Robert, Canyouprovidethedatatoallassoonasyouareable.I'lllookatthedataandgetto everyonewithabriefsummaryreport. Cheers, MikeNelson,R.P.Bio. Principal CascadeEnvironmentalResourceGroupLtd. WhistlerandSquamish,BC|Whitehorse,YT|SanDiego,CA Unit203380262ndAvenue|Squamish|BC|Canada|V8B0C3 TEL:6048150901|CELL:6048159973|FAX:6048150904 mnelson@cerg.ca<mailto:lnelson@cerg.ca>|www.cascadeenvironmental.ca <http://www.cascadeenvironmental.ca/>
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From: Sent: To: Cc: Subject: Ptolemy, Ron ENV:EX 2010 11:17 AM
S22 S22
Ptolemy, Ron
FW: Ashlu Creek Aquatic Environmental Assessment
S22
ItsbeenquiteawhilesinceIwas(partly)involvedwiththisIPPproject.Asyoucanappreciatefrommyinitial reactiontotheaquaticassessmentbelow,Ihadnofaithintheassessmentmethodsorconclusions.Iamnot surprisedatthepresentoutcomeeither. Bestregards, Ronald A. Ptolemy, RPBio

Rivers Biologist/Instream Flow Specialist, Fisheries Science Section Ecosystems Branch Ministry of Environment PO Box 9338 Stn Prov Govt Victoria, BC V8W 9M1 Location: 4th Floor, 2975 Jutland Road, Victoria Phone: 250-356-7054 Fax: 250-387-9750 e-mail: :Ron.Ptolemy@gov.bc.ca

S22 From: Ron Ptolemy Sent: Friday, August 29, 2003 11:41 PM To: Lee Dutta (E-mail) Cc: Ptolemy, Ron ENV:EX Subject: FW: Ashlu Creek Aquatic Environmental Assessment
Lee: I've just scanned through the document you forwarded and have concluded that it lacks proper science in its findings and recommendations. I've also checked some of the key references (Muchow-Richardson on benthic invertebrates) and the consultants have taken great liberty in suggesting intermittent streams with occasional zero flows are beneficial. This is not what the paper suggests and it is hardly applicable to much larger streams (Ashlu) than those described in the Muchow publication (not peer reviewed). I don't trust the results and have no faith in the methods used to describe fish abundance for each reach. The results are at variance to other more thorough stock assessments in the Ashlu. The assessment report does not provide quantitative evidence of why a particular flow should work to sustain fish habitat. Results seem to qualitative with no stated, acceptable methodology. Ron
-----Original Message----From: Ptolemy, Ron WLAP:EX [mailto:Ron.Ptolemy@gems2.gov.bc.ca] Se 003 11:39 AM S22 To: Subject: FW: Ashlu Creek Aquatic Environmental Assessment
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-----Original Message----From: DuttaL@pac.dfo-mpo.gc.ca [mailto:DuttaL@pac.dfo-mpo.gc.ca] Sent: August 29, 2003 11:34 AM To: Ptolemy, Ron WLAP:EX Cc: Willcox, Michael WLAP:EX Subject: FW: Ashlu Creek Aquatic Environmental Assessment
-----Original Message----From: Stephanie Eagen [mailto:seagen@synex.com] Sent: August 29, 2003 11:09 AM To: DuttaL@pac.dfo-mpo.gc.ca Cc: Tom Cleugh Subject: RE: Ashlu Creek Aquatic Environmental Assessment Lee: as requested. Stephanie -----Original Message----From: DuttaL@pac.dfo-mpo.gc.ca [mailto:DuttaL@pac.dfo-mpo.gc.ca] Sent: Friday, August 29, 2003 11:11 AM To: Seagan@synex.com Subject: Ashlu Requesting electronic version of environmental studies. Have a nice weekend, Stephane.
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From: Sent: To: Subject: Hey Tim, Your request is prudent. I reckon the key issue with the instream flow data provided is QA/QC, specifically the derivation of streamflow estimates. Data provided by Robert yesterday implies that the discharge data was downloaded directly from a data logger, when it was obviously stage data that was subsequently converted to discharge by means of some formula. I'd suggest that Robert provide the raw data (ie. stage data) downloaded from the data logger, and the methods followed to develop streamflow estimates. Scott Babakaiff, Scott C ENV:EX Wednesday, April 7, 2010 11:59 AM Bennett, Timothy A ENV:EX RE: IFR flow data
From: Bennett, Timothy A ENV:EX Sent: Wed 07/04/2010 10:58 AM To: 'Mike Nelson'; Babakaiff, Scott C ENV:EX Cc: 'gsteeves@ameresco.com'; 'Francesca.Knight@dfo-mpo.gc.ca'; Berardinucci, Julia F ENV:EX; 'Richard Blanchet'; 'Francois Hebert'; 'Robert Kulka' Subject: RE: IFR flow data
HiMike,Robert: Couldyouconfirmifthereis(andifsoprovide)additionaldatatocovertheentireperiodofcommissioning,andthe periodsoftime(withinthecommissioningphase,whichcommencedlastyear)inwhichflowswerediverted?(e.g., forheadpondfilling,etc..) Thankyou. TimothyBennett,M.Sc.,P.Eng. AssistantRegionalWaterManager

WaterStewardshipDivision MinistryofEnvironment
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Wednesday, April 7, 2010 10:39 AM To: Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX Cc: gsteeves@ameresco.com; Francesca.Knight@dfo-mpo.gc.ca; Berardinucci, Julia F ENV:EX; Richard Blanchet; Francois Hebert; Robert Kulka Subject: RE: IFR flow data
TimandScott, IhavereviewedthechartsanddataprovidedbyRobert,andtheIFRwaseithermaintained orexceededforFebruaryandMarch2010attheAshluhydrofacility. Cheers, MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3
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TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
OriginalMessage From:RobertKulka[mailto:RKulka@innergex.com] Sent:April07109:41AM To:Timothy.Bennett@gov.bc.ca;MikeNelson;Scott.Babakaiff@gov.bc.ca Cc:gsteeves@ameresco.com;Francesca.Knight@dfompo.gc.ca;Julia.Berardinucci@gov.bc.ca; RichardBlanchet;FrancoisHebert Subject:RE:IFRflowdata HelloTim, AttachedaretwofileswithflowdataforAshluasperyourrequest.Iputintheminimum IFRof2.42cmsasabenchmark.PleasecontactmeifyouhaveanyquestionsbutIneedto advisethatIamontheroadforthenextthreedaysandthereforemaynotbeableto respondquickly. Regards, Robert ________________________________________ ROBERTJ.KULKA,P.Eng.,Dipl.Wirt.Ing. ConstructionManager InnergexnergierenouvelableInnergexRenewableEnergy Suite30338FellAvenue NorthVancouver,BritishColumbiaV7P3S2 Phone:604984.8600Fax:604984.8699 Cell.:778227.0434 OriginalMessage From:RobertKulka Sent:Monday,April05,201011:01PM To:'Timothy.Bennett@gov.bc.ca';'mnelson@cerg.ca';'Scott.Babakaiff@gov.bc.ca' Cc:'gsteeves@ameresco.com';'Francesca.Knight@dfompo.gc.ca'; 'Julia.Berardinucci@gov.bc.ca';RichardBlanchet Subject:Re:IFRflowdata HelloTim, IwillgotoAshlutomorrowandwilldownloadthedatafromthecontrolsystem.Itwill takemeafewhourstoconvertthedataandperformatleastsomepreliminaryquality control.Iwilltrymybesttoissuesomethingtomorrowafternoon.Itrustthat formattingandlayoutcouldbecompromisedinordertospeeduptheprocess. Regards, Robert SentusingBlackBerry OriginalMessage From:Bennett,TimothyAENV:EX<Timothy.Bennett@gov.bc.ca> To:MikeNelson<mnelson@cerg.ca>;Babakaiff,ScottCENV:EX<Scott.Babakaiff@gov.bc.ca>; RobertKulka CC:gsteeves@ameresco.com<gsteeves@ameresco.com>;Knight,Francesca <Francesca.Knight@dfompo.gc.ca>;Berardinucci,JuliaFENV:EX <Julia.Berardinucci@gov.bc.ca> Sent:TueApr0601:22:392010
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Subject:RE:IFRflowdata HiMike,Robert; Thanksforfollowingupwiththis. Pleaseprovideallavailableflowdataassoonaspossible,andanexpectedtimelineasto whenwecouldreceivethisinformation. Pleasesendtoallrecipientsofthisemail. Regards, TimBennett AssistantRegionalWaterManager ________________________________ From:MikeNelson[mailto:mnelson@cerg.ca] Sent:Mon05/04/20101:36PM To:Babakaiff,ScottCENV:EX;Bennett,TimothyAENV:EX;RobertKulka Cc:gsteeves@ameresco.com;Knight,Francesca Subject:RE:InquiryreAshluIFRflows Scott, Iwasafraidyouweregoingtosaythat(justkidding). Robert, Canyouprovidethedatatoallassoonasyouareable.I'lllookatthedataandgetto everyonewithabriefsummaryreport. Cheers, MikeNelson,R.P.Bio. Principal CascadeEnvironmentalResourceGroupLtd. WhistlerandSquamish,BC|Whitehorse,YT|SanDiego,CA Unit203380262ndAvenue|Squamish|BC|Canada|V8B0C3 TEL:6048150901|CELL:6048159973|FAX:6048150904 mnelson@cerg.ca<mailto:lnelson@cerg.ca>|www.cascadeenvironmental.ca <http://www.cascadeenvironmental.ca/>
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From: Sent: To: Cc: Subject: Attachments: Nikl, Lee [Lee_Nikl@golder.com] Friday, April 9, 2010 5:05 PM Robert Kulka; Francesca.Knight@dfo-mpo.gc.ca Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Francois Hebert; Brian Patjas; Steve Moir RE: ALGAL TOXICITY TESTS image001.jpg

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BasedontheWaterQualityManagementPlan(November2009)andsupplementalTechMemo(today)Iplanthe following(withMikeNelsoninsupportofthisapproach): NeutralizePHvalueoftunnelflushwatercurrentlycontainedinthetailracebyuseofCO2bubblerto9.0orless (startedat3pm) Dischargetunnelflushwateratflowofapproximately0.02cmsintocreek;currentlycreekflowisapproximately 10cms:theobtaineddilutionratioistherefore1:500.Requiredtimetodischargeisapproximately12hours; Commencepenstock/tunnelfilling(at10%ofavailableflowattheintake:expectedduration36hours).Take sampleofnewpenstock/tunnelwater,rushtoVancouverwithexpectedresultstomorrow(Saturday),say 2pm.Commencediversion/operationsubjecttoresultofthissample,completionoftunnelfilling,completion oftailracedraining,andofcourseavailableflowsattheintake;mostlikelyallthiscouldfalltogetherSundayin theam. FYI:HeadpondfillingcommencedyesterdaymorningandisongoingwithCascadebeingpresentonsite.Headpond isnowapproximately70%full. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying
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of this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work product may not be relied upon.
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From: Sent: To: Cc: Subject: Attachments: Nikl, Lee [Lee_Nikl@golder.com] Friday, April 9, 2010 5:05 PM Robert Kulka; Francesca.Knight@dfo-mpo.gc.ca Mike Nelson; Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Richard Blanchet; Francois Hebert; Brian Patjas; Steve Moir RE: ALGAL TOXICITY TESTS image001.jpg

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BasedontheWaterQualityManagementPlan(November2009)andsupplementalTechMemo(today)Iplanthe following(withMikeNelsoninsupportofthisapproach): NeutralizePHvalueoftunnelflushwatercurrentlycontainedinthetailracebyuseofCO2bubblerto9.0orless (startedat3pm) Dischargetunnelflushwateratflowofapproximately0.02cmsintocreek;currentlycreekflowisapproximately 10cms:theobtaineddilutionratioistherefore1:500.Requiredtimetodischargeisapproximately12hours; Commencepenstock/tunnelfilling(at10%ofavailableflowattheintake:expectedduration36hours).Take sampleofnewpenstock/tunnelwater,rushtoVancouverwithexpectedresultstomorrow(Saturday),say 2pm.Commencediversion/operationsubjecttoresultofthissample,completionoftunnelfilling,completion oftailracedraining,andofcourseavailableflowsattheintake;mostlikelyallthiscouldfalltogetherSundayin theam. FYI:HeadpondfillingcommencedyesterdaymorningandisongoingwithCascadebeingpresentonsite.Headpond isnowapproximately70%full. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying
Page 230 FNR-2011-00265 Part 2
of this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work product may not be relied upon.
Page 231 FNR-2011-00265 Part 2

From: Sent: To: Subject: Attachments: Bennett, Timothy A ENV:EX Friday, January 29, 2010 12:04 PM Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX FW: Ashlu Intake Fish Salvage Jan 21, 2010 100125 Fish Salvage Results.pdf
FYI..
From: Ken McNamara [mailto:kmcnamara@cerg.ca] Sent: Tuesday, January 26, 2010 9:31 AM To: Knight, Francesca; gsteeves@ameresco.com; Bennett, Timothy A ENV:EX; Robert Kulka; rblanchet@innergex.com; vince.busto@dfo-mpo.gc.ca Cc: Christine Becker; Mike Nelson Subject: Ashlu Intake Fish Salvage Jan 21, 2010
HelloAll, PleasefindattachedtheresultsforafishsalvagecarriedoutbyCERGonJan21,2010attheAshluIntake.The salvagewasdoneonthelargestpoolbelowtheobermeyerweirwerefishwereobseved. Regards Ken

KEN MC NAMARA BSC | ENVIRONMENTAL TECHNICIAN
Cascade Environmental Resource Group Ltd. Squamish & Whistler, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-3231 | FAX: 604 815-0904 kmcnamara@cerg.ca | www.cascade-environmental.ca
Page 232 FNR-2011-00265 Part 2

From: Sent: To: Subject: Daniels, Kate EMPR:EX Tuesday, March 16, 2010 11:22 AM Babakaiff, Scott C ENV:EX FW: Soo ROR
HiScott,OliviaforwardedmeyouremailbutIamabiutmystifiedwhenIgotothelink.ImlookingforAshluany hintsonwhatnumberitmightbe?
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Thursday, August 6, 2009 3:17 PM To: Chang, Olivia Y EMPR:EX Subject: RE: Soo ROR
The short answer is that yes, you could get copies of the water licenses, but there are a couple problems: 1. They are not available in a digital format that is easily transferrable: one has to find, download and print each page of each water license separately; 2. The information that is likely of greatest interest to the legislators (ie. minimum instream flows required for protection of ecosystems, obligations for biological monitoring, etc.) is rarely included in the water licenses. Rather, such information is typically included in supplemental documents that the water license references...but these supplemental documents are not available online, and are often not available in a digital format (ie. only in hardcopy in a file); 3. Many of the files (containing the hardcopies referenced in #2) are not stored in the Regional MOE offices, and some are incomplete due to all the changes in administrative responibility (Water Management to Land&Water BC to Water Stewardship Division) in recent years.
If you wanna see what the water licenses look like, use this link (http://a100.gov.bc.ca/pub/wtrwhse/water_licences.input) to search for the water license number (for instance, enter Rutherford Creek under stream name) for any IPP of interest, and then use this link (ftp://ftp.env.gov.bc.ca/pub/outgoing/lic_images/) to find the file that contains the water license of
lic04A01.tif lic04B01.tif
interest (e.g. 117388 for Rutherford Creek). And this is what youll find:
lic04C01.tif lic06A01.tif tec04A01.tif tec04B01.tif tec04C01.tif tec04D01.tif
Probably not the answer you were hoping for, but Im just the messenger! Scott
_____________________________________________ From: Chang, Olivia Y EMPR:EX Sent: Thursday, August 6, 2009 2:53 PM To: Babakaiff, Scott C ENV:EX Subject: RE: Soo ROR
Scott,morerequests.CanIgetcopiesofthewaterlicenceforsomeoftheIPPswewillbevisiting?Mikethinksit wouldbegoodtohavetheminourpackageforthelegislatorssinceitisthemajorregulatorydocument.
1
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O
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Wednesday, August 5, 2009 4:08 PM To: Chang, Olivia Y EMPR:EX Subject: RE: Soo ROR
Well, the extreme low flows typically occur in Dec/Jan (when it will truly look dry). This year, most of the seasonal snowpack has already melted, so Id expect flows to diminish at a fairly rapid rate in August & September until the seasonal rains begin in early autumn. A more immediate concern (in terms of the proposed tour) will be the sediment removal that is likely to begin within the next few weeks. The exact start date depends on the Federal Dept of Fisheries & Oceans providing approval to do so; I understand the approval is expected shortly. Once approval is granted, alot of backhoes & dumptrucks will immediately begin to excavating thousands of cubic meters of sediment that have accumulated in the headpond (immediately upstream of the dam). It wont be pretty, and will likely persist from mid-August to mid-September. Scott
_____________________________________________ From: Chang, Olivia Y EMPR:EX Sent: Wednesday, August 5, 2009 3:51 PM To: Babakaiff, Scott C ENV:EX Subject: Soo ROR
Scott, IrememberyousayingthattheSoowillbedryinthedistantfuture.Whenwasthat?MidAug?LateAug? Thanks!

OliviaChang A/ExecutiveDirector,Minister'sCouncilonMineralExplorationandMining BCMinistryofEnergy,MinesandPetroleumResources 7thfloor1675DouglasSt|Victoria,BC|V8W9N3 direct1.250.952.0485|mobile1.250.514.8061
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From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Tuesday, March 16, 2010 11:48 AM Daniels, Kate EMPR:EX RE: Soo ROR
C102203 (http://a100.gov.bc.ca/pub/wtrwhse/water_licences.output?p_Source_Name=ashlu&p_Licence_No=&p _Priority_Issue_Date=&p_POD_Purpose=&chk_Appurtenant_Land=&p_POD_Qty_Equality=%3D&p_P OD_Qty=&chk_Licence_Comments=&chk_POD_Qty_Flag_Desc=&chk_Date_Updated=&p_Licensee=& p_Dist_Prec_Name=&chk_Client_No=&p_Client_No=&chk_Points_Code=&p_Points_Code=&chk_File _No=&p_File_No=&p_WR_Map=&chk_PCL_No=&p_PCL_No=&chk_Watershed=&p_Watershed=&p_ Export=Screen) FYI, Ashlus water license is old, and doesnt include the sort of detail common in current water licenses...there may be little of interest to you in the water license. Scott
_____________________________________________ From: Daniels, Kate EMPR:EX Sent: Tuesday, March 16, 2010 11:22 AM To: Babakaiff, Scott C ENV:EX Subject: FW: Soo ROR
HiScott,OliviaforwardedmeyouremailbutIamabiutmystifiedwhenIgotothelink.ImlookingforAshluany hintsonwhatnumberitmightbe?
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Thursday, August 6, 2009 3:17 PM To: Chang, Olivia Y EMPR:EX Subject: RE: Soo ROR
The short answer is that yes, you could get copies of the water licenses, but there are a couple problems: 1. They are not available in a digital format that is easily transferrable: one has to find, download and print each page of each water license separately; 2. The information that is likely of greatest interest to the legislators (ie. minimum instream flows required for protection of ecosystems, obligations for biological monitoring, etc.) is rarely included in the water licenses. Rather, such information is typically included in supplemental documents that the water license references...but these supplemental documents are not available online, and are often not available in a digital format (ie. only in hardcopy in a file); 3. Many of the files (containing the hardcopies referenced in #2) are not stored in the Regional MOE offices, and some are incomplete due to all the changes in administrative responibility (Water Management to Land&Water BC to Water Stewardship Division) in recent years.
If you wanna see what the water licenses look like, use this link (http://a100.gov.bc.ca/pub/wtrwhse/water_licences.input) to search for the water license number (for instance, enter Rutherford Creek under stream name) for any IPP of interest, and then use this link (ftp://ftp.env.gov.bc.ca/pub/outgoing/lic_images/) to find the file that contains the water license of interest (e.g. 117388 for Rutherford Creek). And this is what youll find: << File: lic04A01.tif >> << File: lic04B01.tif >> << File: lic04C01.tif >> << File: lic06A01.tif >> << File: tec04A01.tif >> << File: tec04B01.tif >> << File: tec04C01.tif >> << File: tec04D01.tif >>
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Page 235 FNR-2011-00265 Part 2
Probably not the answer you were hoping for, but Im just the messenger! Scott
_____________________________________________ From: Chang, Olivia Y EMPR:EX Sent: Thursday, August 6, 2009 2:53 PM To: Babakaiff, Scott C ENV:EX Subject: RE: Soo ROR
Scott,morerequests.CanIgetcopiesofthewaterlicenceforsomeoftheIPPswewillbevisiting?Mikethinksit wouldbegoodtohavetheminourpackageforthelegislatorssinceitisthemajorregulatorydocument. O
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Wednesday, August 5, 2009 4:08 PM To: Chang, Olivia Y EMPR:EX Subject: RE: Soo ROR
Well, the extreme low flows typically occur in Dec/Jan (when it will truly look dry). This year, most of the seasonal snowpack has already melted, so Id expect flows to diminish at a fairly rapid rate in August & September until the seasonal rains begin in early autumn. A more immediate concern (in terms of the proposed tour) will be the sediment removal that is likely to begin within the next few weeks. The exact start date depends on the Federal Dept of Fisheries & Oceans providing approval to do so; I understand the approval is expected shortly. Once approval is granted, alot of backhoes & dumptrucks will immediately begin to excavating thousands of cubic meters of sediment that have accumulated in the headpond (immediately upstream of the dam). It wont be pretty, and will likely persist from mid-August to mid-September. Scott
_____________________________________________ From: Chang, Olivia Y EMPR:EX Sent: Wednesday, August 5, 2009 3:51 PM To: Babakaiff, Scott C ENV:EX Subject: Soo ROR
Scott, IrememberyousayingthattheSoowillbedryinthedistantfuture.Whenwasthat?MidAug?LateAug? Thanks!

OliviaChang A/ExecutiveDirector,Minister'sCouncilonMineralExplorationandMining BCMinistryofEnergy,MinesandPetroleumResources 7thfloor1675DouglasSt|Victoria,BC|V8W9N3 direct1.250.952.0485|mobile1.250.514.8061
2
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From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Friday, March 19, 2010 8:25 AM Bennett, Timothy A ENV:EX FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan image001.jpg; RE: Ashlu long-term monitoirng
"Recent review" #2 of 2, as promised.
From: Babakaiff, Scott C ENV:EX Sent: Fri 15/01/2010 11:52 AM To: Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Willcox, Michael ENV:EX; Vince.Busto@dfo-mpo.gc.ca; Francesca.Knight@dfompo.gc.ca Subject: 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 in two emails dated January 9 & 12 2010: 1. Ashlu Creek Green Power Hydroelectric Project: Response to Comments on Operations Environmental 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 as Kulka (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 this review as NHCL (2009); 3. Ashlu Creek Flow Monitoring During Ramping prepared by Cascade Environmental Resource Group Ltd for Innergex Renewable Energy Inc, dated December 14 2009, 6 pp. Referenced hereafter 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 2010 email); I was not provided the opportunity to review the proposed ramping work prior to its completion, 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) interchangeably. My review of Kulka (2010), NHCL (2009) and CERG (2009) indicates three general points of concern:
1. Inconsistent IFR provision, with a reasonable likelihood of non-compliance: NHCL
(2009) undertook a series of measurements at the outlet of the IFR pipe, clearly indicating that inadequate delivery of IFR from the pipe can be triggered by accumulations of sediment and LWD in the approach channel. The issue of insufficient IFR provision was resolved once the operators "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 also warn that this requires a "well maintained IFR system". NCHL (2009) suggests that IFR inlet gate could also be operated to manage the IFR release, but warn that "Due to the interaction between the trashrack, inlet gate, and pipe entrance, if is difficult to calculate precise operation of the gate"
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2. Commitments made in Kulka (2010) regarding an imminent revision to the OEMP do not address all concerns identified in MOE reviews of previous OEMP drafts.
Kulka (2010) proposes that the OEMP (Revision B dated November 26 2009) recently reviewed by MOE is based on the Monitoring Plan previously (May 18 2009) presented to DFO and indicate that another version (a revision) will incorporate the comments presented by MOE. Kulka (2010) suggests that the next OEMP revision will fully address MOE 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 [20012008] 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 of operation 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 MOE concerns 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 existing equipment & operational assumptions to meet compliance verification needs (see p. 5 of Kulka, 2010). 3. Ramping rates measured instream by CERG (2009) far exceed the DFO default rates
(2.5-5.0 cm/hr): detailed ramping rate study is proposed to be undertaken in late summer and/or early 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" (p.3 of Kulka, 2010). This seems like a reasonable strategy, except that CERG (2009) found that the ramping rates measured at the primary sites of interest resulting from the present operating strategy (zero to full flow diversion in 90 minutes, or 0.3 cms per minute) far exceeds the default rates typically accepted by DFO:
High discharge (10-30 cms) Ramp Up Ramp Down 12 cm/hr n/a (darkness) 24 cm/hr 23.2 cm/hr n/a (darkness) n/a (darkness) Low discharge (0-10 cms) Ramp Up Ramp Down 12 cm/hr 22 cm/hr (up to 240 cm/hr) 47 cm/hr Unknown 16-20 cm/hr n/a (darkness)
Site 1. Twin Bridges 2. Powerhouse 3. km 4.0 4. Mile 25 bridge
CERG (2009) refers to the operating strategy (0.3 cms per minute) as the 'prescribed' ramping rate, and similar language is used by the proponent in reference to the DFO Authorization, but I do agree with this assertion. Finally, it is apparent that the proponent does not believe they are responsible for delivering a single OEMP that meets both MOE and DFO needs, and they seem unaware that it is their responsibility to jointly address agency review comments & co-ordinate subsequent OEMP drafts (see p.6 of Kulka, 2010). As I described 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. I'll be away from the office the remainder of today and Monday, but am available to discuss this review later next week if need be. Scott
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From: Bennett, Timothy A ENV:EX Sent: Tuesday, January 12, 2010 11:20 AM To: Babakaiff, Scott C ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan
HiScott, Whenyouhaveachance,canyoupleaseletmeknowifyouhaveanycommentsonthematerialsenttousre:the AshluOEMP? Thanks!

From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Saturday, January 9, 2010 1:46 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson; Mike Nelson Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Hi Tim, Please find attached our response to your comments provided in underneath email. I will try to call you early next week to discuss a path forward, including overall timing and LTC commissioning and operation. Regards and happy New Year, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: Friday, December 18, 2009 3:12 PM To: Robert Kulka Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk
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Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental 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. StagedischargeratingcurvestheOEMPcommitstocollectingaminimumofthreedischarge 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.Interms ofdatacollection&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. Developmentoframpingrates:Section12.2oftheOEMPproposesthattherampingratesshall notexceed29.0cmsper90minutes.Thisratewillbeestablishedduringthecommissioningprocess oftheplant,andmaybesubjecttodifferentflowconditionsinthecreek.Thisratewasbasedon thenaturalrampingratesthathavebeenhistoricallyobservedinAshluCreekoverseveralyears since1991....TheOEMPprovidessomedetailregardingproposedmethodsforestablishing rampingratesduringcommissioning,butIwouldsuggestthatsuchprotocol(andsuchinterimrates like29cmsper90minutes)shouldbeestablishedandscientificallyjustifiedbyanexperienced professional,withreferencetoestablishedagencycriteria(e.g.DFOsdefaulthourlyrampingrates of2.5cm&5.0cmforfry&juveniles)orrecommendedguidelines.Finally,Isuggestthatthe commitmentwithinSection14oftheOEMPtosubmittherampingratereportsixmonthsafter commissioningrepresentsaninappropriaterisktofish&fishhabitatgiventherapidinterim rampingrateproposedandthefishvaluespresentinthediversionreach. 4. FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfor datacollectionoranalysisareproposed,despitethebibliographicreferenceinSection16ofthe OEMPtoHatfield&Lewis(2007).TheMOEESDinformationchecklistprovidedintheProvincialIPP GuidebookalsoprovidessupplementalguidanceforOEMPdevelopment.Itismyunderstanding thatthebaselinebiologicaldatacollectedinrecentyearsdidnotfollowanyparticularprotocol,but wasundertakenbyseveraldifferentbiologistsindifferentlocations,usingdifferentmethods.As
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such,itisimperativethatallbaselinedatabecollatedandassessedbyaprofessionalbiologistwith experienceintherelevantspecialization(ie.fisheriesbiology,macroinvertebratebiology),and compiledforassessmentregardingitsadequacyasabaselinetoassessfuturechangesthatmaybe attributabletooperationoftheIPPfacility.Onthisnote...
3. Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g.
durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,apriori agreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.)cannotbe objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis.In theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany diversioninducedchangesinthesebiologicalresponsevariables. 4. DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith textinthebodyoftheOEMP.Forinstance,page3oftheOEMPclearlystates:InthecaseoftheAshlu 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. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated. Forinstance: 1. installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentof 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;
5.
IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE? Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff. Regards,

From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly
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Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management 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 any questions. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Page 243 FNR-2011-00265 Part 2

From: Sent: To: Cc: Subject: Attachments: Babakaiff, Scott C ENV:EX Friday, January 8, 2010 8:28 AM 'Knight, Francesca'; Bennett, Timothy A ENV:EX Stoddard, Erin M ENV:EX; 'Busto, Vince' RE: Ashlu long-term monitoirng 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 the review agencies at the moment. In the process of reviewing the OPP (v.4 dated November 24 2009), I discovered (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 & ongoing meetings & communications regarding IPP review issues. For the record, Chessy: I agree with your conclusions. The May 2009 plan developed by Cascade Environmental is lacking many critical elements of an appropriate monitoring Plan, including a power analysis 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 November 2009, and subsequently reviewed by MOE (see attached email from Tim Bennett, which was sent to the proponent a few weeks ago), was very different than the Plan submitted to DFO in May. It seems that this is not a matter of one version superceding another, but rather that the proponent has submitted different plans to DFO and MOE. I dont know whether the proponent has done this intentionally, believing that one Plan would meet the needs of DFOs Authorization, and the other Plan would address Water License requirements. Or perhaps the different reps for the Proponent (Kelly Boychuk & Robert Kulka) arent even aware that the two different plans exist. Regardless, it seems that action is required from MOE & DFO to ensure that the proponent is made aware that: 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:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, January 7, 2010 6:54 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: 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 the indicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusions regarding 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, which is useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise useless for telling us whether the diversion has influenced the fish population. In addition, there is no method for counting adult fish... just gee traps for the little guys.
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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 are some other short-comings related to methods, but the limited analysis is the biggie. In addition, there is of course nothing proposed for evaluating changes to community structure, but you all know that is my main concern with how invertebrates 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 we would be able to draw any meaningful conclusions about how the altered flow regime affected available habitat types.
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From: Sent: To: Cc: Subject: Attachments: Mike Nelson [mnelson@cerg.ca] Thursday, March 25, 2010 9:52 AM Knight, Francesca; timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Nikl, Lee Christine Becker; Busto, Vince; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX; Robert Kulka RE: 413 Ashlu water quality results 100325 Maxxam Results - B016606.pdf
Chessy,, Furthertoourphoneconversationthismorning,pleasefindattachedthewaterqualitymeasurementstakenfrom thedischargeofthetunnel,andfromtheroadsideditch(intowhichthedischargeflowedatthetimeofsampling). Basedontheseresults(arsenicconcentrationof15.6ppb(total)and14.6ppb(dissolved))andourconversation,I haveadvisedRobertKulkathathecanresumedischargingthetunnelseepagewaterintotheditch.Waterquality sampleswillbetakenthisafternoon,tomorrowmorning,andonMondaytoconfirmarseniclevels.Inaddition, InnergexwillinstallaboardtodirectthetributaryflowsintothemainflowsoftheAshlu,awayfromtheshallow rifflealongtherightbank.Thistemporarymeasurewillberemovedwhenthetunnelseepagedischargeceasein7 10days. WaterQualitysampleswerealsotakenyesterdayfromthetailrace,wherethetunnelseepagehasbeendirected sinceTuesday.Theresultsexpectedtomorrow.Ifthearseniclevelsarelessthan50ppb,thentheestablished protocolwillbeusedfordisposal;ifthearsenicconcentrationsarehigherthan50pbb,thenanappropriatedisposal methodologywillhavetobedeveloped. Cheers,
MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: March-23-10 9:22 AM To: Mike Nelson; timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Nikl, Lee Cc: Christine Becker; Busto, Vince; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX Subject: RE: 413 Ashlu water quality results
Hello everyone, Mike, thanks for taking the lead on reviewing the guidance in the water quality protocol... what you are citing below is my recollection. Given that the dissolved concentration is so high, and that this period of discharge coincides with
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fry emergence, I think the best course of action is to halt the discharge until Lee has a chance to work up a rationale / plan for handling this water. This may include some tox testing (rainbow trout and Daphnid, for example). I have no way of knowing what the total quantity of water for discharge would be, but Lee will be able to get a handle on that through talking with Robert and Mike. Let me know how you want to proceed. Chessy
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: March 22, 2010 5:03 PM To: timmothy.bennett@gov.bc.ca; gsteeves@ameresco.com; Knight, Francesca Cc: Christine Becker Subject: FW: 413 Ashlu water quality results
Timetal., DuringthecommissioningexercisesattheirAshlufacility,Innergexhasbeenexperiencingsomeissueswithmaterial inthetunnelbecomingmobilized.Theyhavedrainedthetunneltoinspectitandarereleasingtheapproximately10 l/sofwaterseepingfromthetunnelintotheroadsideditch(about300minlength)thateventuallyflowsintoa tributaryoftheAshluandthentheAshluitself.Watersamplescollectedlastweek,andreportedtodayindicatethat arseniclevelsareelevated(0.085mg/ldissolvedand0.097mg/total)intheseepagewaters.TheGolderwater qualitymanagementplantodealwiththisissues(November8,2009),calledfora0.050mg/l(50ug/l)tobeadopted asthemaximumdischargeconcentration.Italsostatesthatintheeventthatthereareminorexceedancesofthe 50ug/ltotalarseniclimit,thedissolvedarsenicconcentrationsshouldbeevaluatedbyaqualifiedprofessional(QP) todetermineifthearsenicconcentrationobservedisappropriatefordischarge.Asthe50ug/llevelisbeing exceeded,wehavesuggestedtoInnergexthattheseepageshouldbecontaineduntilfurtherwaterqualitysampling showstheconcentrationshavedroppedtothisvalue,oruntiltheyhavethewaterqualityresultsevaluatedbyLee NiklofGolder(orotherQPtheyretain).NotethatRobertKulka(Innergex)hasspokentoLeeNiklaboutthismatter, butasofyetIhavenotreceivedanythinginwritingfromLee(likelytomorrow). Atpresentthewaterisnotbeingcontained,andisflowingasstatedabove;Innergexarereluctanttocollectthe watersinthetailrace,asthetailraceisbeingusedtoventilatetheongoingworksinthetunnel.Theseepagewaters maynotbeanissue,however,astheAshlusdischargeisnowapproximately15cms,whichwouldamounttoa dilutionratioofabout1,500to1.Ifyouwouldlikeustotakefurtherstepsatthistime,pleaseadvise. Cheers,
MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
From: Christine Becker Sent: March-22-10 12:43 PM To: 'Robert Kulka' Cc: Mike Nelson; 'Knight, Francesca' Subject: 413 Ashlu water quality results
HiRobert, InmylastemailIattachedthesedimentpondsamplingresultsaswellasthewaterqualityresultsforthetunnel seepageattheportal.Ihavereviewedthewaterqualityresultsfromtheportalditchanditlookslikethereisan issuewithdissolvedarsenic(0.085mg/L),whichexceedstheWQguidelinesof0.005mg/L.Irepeatedthesampling lastweektoincludealocationattheoutletoftheditchaswellasahydrocarbonanalysis. Iwouldstronglysuggestthatyoupumptheseepagetoacontainedlocationuntilwereceivethemostrecentsample results(expectedthisweek)topreventelevatedarseniclevelsfromreachingAshluCreek.Chessy,doyouhaveany furthercommentsatthistime? Regards,

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CHRISTINE BECKER (NEE CUNLIFFE). B.SC., B.I.T. Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA Unit 203 38026 2nd Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | FAX: 604 815-0904 cbecker@cerg.ca | www.cascade-environmental.ca
Page 248 FNR-2011-00265 Part 2
Your P.O. #: 413-01-01 Your Project #: 413-01-01 Your C.O.C. #: 08311719
Attention: ROBERT J. KULKA ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP VANCOUVER SUITE 303-38 FELL AVENUE NORTH VANCOUVER, BC CANADA V7P 3S2 Report Date: 2010/03/24 This report supersedes all previous reports with the same Maxxam job number
CERTIFICATE OF ANALYSIS
MAXXAM JOB #: B016606 Received: 2010/03/22, 11:20 Sample Matrix: Water # Samples Received: 2 Date Extracted N/A N/A N/A N/A N/A N/A 2010/03/23 N/A N/A N/A N/A N/A Date Analyzed 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/23 2010/03/23 2010/03/17 2010/03/23
Analyses Hardness Total (calculated as CaCO3) Hardness (calculated as CaCO3) Na, K, Ca, Mg, S by CRC ICPMS (diss.) Elements by ICPMS Low Level (dissolved) () 1 Na, K, Ca, Mg, S by CRC ICPMS (total) Elements by ICPMS Low Level (total) () 1 PAH in Water by GC/MS (SIM) Total LMW, HMW, Total PAH Calc Filter and HNO3 Preserve for Metals pH Water Sulphate by Automated Colourimetry Total Suspended Solids
Quantity 2 2 2 2 2 2 2 2 2 2 2 2
Laboratory Method
Analytical Method
BRN SOP-00206 BRN SOP-00206 BRN SOP-00206 BRN SOP-00206 BRN SOP-00331 R11.0 BRN WI-00006 R1.0 BRN SOP-00264 R4.0 BRN-SOP 00243 R1.0 BRN SOP-00277 R5.0
Based on EPA 200.8 Based on EPA 200.8 Based on EPA 200.8 Based on EPA 200.8 Based on EPA 8270D Based on EPA 200.2 Based on SM-4500H+B Based on EPA 375.4 Based on SM - 2540 D
* Results relate only to the items tested.
(1) SCC/CAEAL
Encryption Key
Please direct all questions regarding this Certificate of Analysis to your Project Manager. ASHLEY NIVISON, BBY Customer Service Email: ashley.nivison@maxxamanalytics.com Phone# (604) 444-4808 Ext:230 ==================================================================== Maxxam has procedures in place to guard against improper use of the electronic signature and have the required "signatories", as per section 5.10.2 of ISO/IEC 17025:2005(E), signing the reports. For Service Group specific validation please refer to the Validation Signature Page.
Total cover pages: 1

Maxxam Analytics International Corporation o/a Maxxam Analytics Burnaby: 8577 Commerce Court V5A 4N5 Telephone(604) 444-4808 Fax(604) 444-4511
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Maxxam Job #: B016606 Report Date: 2010/03/24
ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP Client Project #: 413-01-01 Your P.O. #: 413-01-01 Sampler Initials: CB
RESULTS OF CHEMICAL ANALYSES OF WATER

Maxxam ID Sampling Date COC# Units Preparation Filter and HNO3 Preservation Calculated Parameters Total Hardness (CaCO3) Misc. Inorganics Dissolved Hardness (CaCO3) Anions Dissolved Sulphate (SO4) Polycyclic Aromatics Low Molecular Weight PAH`s High Molecular Weight PAH`s Total PAH Physical Properties pH Physical Properties Total Suspended Solids N/A mg/L mg/L mg/L ug/L ug/L ug/L pH Units mg/L T30847 2010/03/18 13:35 08311719 AT PORTAL LAB 186 119 110 0.31 0.15 0.46 8.9 110 T30848 2010/03/18 13:50 08311719 DOWNSTREAM OF PORTAL DITCH LAB 44.9 46.2 32 <0.05 <0.02 <0.05 8.6 6 4
RDL N/A 0.5 0.5 0.5 0.05 0.02 0.05
QC Batch ONSITE 3828584 3828729 3839665 3828587 3828587 3828587 3831634 3832439
N/A = Not Applicable RDL = Reportable Detection Limit
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SEMIVOLATILE ORGANICS BY GC-MS (WATER)

Maxxam ID Sampling Date COC# Units Polycyclic Aromatics Naphthalene 2-Methylnaphthalene Quinoline Acenaphthylene Acenaphthene Fluorene Phenanthrene Anthracene Acridine Fluoranthene Pyrene Benzo(a)anthracene Chrysene Benzo(b&j)fluoranthene Benzo(k)fluoranthene Benzo(a)pyrene Indeno(1,2,3-cd)pyrene Dibenz(a,h)anthracene Benzo(g,h,i)perylene Surrogate Recovery (%) D10-ANTHRACENE (sur.) D12-BENZO(A)PYRENE (sur.) D8-ACENAPHTHYLENE (sur.) D8-NAPHTHALENE (sur.) TERPHENYL-D14 (sur.) T30847 2010/03/18 13:35 08311719 AT PORTAL T30848 2010/03/18 13:50 08311719 DOWNSTREAM OF PORTAL DITCH <0.01 <0.01 <0.05 <0.01 <0.01 <0.01 0.02 <0.01 <0.05 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.02 <0.02 <0.02 83 82 83 80 88
RDL
QC Batch
ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L % % % % %
0.03 0.02 0.11 0.01 <0.01 0.04 0.08 0.02 <0.05 0.05 0.07 0.02 0.02 <0.01 <0.01 <0.01 <0.02 <0.02 <0.02 84 79 84 83 88
0.01 0.01 0.05 0.01 0.01 0.01 0.01 0.01 0.05 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.02 0.02 0.02
3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568
RDL = Reportable Detection Limit Page 3 of 11
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ELEMENTS BY ATOMIC SPECTROSCOPY (WATER)

Maxxam ID Sampling Date COC# Units T30847 2010/03/18 13:35 08311719 AT PORTAL T30848 2010/03/18 13:50 08311719 DOWNSTREAM OF PORTAL DITCH 22.1 0.40 14.6 14.3 <0.01 <0.005 1010 <0.005 6.7 0.023 0.64 6 0.010 50.6 2.42 5.64 0.12 0.34 5900 <0.005 87.3 0.004 <0.01 <0.5 3.10 3.1 <0.1 <0.1 12.7 3.53 2.35 67.8 15
RDL
RDL
QC Batch
Dissolved Metals by ICPMS Dissolved Aluminum (Al) Dissolved Antimony (Sb) Dissolved Arsenic (As) Dissolved Barium (Ba) Dissolved Beryllium (Be) Dissolved Bismuth (Bi) Dissolved Boron (B) Dissolved Cadmium (Cd) Dissolved Chromium (Cr) Dissolved Cobalt (Co) Dissolved Copper (Cu) Dissolved Iron (Fe) Dissolved Lead (Pb) Dissolved Lithium (Li) Dissolved Manganese (Mn) Dissolved Molybdenum (Mo) Dissolved Nickel (Ni) Dissolved Selenium (Se) Dissolved Silicon (Si) Dissolved Silver (Ag) Dissolved Strontium (Sr) Dissolved Thallium (Tl) Dissolved Tin (Sn) Dissolved Titanium (Ti) Dissolved Uranium (U) Dissolved Vanadium (V) Dissolved Zinc (Zn) Dissolved Zirconium (Zr) Dissolved Calcium (Ca) Dissolved Magnesium (Mg) Dissolved Potassium (K) Dissolved Sodium (Na) Dissolved Sulphur (S)
ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L mg/L mg/L mg/L mg/L mg/L
6 1.3 43.1 31.9 <0.05 <0.03 3200 <0.03 17.1 0.03 0.5 25 0.04 174 0.9 17.2 0.2 1.0 14900 0.05 247 0.01 <0.05 <3 10.0 10 <0.5 <0.5 28.2 11.8 7.1 213 <50
1 0.1 0.1 0.1 0.05 0.03 300 0.03 0.5 0.03 0.3 5 0.03 3 0.3 0.3 0.1 0.2 500 0.03 0.3 0.01 0.05 3 0.01 1 0.5 0.5 0.3 0.3 0.3 0.3 50
0.2 0.02 0.02 0.02 0.01 0.005 50 0.005 0.1 0.005 0.05 1 0.005 0.5 0.05 0.05 0.02 0.04 100 0.005 0.05 0.002 0.01 0.5 0.002 0.2 0.1 0.1 0.05 0.05 0.05 0.05 10
3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3829996 3829996 3829996 3829996 3829996
Page 252 FNR-2011-00265 Part 2
ELEMENTS BY ATOMIC SPECTROSCOPY (WATER)

Maxxam ID Sampling Date COC# Units T30847 2010/03/18 13:35 08311719 AT PORTAL T30848 2010/03/18 13:50 08311719 DOWNSTREAM OF PORTAL DITCH 170 0.43 15.6 15.0 <0.01 0.011 962 0.005 6.8 0.105 1.86 122 0.159 49.3 9.80 5.59 0.19 0.30 6330 0.010 86.6 0.004 0.08 5.9 3.14 3.3 8.9 0.1 12.2 3.48 2.23 64.6 13
RDL
RDL
QC Batch
Total Metals by ICPMS Total Aluminum (Al) Total Antimony (Sb) Total Arsenic (As) Total Barium (Ba) Total Beryllium (Be) Total Bismuth (Bi) Total Boron (B) Total Cadmium (Cd) Total Chromium (Cr) Total Cobalt (Co) Total Copper (Cu) Total Iron (Fe) Total Lead (Pb) Total Lithium (Li) Total Manganese (Mn) Total Molybdenum (Mo) Total Nickel (Ni) Total Selenium (Se) Total Silicon (Si) Total Silver (Ag) Total Strontium (Sr) Total Thallium (Tl) Total Tin (Sn) Total Titanium (Ti) Total Uranium (U) Total Vanadium (V) Total Zinc (Zn) Total Zirconium (Zr) Total Calcium (Ca) Total Magnesium (Mg) Total Potassium (K) Total Sodium (Na) Total Sulphur (S)
ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L mg/L mg/L mg/L mg/L mg/L
2030 2.1 68.1 67.0 0.06 <0.03 3110 0.15 20.9 1.31 17.1 1860 3.10 168 94.3 16.8 1.7 0.9 21800 0.13 315 0.02 0.99 94 10.8 12 55.9 1.1 51.8 13.8 6.8 207 <50
1 0.1 0.1 0.1 0.05 0.03 300 0.03 0.5 0.03 0.3 5 0.03 3 0.3 0.3 0.1 0.2 500 0.03 0.3 0.01 0.05 3 0.01 1 0.5 0.5 0.3 0.3 0.3 0.3 50
0.2 0.02 0.02 0.02 0.01 0.005 50 0.005 0.1 0.005 0.05 1 0.005 0.5 0.05 0.05 0.02 0.04 100 0.005 0.05 0.002 0.01 0.5 0.002 0.2 0.1 0.1 0.05 0.05 0.05 0.05 10
3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3831580 3831580 3831580 3831580 3831580
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ELEMENTS BY ATOMIC SPECTROSCOPY (WATER) Comments Sample Sample T30847-04 Elements by ICPMS Low Level (dissolved): RDL raised due to sample matrix interference. T30847-03 Elements by ICPMS Low Level (total): RDL raised due to sample matrix interference.
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QUALITY ASSURANCE REPORT
Matrix Spike % Recovery QC Limits 100 80 - 120 101 80 - 120 100 80 - 120 106 80 - 120 100 80 - 120 100 80 - 120 102 80 - 120 104 80 - 120 99 80 - 120 101 80 - 120 101 80 - 120 105 80 - 120 98 80 - 120 107 80 - 120 Spiked Blank % Recovery QC Limits 99 80 - 120 99 80 - 120 97 80 - 120 102 80 - 120 102 80 - 120 100 80 - 120 103 80 - 120 104 80 - 120 99 80 - 120 103 80 - 120 103 80 - 120 104 80 - 120 98 80 - 120 103 80 - 120 Method Blank Value Units <4 mg/L <0.02 ug/L <0.01 ug/L <0.005 ug/L <0.1 ug/L <0.005 ug/L <0.05 ug/L <0.005 ug/L <0.5 ug/L <0.02 ug/L <0.04 ug/L <0.002 ug/L <0.2 ug/L <0.1 ug/L <0.2 ug/L <0.02 ug/L <0.02 ug/L <0.005 ug/L <50 ug/L <1 ug/L <0.05 ug/L <0.05 ug/L <100 ug/L <0.005 ug/L <0.05 ug/L <0.002 ug/L <0.01 ug/L <0.5 ug/L <0.1 ug/L <0.02 ug/L <0.01 ug/L <0.005 ug/L <0.1 ug/L <0.005 ug/L <0.05 ug/L <0.005 ug/L <0.5 ug/L <0.02 ug/L <0.04 ug/L RPD Value (%) QC Limits 5.4 25
QC Batch 3832439 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3832809 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577
Parameter Total Suspended Solids Total Arsenic (As) Total Beryllium (Be) Total Cadmium (Cd) Total Chromium (Cr) Total Cobalt (Co) Total Copper (Cu) Total Lead (Pb) Total Lithium (Li) Total Nickel (Ni) Total Selenium (Se) Total Uranium (U) Total Vanadium (V) Total Zinc (Zn) Total Aluminum (Al) Total Antimony (Sb) Total Barium (Ba) Total Bismuth (Bi) Total Boron (B) Total Iron (Fe) Total Manganese (Mn) Total Molybdenum (Mo) Total Silicon (Si) Total Silver (Ag) Total Strontium (Sr) Total Thallium (Tl) Total Tin (Sn) Total Titanium (Ti) Total Zirconium (Zr) Dissolved Arsenic (As) Dissolved Beryllium (Be) Dissolved Cadmium (Cd) Dissolved Chromium (Cr) Dissolved Cobalt (Co) Dissolved Copper (Cu) Dissolved Lead (Pb) Dissolved Lithium (Li) Dissolved Nickel (Ni) Dissolved Selenium (Se)
Date 2010/03/23 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24
NC
20
111 111 110 105 102 100 104 NC 100 112
80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120
94 98 97 98 97 101 107 101 97 98
80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120
4.0 NC NC NC 5.6 2.2 NC 0.9 4.9 NC
20 20 20 20 20 20 20 20 20 20
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Matrix Spike % Recovery QC Limits 107 80 - 120 106 80 - 120 110 80 - 120 Spiked Blank % Recovery QC Limits 105 80 - 120 95 80 - 120 99 80 - 120 Method Blank Value Units <0.002 ug/L <0.2 ug/L <0.1 ug/L <0.2 ug/L <0.02 ug/L <0.02 ug/L <0.005 ug/L <50 ug/L <1 ug/L <0.05 ug/L <0.05 ug/L <100 ug/L <0.005 ug/L <0.05 ug/L <0.002 ug/L <0.01 ug/L <0.5 ug/L <0.1 ug/L 84 % 87 % 84 % 83 % 93 % <0.01 ug/L <0.01 ug/L <0.05 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.05 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L <0.01 ug/L RPD Value (%) QC Limits 2.8 20 NC 20 16.3 20 9.4 20 0.8 20 1.6 20 NC 20 NC 20 NC 20 5.8 20 0.2 20 NC 0.9 NC NC 20 20 20 20
QC Batch 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3833577 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568 3834568
Parameter Dissolved Uranium (U) Dissolved Vanadium (V) Dissolved Zinc (Zn) Dissolved Aluminum (Al) Dissolved Antimony (Sb) Dissolved Barium (Ba) Dissolved Bismuth (Bi) Dissolved Boron (B) Dissolved Iron (Fe) Dissolved Manganese (Mn) Dissolved Molybdenum (Mo) Dissolved Silicon (Si) Dissolved Silver (Ag) Dissolved Strontium (Sr) Dissolved Thallium (Tl) Dissolved Tin (Sn) Dissolved Titanium (Ti) Dissolved Zirconium (Zr) D10-ANTHRACENE (sur.) D12-BENZO(A)PYRENE (sur.) D8-ACENAPHTHYLENE (sur.) D8-NAPHTHALENE (sur.) TERPHENYL-D14 (sur.) Naphthalene 2-Methylnaphthalene Quinoline Acenaphthylene Acenaphthene Fluorene Phenanthrene Anthracene Acridine Fluoranthene Pyrene Benzo(a)anthracene Chrysene Benzo(b&j)fluoranthene Benzo(k)fluoranthene Benzo(a)pyrene
Date 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24 2010/03/24
80 86 76 68 89 70 72 102 72 77 78 81 79 91 80 87 82 82 78 89 86
60 - 130 60 - 130 50 - 130 50 - 130 60 - 130 50 - 130 50 - 130 50 - 130 50 - 130 50 - 130 50 - 130 60 - 130 60 - 130 50 - 130 60 - 130 60 - 130 60 - 130 60 - 130 60 - 130 60 - 130 60 - 130
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Matrix Spike % Recovery QC Limits Spiked Blank % Recovery QC Limits 86 60 - 130 86 60 - 130 85 60 - 130 98 80 - 120 Method Blank Value Units <0.02 ug/L <0.02 ug/L <0.02 ug/L 0.8, RDL=0.5 mg/L RPD Value (%) QC Limits
QC Batch 3834568 3834568 3834568 3839665
Parameter Indeno(1,2,3-cd)pyrene Dibenz(a,h)anthracene Benzo(g,h,i)perylene Dissolved Sulphate (SO4)
Date 2010/03/24 2010/03/24 2010/03/24 2010/03/17
0.1
20
N/A = Not Applicable RDL = Reportable Detection Limit RPD = Relative Percent Difference Duplicate: Paired analysis of a separate portion of the same sample. Used to evaluate the variance in the measurement. Matrix Spike: A sample to which a known amount of the analyte of interest has been added. Used to evaluate sample matrix interference. Spiked Blank: A blank matrix to which a known amount of the analyte has been added. Used to evaluate analyte recovery. Method Blank: A blank matrix containing all reagents used in the analytical procedure. Used to identify laboratory contamination. Surrogate: A pure or isotopically labeled compound whose behavior mirrors the analytes of interest. Used to evaluate extraction efficiency. NC (Matrix Spike): The recovery in the matrix spike was not calculated. The relative difference between the concentration in the parent sample and the spiked amount was not sufficiently significant to permit a reliable recovery calculation. NC (RPD): The RPD was not calculated. The level of analyte detected in the parent sample and its duplicate was not sufficiently significant to permit a reliable calculation.
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Validation Signature Page

Maxxam Job #: B016606
The analytical data and all QC contained in this report were reviewed and validated by the following individual(s).
TOM SHUM, BBY Scientific Specialist
==================================================================== Maxxam has procedures in place to guard against improper use of the electronic signature and have the required "signatories", as per section 5.10.2 of ISO/IEC 17025:2005(E), signing the reports. For Service Group specific validation please refer to the Validation Signature Page.
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From: Sent: To: Cc: Subject:
S22 S22 S22
Ptolemy, Ron ENV:EX; Babakaiff, Scott C fo-mpo.gc.ca;

S22
S22
FW: Ashlu flows (FYI from BC)
S22
Ifthatminimaldamspill(perhaps1%ofmeanannu.flowatmost?)compliesw/itswaterlicense,thenthelatteris justaglorifiedpieceofpaper.Thattricklecertainlydoesntcomplyw/theTennantmethodorsupportiveempirical data(e.g.,Vadas2000). Bob

Vadas, R.L. Jr. 2000. Instream-flow needs for anadromous salmonids and lamprey on the Pacific coast, with special reference to the Pacific Southwest. Environmental Monitoring and Assessment 64: 331-358 (cf. http://www.springerlink.com/content/v028xu2lr7q80j25).
From Sent: S22 To C sc Subject: Ashlu flows

S22
S22
ron.ptolemy@gov.bc.ca;
Hi Guys
S22 I just thought I would drop a line in regards to a recent email from In it he has a number of S22 recent photos, taken by of the Ashlu at the dam whi hat the stream in the diversion as, essentially, b ewatered relative to its channel capacity. I also got a photo taken by S22 on the same day of the dam photos, at the powerhouse looking downstream from the tailrace and, although it is not a great picture, suggests that the discharges in the stream are actually not too bad in the non-diversion areas.
The diversion zone visually looks something like an aquatic Hiroshima (i.e., it is obliterated). In the far left of the dam superstructure you can see, what appears to be the low-flow tunnel with minimum discharges being released; the volume looks to be only a tiny percentage of the inflows (and, therefore, the MAD).. Does anyone know if the proponents are in compliance with their water licences under these flows? And what is the conservation flows below the dam in the diversion areas? Is there a rationale behind the conservation flow volume? Do these minimum flows meet the Hatfield requirements? Are fish and aquatic invertebrate populations being protected by minimum flows in the canyon area? If not, how was this HADD compensated for under Section 35 of the Canada Fisheries Act? Any thoughts would be appreciated.
S22
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(See attached file: Ashlu below powerhouse.JPG)(See attached file: Ashlu downstream dam 1.JPG)(See attached file: Ashlu downstream dam 2.JPG)
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From: Sent: To: Cc: Subject: Attachments: McGuire, Jennifer ENV:EX Sunday, April 4, 2010 11:38 AM Berardinucci, Julia F ENV:EX Babakaiff, Scott C ENV:EX; Barrett, Scott ENV:EX; Bennett, Timothy A ENV:EX Fyi: Ashlu flows Ashlu below powerhouse.JPG; Ashlu downstream dam 1.JPG; Ashlu downstream dam 2.JPG
Suggest we discuss at REC and confirm a process for a coordinated response ... With WSD as the lead (due to the WA authorization). ESD folks - as per Bab's comment - hold on responses until direction provided ... Possibly on Tuesday. JLM
From: Babakaiff, Scott C ENV:EX To: Bennett, Timothy A ENV:EX; Barrett, Scott ENV:EX Cc: McGuire, Jennifer ENV:EX Sent: Sun Apr 04 10:58:37 2010 Subject: FW: Ashlu flows FYI. I do not plan on responding to Scott
S22
unless directed to do so.
S22 From Sent: Thu 01/04/2010 4:30 PM To S22 S22 Cc ENV:EX; vince.busto@dfo-mpo.gc.ca Subject: Ashlu flows
Ptolemy, Ron ENV:EX; Babakaiff, Scott C
Hi Guys
S22 I just thought I would d gards to a recent email from In it he has a number of S22 recent photos, taken by f the Ashlu at the dam which suggests that the stream in the diversion as, essentially, be watered relative to its channel capacity. I also got a photo taken by S22 on the same day of the dam photos, at the powerhouse looking downstream from the tailrace and, gh it is not a great picture, suggests that the discharges in the stream are actually not too bad in the non-diversion areas.
The diversion zone visually looks something like an aquatic Hiroshima (i.e., it is obliterated). In the far left of the dam superstructure you can see, what appears to be the low-flow tunnel with minimum discharges being released; the volume looks to be only a tiny percentage of the inflows (and, therefore, the MAD).. Does anyone know if the proponents are in compliance with their water licences under these flows? And what is the conservation flows below the dam in the diversion areas? Is there a rationale behind the conservation flow volume? Do these minimum flows meet the Hatfield requirements? Are fish and aquatic invertebrate populations being protected by minimum flows in the canyon area? If not, how was this HADD compensated for under Section 35 of the Canada Fisheries Act? Any thoughts would be appreciated.
1
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S22
(See attached file: Ashlu below powerhouse.JPG)(See attached file: Ashlu downstream dam 1.JPG)(See attached file: Ashlu downstream dam 2.JPG)
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, April 5, 2010 1:06 PM McGuire, Jennifer ENV:EX Barrett, Scott ENV:EX FW: Inquiry re Ashlu IFR flows
Just keeping y'all in the loop regarding communications today between Tim, myself & the Ashlu IEM/proponent... Hopefully we'll have some answers & data regarding the Ashlu IFR question in the next day or so.
From: Babakaiff, Scott C ENV:EX Sent: Mon 05/04/2010 1:03 PM To: Mike Nelson; Bennett, Timothy A ENV:EX; Robert Kulka Cc: gsteeves@ameresco.com; Knight, Francesca Subject: RE: Inquiry re Ashlu IFR flows I can't speak for Tim, but my preference would be that you do both: provide the data to allow our review ASAP, but also review the data yourselves.
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Mon 05/04/2010 12:32 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; Robert Kulka Cc: gsteeves@ameresco.com; Knight, Francesca Subject: RE: Inquiry re Ashlu IFR flows
Scott, Theshortanswertoyourquestionisyes.IjustgotoffthephonetoRobert,andhewill forwardthedatatoallorwouldyouratherwepourthroughthedatatoverify compliance? Cheers, MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca OriginalMessage From:Babakaiff,ScottCENV:EX[mailto:Scott.Babakaiff@gov.bc.ca] Sent:April051012:06PM To:MikeNelson;Bennett,TimothyAENV:EX Cc:gsteeves@ameresco.com;Knight,Francesca Subject:RE:InquiryreAshluIFRflows CancomplianceoftheIFRbeverifiedviaprovisionofcontinuousstreamflowdatawithin thediversionreachfromthepastfewmonths? ________________________________ From:MikeNelson[mailto:mnelson@cerg.ca] Sent:Mon05/04/201010:36AM To:Bennett,TimothyAENV:EX Cc:Babakaiff,ScottCENV:EX;gsteeves@ameresco.com;Knight,Francesca Subject:RE:InquiryreAshluIFRflows
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Tim, Iamnotawareofanynoncompliances.Whentheheadpondisfull,theIFRisreleased automaticallythroughtheIFRpipe.Also,theheadpondhasbeenemptysinceMarch1due tocleaningofgravelfromthetunnel;so100%oftheriverwasreleasedlastmonth.We've beentakingweeklysamplesfromtheriverandfromthetunnelseepageforarsenicand relatedparameters.We'llbefilingareportonthatshortly. TheplanistorefilltheheadpondeithertomorrowofWednesday,holdingbackamaximum of10%oftheAshlu'sflowandthenstartthetunnelflushingprocedureaccordingtothe protocol.We'llresumeweeklyreportingduringthiswork. Cheers, MIKENELSON,R.P.BIO. Principal CascadeEnvironmentalResourceGroupLtd. WhistlerandSquamish,BC|Whitehorse,YT|SanDiego,CA Unit203380262ndAvenue|Squamish|BC|Canada|V8B0C3 TEL:6048150901|CELL:6048159973|FAX:6048150904 mnelson@cerg.ca|www.cascadeenvironmental.ca OriginalMessage From:Bennett,TimothyAENV:EX[mailto:Timothy.Bennett@gov.bc.ca] Sent:April051010:14AM To:MikeNelson Cc:Babakaiff,ScottCENV:EX;gsteeves@ameresco.com Subject:RE:InquiryreAshluIFRflows HiMike, We'vereceivedinquiriesregardingwhetherAshluisreleasingitsIFRrequirement. Canyou(orGeorge)pleaseconfirmifyouareawareofanynoncomplianceswiththeIFR requirement(i.e.,dateswhentheplantmaynothavebeenreleasingtherequiredflows)? Also,canyoupleaseconfirmthestatusoftheplant?Iunderstanditstillundergoing commissioning(viaGeorge'slatestextension),buthowoftenareeitherofyouor delegatesonsitetomonitorthis? thanks, TimBennett
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From: Sent: To: Cc: Subject: Bennett, Timothy A ENV:EX Monday, April 5, 2010 10:23 PM Mike Nelson; Babakaiff, Scott C ENV:EX; Robert Kulka gsteeves@ameresco.com; Knight, Francesca; Berardinucci, Julia F ENV:EX RE: IFR flow data
Hi Mike, Robert; Thanks for following up with this. Please provide all available flow data as soon as possible, and an expected timeline as to when we could receive this information. Please send to all recipients of this e-mail. Regards, Tim Bennett Assistant Regional Water Manager
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Mon 05/04/2010 1:36 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; Robert Kulka Cc: gsteeves@ameresco.com; Knight, Francesca Subject: RE: Inquiry re Ashlu IFR flows
Scott, Iwasafraidyouweregoingtosaythat(justkidding). Robert, Canyouprovidethedatatoallassoonasyouareable.Illlookatthedataandgetto everyonewithabriefsummaryreport. Cheers, MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
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From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Thursday, April 15, 2010 10:02 AM Knight, Francesca RE: Outstanding Requirements for Ashlu Creek Hydro Project
Great stuff Chessy. Thanks much. For your info, I'll also forward some recent work (a stats analysis and my response) on a different IPP in Region 2. It relates to a non-parametric statistical approach for macroinvert monitoring to be used at East Toba-Montrose. No review requested (the major projects folk at DFO are involved), just a little light reading for your enjoyment when you're not on the motorcycle. Scott
S. 22
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thu 15/04/2010 9:58 AM To: Robert Kulka; Richard Blanchet Cc: Babakaiff, Scott C ENV:EX; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; mnelson@cerg.ca; Bennett, Timothy A ENV:EX Subject: Outstanding Requirements for Ashlu Creek Hydro Project Hello Robert and Richard, I have included here DFO's comments on Focus' draft OEMP. Overall, I'd say that the monitoring program as proposed does not enable DFO to determine whether the assumptions carried forward in the CEAA screening and approval documents were in fact correct. In other words, the program will not be able to determine whether there are any adverse effects on the Ashlu as a result of plant operations.
I.
Water levels, temp., and flows 1. MoE has provided an excellent identification of the proposed programs deficiencies with respect to instream flow monitoring. I cant improve on his work, although I have one comment on ramping. 2. Ramping (Sec. 5.1.2): Focus alludes to a ramping study conducted by Cascade Environmental in 2009. What was the purpose of that study? What ramping rates were evaluated? Focus seems to indicate that the OEMP will monitor ramping during any plant start-ups and shut-downs, but how, according to what rates, etc? This is a pretty important component of ascertaining the potential effects of plant operations. It seems to be dismissed.
II.
Water Quality I will focus on my biggest issue with this section, as opposed to commenting on selected parameters or station locations. The objective of the Focus program is to detect changes to water quality in Ashlu Creek as a result of the project. Further, Changes to water quality will be assessed by comparing baseline and operations values and among sample sites for each of the parameters using Cavanah et al. (1998). The problem with this objective is that I dont see any way to compare operational WQ with baseline WQ, as the baseline program is such a mish-mash of data collection over several years time, by various consultants. The situation could be improved by a review and summary of all pre-operational data by an appropriately qualified scientist. I dont know if any summary statistics could be done, but they would be handy for
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understanding the basic water chemistry of the river and variability around those parameters. Overall, though, we know Ashlu WQ was not limiting to aquatic life before operations, but may be affected by plant operations. Another way to put this is to say that the ability to conduct rigorous statistical comparisons of select WQ parameters before and after operation commencement is a nice-to-have. Comparing operational WQ (both in control reaches and effected reaches) to relevant guidelines (BC WQGs or literature values for those parameters that do not have existing WQGs) is a must-have. If a really detailed analysis exists of baseline WQ data, it should be summarized in the OEMP. If it does not, thats a missed opportunity. I cant really criticize the parameter selection, but rather, how it relates to the baseline picture of Ashlu water chemistry. I do think that Focus should pay very close attention on temperature and dissolved oxygen in the diversion vs. control reaches. III. Fish Habitat 1. While I can see some value in qualitative habitat assessment on a reach-wide basis, there is no real scientific rigor in the Focus proposal, so no way to meaningfully assess habitat changes or impairment over time, as a result of the altered flow regime. Representative transects should be selected in each reach, and available habitat type and area quantified at various flows. And no baseline habitat data were collected after 2004, and its now 2010. Thats plenty of time to have set up transects! 2. Focus is planning on documenting qualitative changes to instream habitat potentially caused by the altered flow regime. How? If a substantial effort was spent on baseline studies assessing spawning potential [in the diversion reach and downstream] then pick some relevant metrics from this work and use them to quantitatively assess changes over time. And if rearing habitat was not adequately assessed during baseline studies, why did ACILP not collect such data between 2004 and now?
3. Focus proposes that Additional information such as habitat suitability for species of interest for spawning, rearing and overwintering life history stages will be assessed using professional judgement at IFR. With all due respect to Mr. Johnsons many years in the field, we just dont place much value on such methods anymore. Simply, the science has evolved. Effective quantitative habitat monitoring (e.g., transects) would enable use of habitat suitability index models for steelhead and coho. I dont think these models are perfect, and they can certainly be misused (i.e., model parameterized with habitat variables that are not relevant to the stream of interest), but why not give it a shot here? The HSI model would be a good place to start a meaningful evaluation of habitat suitability to the referenced species and life stages, and how plant operations effect the modeled relationships. IV. Fish Community 1. This section would benefit from a good figure showing reach breaks and sample locations. 2. All existing baseline data should be evaluated by a qualified fisheries biologist to give DFO and MoE the best possible picture of fish use, abundance, population size, etc. The baseline work done on this very important indicator is limited, and unfortunately provides us with no real population estimates for species and life stages of interest. Additional baseline work could have been done over the last couple of years, to at least give us good population estimates and form the basis for comparison in future years of operation. Focus should be very careful in characterizing baseline conditions while baseline sampling resulted in low fish capture numbers, I would err on the side of inadequate sampling, rather than low fish productivity in the Ashlu! 3. I dont see the value of the gut contents survey stomach-pumping the fish places undue stress on them for no real reason. If Focus feels that strongly about this part of the study, why
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not then only do it on a limited number of fish? The way the report reads, it sounds like all captured fish will have their stomachs pumped. I dont see any reason for this. 4. ACILP is responsible for monitoring fish passage upstream of the intake structure (i.e., use of the fish ladder). The proposed monitoring is too qualitative periodic observations?...how many? Any possibility for a passive fish counter, etc? 5. Focus makes no mention of basic statistical analysis tools that could be used for evaluating differences in fish community metrics in control vs. diversion reach sites. For Focus consideration: i. hypothesis testing: can be used to evaluate whether a given metric (mean parr abundance, for example) in the diversion reach differs from either the upstream control or downstream sites. Ideally, this could also be done for comparisons of baseline vs. operational data. ii. ANOVA: very good for understanding the relationship between natural variability and measured biological response. Use of these tools does require some a sampling considerations in study design, which unfortunately is not evident in Focus OEMP. 6. MoE has already brought up the issue of power analysis in their comments, and I have chosen to address it in a later section of my comments. But, Focus does state: Quantitative multivariate analysis of the data with power analysis to assess the biological change will be performed if possible. At the risk of sounding incredibly critical, there is nothing in Focus OEMP study design that would enable such an analysis. For one thing, power analysis needs to be done first. It is a critical component of study design and forms the basis for such things like number of sampling stations, number of replicates, etc. And with respect to Focus use of multivariate statistics Focus has not demonstrated a working knowledge of univariate statistics in the study design, so I am cautious as to their correct use of multivariate tools.
V.
Aquatic insects 1. I think the baseline data would benefit from a thorough review and synthesis by a biologist experienced with these types of datasets. It is however unfortunate that taxonomy was not at least to the genus level. 2. I have emphasized in other report reviews just how important I think benthic/drift invertebrate data is for assessing changes in aquatic environments. I dont think that maintenance of pre-disturbance invertebrate abundance and biomass is sufficient to maintain the productivity of a given affected reach (e.g., sufficient to maintain food for fish, therefore maintaining pre-development fish population levels), and therefore the affected stream as a whole. From Focus overview of baseline studies, it sounds like the emphasis was on invertebrate abundance.
3. I support Focus direction to evaluate taxonomy to the genus/species level, but beyond that, I am not confident in the proposed data analysis and summary, primarily because there is not a solid analysis plan presented in the OEMP. Focus could consider the following metrics. The metrics listed here are not an exhaustive list; other site-specific metrics of interest may be added (such as presence of rare taxa). Simpsons diversity index: takes into account both the abundance patterns and taxonomic richness of the community. The formula for calculating this metric can be found in the primary literature. Taxa (i.e., Family) richness.
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Taxa (e.g., family) density: the number of individuals of each family expressed per unit area. Id pay careful attention to presenting the top three taxa (based on abundance). Taxa (e.g., family) proportion: the percentage abundance for each taxon at each station. EPT density and proportion: expresses the density and proportion of taxa representing the orders Ephemeroptera (Mayflies), Trichoptera (caddisflies) and Plecoptera (stoneflies). These orders are considered to be indicative of healthy stream conditions, and make up a valuable component of the salmonid diet. Bray-Curtis (B-C) Index: expresses the degree of invertebrate community similarity / dissimilarity between stations (i.e., diversion reach vs. controls, or post-development vs. baseline). It is a distance coefficient that reaches a maximum value of 1 for two sites that are entirely different, and a minimum value of 0 for two sites that are entirely the same. The distance coefficient measures the amount of association between sites, and would be useful for presenting an overall picture of how the invertebrate data differ in ordination space, and therefore how the invertebrate community within the diversion reach differs from the control or baseline (if at all), which is a primary research question.
4. Focus should re-visit their considerations on what constitutes a drift net sample. In my mind, if nets are pulled every hour instead of every four hours, each pull is not a separate sample, but rather creates incidents of pseudo-replication (which, of course, confounds data analysis). The sample interval (e.g., four hours) should be set in the study design; if nets are clogging with fine sediment and have to be pulled hourly, those four hourly pulls should be composited into one replicate. VI. Mitigation and Compensation Works Is Edith Tobe (Squamish River Watershed Society) monitoring the compensation works? VII. Assessment of effects 1. Kudos to Focus for identifying the very important issue of effect thresholds within the field of IPP effects monitoring. I believe that the IPP industry is very much behind some other industries with respect to accepted critical effect thresholds. Also, though, I believe that Focus is absolutely incorrect to say that the term effect thresholds refers to the degree of change or level of effect based on professional opinion. Focus should look at models like the MMER EEM program (metal mining effluent effects regulation environmental effects monitoring program) and the pulp-and-paper mill effluent EEM programs (these are only two of many!). Or, look at numerous ecological risk assessment models. Any of these contain narrative and quantitative guidance on selecting critical effect sizes, or go so far as to stipulate a given effect threshold, above which some policy, regulatory, or operational action/change is required. Focus has an opportunity to really shine here they have acknowledged a very important issue, which no other consultants working in the field of IPP effects monitoring seem to be discussing. 2. The only other thing I can add to MoEs comments on power analysis is how power analysis relates to the idea of effect thresholds. You cannot begin to quantify an effect size of interest without adequate power analysis. Ideally, effect size is determined a priori. Lets say I am only going to care about a 50% reduction (my chosen effect threshold) in parr abundance in the diversion reach relative to whatever (upstream control, a baseline year of interest, etc). Power analysis is going to tell me that my sampling effort will be a lot less than if I want to be able to detect a 20% reduction in that fish population metric.
regards,
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Francesca Francesca Knight, M.Sc., R.P.Bio. Habitat Biologist Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, April 19, 2010 11:50 AM Stoddard, Erin M ENV:EX Bennett, Timothy A ENV:EX FW: Ashlu OPP
Hey Erin, As requested, find below my comments on the Ashlu OPP (Revision A) which Id reviewed on Jan. 8 2010. Ive also attached an email request sent to you, Francesca & Vince from Tim Bennett dated Jan. 8 2010 which sought review of the OPP, but I have no record of a response from any of yall. Similarly, I have no record of Tim having provided our review comments to the proponent but I understand the comments were provided to the proponent a few weeks later.
RE: Ashlu ng-term monitoirng
If there has been a subsequent update to the OPP, I have not received it. Scott
_____________________________________________ From: Babakaiff, Scott C ENV:EX Sent: Friday, January 8, 2010 4:17 PM To: Bennett, Timothy A ENV:EX Subject: Ashlu OPP
Tim, Ive reviewed the Ashlu IPP Operating Parameters & Procedures (OPP) Report (Revision A) dated October 28 2009, and submitted to MOE on November 24 2009. In short, the basic structure of the OPP report (ie. the Table of Contents) seems reasonable, but additional work is required to address: a) information deficiencies and, b) contradictions between text in the OPP and documents referenced in the Appendices (e.g. Water License, DFO Autorization). As you know, I have a relatively narrow scope in review of OPPs (given my relatively narrow expertise), but what its worth, here is the additional work I recommend: 1. Flow Monitoring (p. 3, 23) including IFR verification (p. 11), ramping (p. 7) and maximum licensed flow diversion (not included in OPP)- much more detail is required regarding development (and maintenance) of calibrated rating curves for each of the stream flow monitoring stations, with explicit commitments regarding data collection, archival and submission (including agency notification in the event of shutdowns or IFR deficiencies within 24 hours) be detailed in the OP&P. For instance: regarding continuous stage measurement and digital data logging, Section 3.2.2.3 of the BC Provincial Hydrometric Standards (2008) recommend collection of a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, a much shorter stage sampling frequency is recommended (say, 10-second), with a 2-minute average for storage in the data logger (and submission to agencies). It is also recommended that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment
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damage) do not result in lengthy data gaps. For purposes of graphical presentation in annual monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data. These recommendations regarding streamflow data collection, archival and submission apply to verification of compliance with: IFR, ramping and maximum flow diversion. Suffice to say that details regarding verification of IFR compliance as proposed in the OPP (Attention will also be given to confirm IFR flows by visually comparing the IFR probe reading with the benchmark in the creek at the IFR gauging station per Section 3.1) are inadequate. Likewise, the proposed details regarding verification of ramping rate compliance (Section 2.2.2) provide little detail, and proposed locations (250 m and 800 m downstream of the intake) will not necessarily be those that are of greatest interest to DFO & MOE. 2. Ramping (p.7-8)- Also, Im confused by text in Section 2.2.2 of the OPP concluding that The DFO Authorization for Ashlu Creek stipulates a ramping rate of 90 to 120 minutes for full diverted flow of 29 cms but Actual Ramping Rates will be established during the commissioning process. I understand that a ramping study is scheduled to be undertaken during commissioning, but it seems that the proponent believes that (1) the ramping rates have already been established, and (2) there is no need to describe within the OPP any means of verifying ramping rate compliance. I do not agree with this belief. 3. Shutdowns (p.13-15): number, frequency, duration and cause (e.g. per the types listed on p.23 of OPP) should be documented & submitted to MOE annually. Any shutdowns which result in noncompliance of license conditions (e.g. IFR provision, ramping rates) or fish stranding should result trigger notification to MOE within 24 hours and mitigative prescriptions (e.g. fish salvage) as needed. 4. Fish Passage at dam (p.18): additional detail regarding specific activities to be undertaken to ensure fish passage at the intake such as frequency & timing of fish ladder inspections, methods for inspection, mitigative strategies, etc. Erin Stoddard provided a bit of verbage on this issue for his review of the Upper Harrison OPPs:
Inspections and maintenance of the intake fishway will be undertaken daily to ensure that fish passage is functional during all expected fish migration periods (e.g. April to June for Rainbow Trout). The DFO Section 35(2) authorization requires passage to remain operational at a minimum from April 15th to May 15th eac year. However, depending on flows, temperature, and associated fish activity at the intake fishway will remain open for longer periods and will be maintained operational throughout the year if considered appropriate or as directed by DFO or MOE. Fish counters will be installed at both the upstream and downstream ends of the fishway to assess its effectiveness and record fish movement activity. Fish mortalities associated with the fishway or intake will be reported to MOE and DFO within 24 hours. Inspections, maintenance, and fish movement, stranding and mortalities will be recorded and reported annually. A small boat will be available at the intake daily to cross the headpond to access the fishway when flows are too high to make crossing of the stream practical or safe downstream of the intake. The Long Term Aquatic Monitoring Program will review the annual reports to assess fish movement activity and the performance of the fishway, and will provide a means for MOE and DFO to determine whether fishway changes or replacement is required.
5. Sediment & LWD throughput past the dam (p.8): Section 2.2.3 of the OPP provides some reasonable detail regarding proposed sediment management at the headpond, but it should also include consideration of Large Woody Debris (LWD) management. Maintenance of LWD passage past the dam is explicitly required in the agency approvals. 6. Fish access into the tailrace (p.4)- have fish been: a. explicitly excluded from the tailrace, or, b. are they allowed unimpeded migration into & out of the tailrace without risk of stranding during emergency shutdowns/ramping, or, c. are there some operational details required in the OPP which prescribe activities to be undertaken by the proponent to ensure a) or b)?
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Thanks for the opportunity to provide input, and lemme know if you require any supplemental info or detail, Scott
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From: Sent: To: Cc: Subject: Babakaiff, Scott C ENV:EX Monday, April 19, 2010 4:04 PM 'Knight, Francesca'; Bennett, Timothy A ENV:EX; 'Richard Blanchet'; 'Robert Kulka' Barrett, Scott ENV:EX; 'Busto, Vince'; Stoddard, Erin M ENV:EX; 'gsteeves@ameresco.com'; 'mnelson@cerg.ca' RE: Outstanding Requirements for Ashlu Creek Hydro Project (Water file 2001264)
I dont believe the time & location were finalized, but I believe Tim&I were aiming for mid-afternoon (2PM) in Surrey. FYI, Im at a meeting in Chilliwack until 1230 and I wouldnt be able to make it to North Van until 2303PM. Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Monday, April 19, 2010 3:59 PM To: Bennett, Timothy A ENV:EX; Richard Blanchet; Robert Kulka Cc: Barrett, Scott ENV:EX; Babakaiff, Scott C ENV:EX; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; mnelson@cerg.ca Subject: RE: Outstanding Requirements for Ashlu Creek Hydro Project (Water file 2001264) Hello everyone, if this meeting is going ahead, any chance we could have it in the Innergex offices in North Van? Is a time set yet? thanks Francesca
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: April 18, 2010 9:44 PM To: Richard Blanchet; Robert Kulka Cc: Barrett, Scott ENV:EX; Babakaiff, Scott C ENV:EX; Knight, Francesca; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; mnelson@cerg.ca Subject: RE: Outstanding Requirements for Ashlu Creek Hydro Project (Water file 2001264)
Hi Richard, Thanks for your e-mail. We (Scott, Erin and I) would be available for a meeting this thursday afternoon. However, I suggest that Francesca and Vince should be at this meeting as I understand that DFO has provided comments on the OEMP as well.
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Chessy, Vince: are either of you available on thursday afternoon? Regards. Tim
From: Richard Blanchet [mailto:RBlanchet@innergex.com] Sent: Thu 15/04/2010 10:47 AM To: Bennett, Timothy A ENV:EX; Robert Kulka Cc: Barrett, Scott ENV:EX; Babakaiff, Scott C ENV:EX; Knight, Francesca; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; mnelson@cerg.ca Subject: RE: Outstanding Requirements for Ashlu Creek Hydro Project (Water file 2001264)
GoodmorningTim, IntheabsenceofRobertandbasedonyouravailability,Iamsuggestingtohavethemeetingscheduledfornext Thursdayafternoon(April22nd).Pleaseletmeknowifthatisstillpossibleforyou. Bestregards Richard
__________________________
RICHARD BLANCHET, P.Eng., M.Sc.
Vice President Western Region - Hydroelectric Energy
http://www.innergex.com/logo.jpg
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 228.0855 From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: April 14, 2010 5:19 PM To: Robert Kulka; Richard Blanchet Cc: Barrett, Scott ENV:EX; Babakaiff, Scott C ENV:EX; Knight, Francesca; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; mnelson@cerg.ca Subject: RE: Outstanding Requirements for Ashlu Creek Hydro Project (Water file 2001264) Importance: High
HiRobert; ThankyouforprovidingarevisedOEMP(RevisionC,datedMarch2010)fortheAshlufacility,whichisintendedto addressMoEsearliercommentsonthepreviousrevisionB,datedandsubmittedNovember2009. StaffhavecompletedtheirreviewoftheOEMPandprovideddetailedcomments,attachedintheemailchain below.Insummary,itdoesnotappearthattherevisedOEMPfullyaddressourpreviouscomments,andthe followingobservationshavebeenmade: Apparentinconsistencybetweenproposedmethodology/monitoringandreferencedguidelines(e.g.,rating curves,etc); Concernsaboutproposedrampingratesvscriteriaincurrentuse(e.g.,defaultratesacceptedbyDFO),and thetimingoffutureproposedrampingstudies;
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insufficientdetail/quantificationofbaselinedataandnoanalysestodeterminewhetherthisdataandthe proposedmonitoringprogramcanbeusedtodrawscientificallydefensibleandstatisticallyvalidconclusions regardingimpacts; apparentincompletionofprediversionactivitieswhicharerequiredforimpactandcompliancemonitoring andassessment;and, insufficientdetailandinferred/suggested(over)relianceonprofessionaljudgementorqualitative assessment,ratherthanrigorousquantitativeassessment. Pleasereviewandcarefullyconsiderallofthedetailedcomments(intheemailchainbelow). IalsonotethatyourcoverlettersuggeststhatyouunderstandthattheOEMPisthelastremainingdocument requiredpriortomyissuanceofaLeavetoCommenceOperation(LTCO),andthatyouwouldliketoreapplyforthe LTCO.IwouldliketoclarifythatthefollowinginformationmustbesubmittedpriortoyourobtainingaLeaveto CommenceOperationsforthisproject: 1. amonitoringplansuitabletodeterminethenatureofanyimpactsfromoperations(OEMP); 2. amonitoringplantoconfirmthatinstreamflowrequirements(IFR)arereleasedattheintakeand observedwithinthestream[currentlyspecifiedwithintheOPPand/orOEMP];and, 3. aplandocumentinghowworkswillbeoperatedandmaintained(OperatingParametersandProcedures manual,OPP). Withregardtothelastitem(#3),IwillbeforwardingdetailedcommentsontheOPPmanualearlynextweek. Theinformationoutlinedinitems#1to#3,above,mustbesatisfactoryto,andacceptedby,theRegionalWater ManagerorAssistantRegionalWaterManager.Icurrentlyconsiderthattheseinformationrequirementshavenot beenmet,andamnotwillingtoconsiderissuanceofaLeavetoCommenceOperationsatthistime. Pleasedonothesitatetocontactmetoarrangeacallormeetingtodiscussthesecomments,itemsand/ornext steps.IamcurrentlyavailablenextWednesdayorThursdayafternoon;however,Isuggestyoucontactmeviae mailtosetupameetingordiscussiontimeasIwillbeinmeetingsandoutoftheofficeuntilnextTuesday. Regards,
TimothyBennett,M.Sc.,P.Eng. AssistantRegionalWaterManager WaterStewardshipDivision MinistryofEnvironment
From: Stoddard, Erin M ENV:EX Sent: Wednesday, April 14, 2010 12:02 PM To: Bennett, Timothy A ENV:EX Cc: Barrett, Scott ENV:EX; Babakaiff, Scott C ENV:EX; 'Knight, Francesca'; 'Busto, Vince' Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
Tim, GeneralandspecificcommentsontheMarch2010versionoftheOperationEnvironmentalMonitoringPlanforthe abovereferencedprojectareprovidedbelowandadditionalspecificcommentsareimbeddedwithinScott Babakaiffsattachedemail. 1. Thedocumentmakesreferencetoqualitativeassessmentsorprofessionalobservationsinseveral sections.Thisisaninappropriateapproachthatprovidesnoopportunitiesforanalysis,noassurancethat assessmentswouldbecompletedconsistentlythroughthetermoftheprogram,andthedatacouldnotbe usedtodetermineeffectorimpactafterthe5yearterm.

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2.
Themonitoringoffishwayaccessanduseneedstobequantitative,notbyobservation.Thissection (5.7.2.1)needstobeextensivelyrevised,andshouldincludethemonitoringandmanagementofthe approachesthroughfloworchannelrevisiontoensurethatpassageisprovidedandeffective.The managementandmaintenanceofthefishwayandensuringitseffectivenessshouldalsobeincludedwithin theOPP. 3. Asaresidentfishpopulationextendsintoandbeyondthefacilityheadpond,themonitoringprogram shouldincludemonitoringtheeffectsofmanagementandmaintenanceoftheheadpond,includingbutnot limitedtosubstratestabilityandheadpondflushing.Themanagementoftheheadpondandmitigationof impactstofishandfishhabitatfrommaintenanceactivitiesshouldalsobeaddressedintheOPP. 4. Themonitoringandmanagementofthetailraceshouldbeincorporatedintotheprogramtoensurethat accesstofishisrestricted.Ifrestrictionisnotpossible,thentheprogramshoulddescribeindetailhowthe tailracewouldbemonitoredandmanagedtomitigatefishstrandingandkills.Themonitoringand managementofthetailraceshouldalsobeaddressedindetailintheOPP. AswithScott,Icouldcontinuewithmyreviewandprovidespecificdetailsofalltheinadequaciesofthismonitoring program;however,Iunderstandthattheproponentisanxioustoreceivefeedbackonthisrecentversionofthe document.Pleasecontactmeifyourequireclarificationoradditionalinformation. Sincerely, ErinM.Stoddard,R.P.Bio.
From: Babakaiff, Scott C ENV:EX Sent: Tuesday, April 13, 2010 2:06 AM To: Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Barrett, Scott ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Hi Tim, Per your request (and in anticipation of our meeting on Tuesday afternoon), I've competed a more detailed review of the latest OEMP iteration (Revision C) for the Ashlu IPP. You may recall that I sent a short email a few weeks ago indicating that the latest iteration did not address the deficiencies I'd previously identified in Revision B back in December 2009. So, here's a point-by-point review of Revision C in comparision to my December 2009 comments on Revision B (review comments on Revision B shown in italics): "Ive reviewed Revision B of the Operations Environmental Management Plan for the Ashlu Creek project (dated November 2009) as submitted by Innergex. The document is hereafter referenced simply as the OEMP since there is no authorship or bibliographic detail included. The absence of any explicit authorship is notable: there is little evidence that the OEMP has been composed by a licensed professional (e.g. RP Bio) with experience in the development or implementation of a monitoring program intending to fulfill agency needs. In short, the OEMP is typical for a preliminary draft, but it is troubling that completion of project construction & commissioning is imminent." Revision C has been composed by Focus Environmental Ltd. , but no individual author is named. Given the corporate structure of Focus Environmental, it seems safe to assume that the author is Bill Johnson (a RP Bio.) but this detail should have been provided.
Forconsistencyandaccountability,allsubsequentdocumentsshouldbesignedbyanappropriatelyqualified professional(s)ascommittedtobytheproponent.Thesignatoriesofthisdocumentshouldonlybedevelopingand signingoffonthesectionsofthedocumentthattheyarequalifiedtoprovideadviceon.

"Regardless, I have several primary concerns with the OEMP: 1. Few commitments to follow commonly-accepted guidelines for data collection & analysis, despite a proposal that monitoring details meet the requirements of DFO and MOE (p. 6 of the OEMP). I suggest many details proposed in the OEMP are seemingly arbitrary and do not reference any guidelines or standards typically referenced by Provincial or Federal agencies.
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Revision C certainly includes more details than Revision B: a simple glance at the Table of Contents would allow this conclusion. Whether much of this detail is required is certainly questionable, but leaving that aside, I appreciate that Revision C similarly includes more commitments to follow commonly-accepted guidelines for data collection & analysis (e.g. text in Section 5). However, the details of data collection & analysis tabulated in the respective sub-sections of Section 5 are often inconsistent with the details of the respective guidelines (e.g. hydrometric guidance in Section 5.1). I'll suggest that this represents a lack of due dilligence rather than any intentional deceit. However, it is interesting that Section 5.0 (p.15) of Revision C includes the retrospective explanation that "baseline studies were carried out from 2001 to 2006 by Sigma and TRC Biological Ltd (TRC, 2005) according to B.C. Resource Inventory Standards Committee (RISC) standards, but prior to the Provincial guidelines compiled by Hatfield et al (2007)". This is a very generalized statement, and the author of Revision C does not provide any detail or supporting evidence for the claim of 'RISC standards' being met (ie. which RISC standards and for which components?). Nor does the author indicate how these RISC standards may or may not apply to the collection & analysis of data at this particular site. For example, RISC standards in 2006 did not include detailed guidance determination of stage-discharge rating curves, nor did they include guidance regarding recommended protocol for the collection of fish abundance data at sites such as Ashlu (ie. cold, deep, silty, low-conductivity streams) where standard methods (ie. electro-shocking) may be inappropriate. For instance: 1. Stage-discharge rating curves- the OEMP commits to collecting a minimum of three discharge measurements and warns that ...it is unlikely that flows will be able to be measured above 20% of mean annual discharge. There are clear and well-established guidelines for developing stage-discharge rating curves (e.g. LWBC Hydrometric Guidelines; B.C. Provincial Hydrometric Standards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometri c%20Standards%20V1.0,%20March%2012,%202009.pdf) that the proponent is recommended to meet. Section 5.1.2 includes reference to appropriate guidance (RISC, 2009 & LWBC, 2005) for development of stage-discharge rating curves at the three proposed hydrometric stations, but explicit work to be undertaken to develop rating curves (e.g. 'three measurements' per Table 2 in Section 5.1.2) is inadequate and not consistent with provincial guidance. In fact, Section 5.1.2.1 of Revision C indicates that two of the three gauges have yet to be installed (so the rating curves have not yet been established), and Revision C indicates that 'calibration' of the gauge proposed for verifying compliance with IFR & ramping rates (WQ1) has already been completed by Northwest Hydraulic Consultants Ltd.(December 9 2009 report) but I do not believe this work has been reviewed & accepted by MOE. Text includes within Section 2.8 of Revision C suggests that the proponent may have a different understanding of IFR gauge calibration than the standard expected by MOE for streamflow measurement (" The sensor was tied into a benchmark in November 2009 following calibration of the 2.42 m/s IFR required under the DFO Authorization. The benchmark serves as a visual reference to calibrate the level probe") . The absence of an agency-approved rating curve and data collection protocol calls into question the reliability of streamflow data provided to date, including verification of compliance with IFR provision, so I recommend that the work be completed & submitted for MOE review ASAP, with no provision of final leaves to commence operation until the rating curves have been reviewed and accepted by MOE. Rating curve development for all three proposed gauges must be completed by a licensed Professional with appropriate training and experience in the collection & analysis of stream discharge data. The OEMP (and OPP) should also include a commitment to complete ongoing discharge measurements at each station to allow verification of the rating curve (or re-development of a rating curve, if need be) per the latest (2009) RISC standards. I can provide more detail to the consultants if need be. 2. Reporting of stream flow data: the OEMP commits to collect to collect flow data on a continuous basis, typically in 15-minute intervals and promises that data will be recorded...and can be provided to onsite DFO and/or MOE staff...for compliance purposes...flow data will be reported quarterly. I suggest there is no need to submit data to review agencies more frequently than once per year, but agencies must be informed within 24 hours of any non-compliance (e.g. IFR provision, ramping rates), and the proponent must resolve the issue of non-compliance immediately. In terms of data collection&logging, I note that the BC Provincial Hydrometric Standards (Section 3.2.2.3) recommends a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, particularly those with the diversity of fish values in the Ashlu diversion reach, I would recommend a much shorter stage sampling frequency (say, 10-second), with a 2-minute average for storage in
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the data logger (and submission to agencies). I would also recommend that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment damage) do not result in lengthy data gaps. For purposes of graphical presentation in monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data. Section 5.1.3 of Revision C includes more detail than previous iterations, but still does not address the deficiencies identified in Revision Revision B (see above). Of greatest concern is the absence of a commitment to inform MOE within 24 hours of any non-compliance with water license conditions (ie, IFR provision, ramping rates) and immediately address any issues of non-compliance. Instead, Revision C simply commits to having the data available for agency review, if need be, along with annual submission: this is obviously inadequate. Also, Table 2 does not include any explicit commitments to the sample averaging intervals to be applied, despite my previous comments requesting such detail. I'm left with the impression that the author of Revision C has either not been provided with my previous review comments, or has wilfully ignored them. 3. Development of ramping rates: Section 12.2 of the OEMP proposes that the ramping rates shall not exceed 29.0 cms per 90 minutes. This rate will be established during the commissioning process of the plant, and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991.... The OEMP provides some detail regarding proposed methods for establishing ramping rates during commissioning, but I would suggest that such protocol (and such interim rates like 29 cms per 90 minutes) should be established and scientifically-justified by an experienced professional, with reference to established agency criteria (e.g. DFOs default hourly ramping rates of 2.5 cm & 5.0 cm for fry & juveniles) or recommended guidelines. Finally, I suggest that the commitment within Section 14 of the OEMP to submit the ramping rate report six months after commissioning represents an inappropriate risk to fish & fish habitat given the rapid interim ramping rate proposed and the fish values present in the diversion reach.
Ramping rate monitoring is proposed in Section 5.1 of Revision C, but again, the streamflow gauges proposed for monitoring of the ramping rates have either not yet been installed (WQ2, WQ3) or lack agency-approved rating curves (WQ1, WQ2, WQ3). Text within Section 5.1 of Revision C also suggests that the proponent is aiming to simply "track ramping rates during shut down" and may not fully understand that they will be obligated to verify compliance with ramping rates that will not harmfully alter or disrupt fish & fish habitat. It is also my understanding in the ongoing absence of a detailed ramping rate assessment, the proponent will be obligated to follow the DFO default standards (2.5 cm/hour when fry are present, 5.0 cm/hour otherwise) but there is no reference in Revision C to this standard.
Thelackofappropriatelycalibratedflowmonitoringequipmentandagencysupportedrampingrateshasthehigh potentialtoresultinsignificantimpactstofishandfishhabitat,includingfishkills.Thisshouldbeaddressedand confirmedinthenextversionofthedocumentandresolvedpriortooperation.

4. Fish Abundance (Section 7) & Invertebrate Density (Section 8): no methodological guidelines for data collection or analysis are proposed, despite the bibliographic reference in Section 16 of the OEMP to Hatfield & Lewis (2007). The MOE-ESD information checklist provided in the Provincial IPP Guidebook also provides supplemental guidance for OEMP development. It is my understanding that the baseline biological data collected in recent years did not follow any particular protocol, but was undertaken by several different biologists in different locations, using different methods. As such, it is imperative that all baseline data be collated and assessed by a professional biologist with experience in the relevant specialization (ie. fisheries biology, macroinvertebrate biology), and compiled for assessment regarding its adequacy as a baseline to assess future changes that may be attributable to operation of the IPP facility.
Revision C includes an update on biological data collection undertaken since provision of the Water License & DFO Authorization (July 2006) : none. It includes some qualitative summaries of the baseline fish abundance & macroinvertebrate data collected in 2001-2004, but very little quantitative summarization. Section 5.3.1 of Revision C provides qualitative summaries of baseline fish habitat work (Section 5.3.1), and concludes that "Sampling and reporting standards and protocols for the inventory and analysis of fish habitat were available at the time Sigma conducted baseline programs, such as Fish Habitat Assessment Procedures (FHAP) outlined in Johnston and Slaney (1996) and the Reconnaissance1:20,000 Fish and Fish Habitat Inventory: Standards and Procedures (RIC, 1999a, 1999b, and RISC, 2001). Sigma (2002) did not refer to these documents, although we suspect, given
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the type of discussion in Sigma (2002 and 2004a) that they were aware of them, but simply omitted to reference them". Of course, an alternative explanation is that no specific set of guidelines were followed by the consultants in completion of the baseline studies, which I recall was the conclusion generated in MOE's review of the baseline studies back in 2004. It is proposed in Section 5.3.2 of Revision C that such qualitative fish habitat summaries persist as a component of operational monitoring. Similarly, Section 5.4.1 includes a summary of baseline fish sampling efforts, which seems to represents a total baseline effort in the diversion reach of approximately seven site visits over 14 days in 2001, and some follow-up work in 2002 (effort unquantified). It is subsequently concluded in Section 5.4.1 of Revision C that "Sigma conducted salmon spawning surveys in Reach 1 in 2003 (see Sigma2004a). It appears no further fish sampling was conducted by either Sigma or TRC". Section 5.4.2 includes several pages of proposed future (post-diversion) fish monitoring efforts, but given the negligible baseline data collection efforts conducted to date, I question the utility of such information to "determine the nature of any impacts of the project on fish" (per the water license). However, I'll leave any detailed consideration of proposed fish and macroinvertebrate baseline sampling effort to agency biologists in ESD (Erin Stoddard, Scott Barrett) or DFO (Francesca Knight). Finally, I suggest that any reference to informing DFO of any fish mortalities related to project operations (ie. Section 5.4.3) should also include a commitment to inform MOE.
Alackofadequatebaselinefishpopulationassessmentisnoexcuseforproposinganinadequate,inconsistentand inappropriatefishmonitoringprogram.Consistentdetailsofeffortincludingaadequatenumberofsamplesites, appropriatemethodrecommendationsandproperanalysisshouldhavebeenprovidedwithalevelofintensity necessarytoconfirmeffect.Thiswascommittedtobytheproponent,butwasnotprovidedinVersionC. Thereshouldnotbeanyopportunitiestochangeanyofthemonitoringparametersbasedonprofessional judgmentorconsultationwiththeagencies.Theplanshouldbedevelopedproperlyandapprovedbythe agenciessothatdatacanbeadequatelycollectedandanalyzedsothatitcanbeshownbytheproponentthatthere wasnoeffect/impactsbeyondwhatwasexpected. Baselineandfishcommunitydatacollectionshouldincorporateaproperlydevelopedmarkrecaptureprogram. Onlymethodsincludingthreepassremovalelectrofishing,nightsnorkelingandintensiveminnowtrappingshould beproposed.Allfishsamplingshouldincludesignificantsamplinginallreachesandallhabitattypesofconcern includingcompensationhabitats.Thesamplesites,effortandmethodsproposedintheVersionCprogramare considerablyinadequateorinappropriate. Someappropriatebaselinedatacouldbecollectedwithguidancefromanappropriatelyqualifiedprofessional duringthecurrentlowflowperiod.However,opportunitiesforcollectingthisdataareveryshortpriortohigh water,andlikelywillnotextendbeyondthenexttwoweeks,weatherdependent.Thenextlowerflowopportunity wontbeavailableuntiltheearlyfall(notaslow)orwinter.
2. No baseline data or power analysis: the adequacy of the monitoring details proposed in the OEMP (e.g. duration and frequency of sampling, expected natural variability, sample sizes, methods of analysis, a priori agreement on ecologically-acceptable thresholds of dependent variables, corrective/compensatory measures to be adopted upon threshold exceedance, monitoring program budgets, etc. ) cannot be objectively considered without preliminary analysis of baseline data, including statistical power analysis. In the absence of such analyses, particularly for the biological data described in Sections 6&7 of the OEMP, I have little confidence in the adequacy of prediversion baseline data described in the OEMP to assess any diversion-induced changes in these biological response variables. Revision C does not include any quantitative analysis of baseline data or power analysis on fish abundance. This is not surprising, given the baseline dataset described in Section 5.4.1 of Revision C. I suggest that it is either naive or misleading to justify the absence of a power analysis on "low fish capture numbers during baseline sampling in the Project area" and to subsequently suggest that "there may be insufficient baseline information to apply the BACI approach with any statistical reliability...since fish capture numbers were low during baseline sampling". It seems more likely that it was it is inadequate sampling effort, not necessarily low fish numbers, that have resulted in the inability to apply the BACI approach or to complete a power analysis on fish abundance data. Rather than proposing that "only trends in fish community metrics can be used for comparison with baseline", I suggest that an appropriate level of diligence would include proposal of a detailed fish data collection program prior to diversion that would address this deficiency in baseline
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data. The proposal in Section 5.4.2.2 of Revision C that "Quantitative multivariate analysis of the data with power analysis to assess the biological change will be performed if possible" doesn't meet agency needs to assess the likelihood that the proposed monitoring program will be adequate to allow statistical resolution of project-related impacts to fish.
Theanalysisandjustificationfortheproposedfishcommunitytrendanalysisisinappropriate,andtheproposed trendanalysisisalsoinappropriatetodeterminepotentialeffectsorimpacts.Adequatebaselinefishcommunity datashouldbecollectedpriortooperationsuchthataproperfishmonitoringprogramcanbedeveloped.

3. Details of monitoring commitments tabulated in the Appendix of the OEMP do not seem congruent with text in the body of the OEMP. For instance, page 3 of the OEMP clearly states: In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. However, monitoring proposed for some components (e.g. biological components from Tables 3-5 of the OEMP) have been copied verbatim from the guidelines (which, incidentally, are not referenced correctly) and subsequent case study (Trout Creek), so it is unclear what aspects of the monitoring criteria will or will not be undertaken per the OEMP. Monitoring commitments tabulated in Revision C are relatively congruent with the associated text, but (as described above) there are many instances where these commitments refer to consistency with Provincial Guidelines, when such consistency may not be achieved by tabulated protocol (ie. sampling, analysis). 4. Pre-diversion activities which may require several months to complete have yet to have been initiated. For instance: 1. installation of the four pressure transducers (per Section 4.2.1 of the OEMP) and development of associated rating curves for water flow (Section 4) and instream flow (Section 11) monitoring; As described above, gauge installation & rating curve establishment has still has not yet been completed. 2. Collection of stream channel morphology data (per Section 10 of the OEMP). This component of the OEMP is particularly ill-defined: there are no explicit guidelines or standards referenced, and I also question the proposed benefits of completing repeat surveys at a few transects to assess whether the IFR is affect any of the fish habitat as was originally predicted. Assessment of changes in channel morphology related to project operations (e.g. flow diversion, changes in sediment and LWD transport rates and volumes, etc.) is crucial, but should be considered more holistically using low-level air photos and longitudinal survey profiles. Again, it is recommended that an professional experienced with development of channel monitoring programs (ie. a fluvial geomorphologist or river engineer) be tasked with developing the study design and undertaking the work prior to final commissioning;
Section 5.6.1 of Revision C clearly states what baseline data has been collected: "Geomorphology studies designed specifically to establish bed load transport and deposition characteristics through the Project area were not conducted as baseline prior to construction of the Project". This certainly doesn't preclude collection of such 'baseline' data prior to initiation of operations. However, the data collection program proposed in Section 5.6.2.2 of Revision C will not meet agency goals of resolving whether changes to sediment & LWD transport associated with project operations have impacts fish & fish habitat in reaches downstream (and potentially upstream) of the project. I strongly suggest that a more careful consideration of the proposed channel morphology data collection & analysis program be undertaken by a professional experienced in fluvial geomorphology, with reference to the baseline data collection program recommended in my review of Revision B (ie. site surveys and aerial methods such as low-level photography or LIDAR).
Allflowmonitoringequipmentinstallationandsetup,andgeomorphology/habitatassessmentsneedtobe conductedpriortooperations.Thisistoensuretheavailabilityofadequatebaselinedatatodevelopthemonitoring programandthendetermineeffect/impactonaquaticspeciesandtheirhabitatspostoperation.

Again, as per my review of Revision B, I suggest that the examples I've provided regarding deficiencies in Revision C do not represent the full suite of deficiencies; they were simply the most obvious shortfalls within my area of expertise. A more complete suite of review comments may be available through consultation with other ESD staff (ie. Erin Stoddard & Scott Barrett), WSD staff (e.g. Jim Davies) or our Federal counterparts (e.g. Vince Busto & Francesca Knight). Revision C is certainly an improvement on Revision B, but it is unfortunate so many deficiencies in the OEMP persist. It is also unfortunate that it has become apparent that no baseline fish&fish habitat data has been
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collected in the last eight years. I remain unconvinced that the monitoring program as proposed in Revision C adequately addresses Conditions i(2) of the Water Licence which "Requires a monitoring program suitable to determine the nature of any impacts of the project on fish and wildlife" and i(3) which requires a monitoring program to evaluate the effect of the regulation of works as ordered in number 1 above. Scott
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thu 18/03/2010 4:40 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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From: Sent: To: Subject: Attachments: Babakaiff, Scott C FLNR:EX Thursday, April 21, 2011 4:04 PM Barrett, Scott FLNR:EX FW: Ashlu April 20, 2011 non-compliance update image002.jpg; image001.jpg
FYI: lotsa dead fish from yesterdays Ashlu episode...will be interesting to see DFOs response.
From: Matt Henderson [mailto:MHenderson@innergex.com] Sent: Thursday, April 21, 2011 3:56 PM To: Bennett, Timothy A FLNR:EX Cc: Knight, Francesca; vince.busto@dfo-mpo.gc.ca; Babakaiff, Scott C FLNR:EX; Stoddard, Erin M FLNR:EX Subject: Ashlu April 20, 2011 non-compliance update
Tim, PleaseseebelowforanupdatefromEcofishonyesterdaysfloweventatAshlu. Thanks, Matt

Matt Henderson Environmental Coordinator
INNERGEX Tel : 604 984-8600 | Fax : 604 984-8699 | www.innergex.com
From: Elyse MacDonald [mailto:emacdonald@ecofishresearch.com] Sent: April-21-11 3:33 PM To: Matt Henderson Cc: fjalewis@ecofishresearch.com Subject: Ashlu results today
HiMatt, WearrivedatthedownstreammonitoringsitesatAshluat~10:30amtoday.Wesearched7sitesforatotalof700 m2andfound23deadfish.Twoofthesiteswesearchedtodayweresearchedyesterday,when16deadfishwere found,foratotalof39deadfishfoundinthedownstreamreach. Hereisabreakdownofourresults,whereDSSD04and05areourpreestablishedmonitoringsitesand0812are sitessearchedtoday,downstreamof04and05butwithinthereconnaissanceareas1and2inourMay2010report. DSSD040deadfishfoundyesterday;3deadfishfoundtoday.Allfishingoodconditionandlikely strandedduetoramping. DSSD0516deadfishfoundyesterday;8deadfishfoundtoday.Allfishingoodconditionandlikely strandedduetoramping. DSSD08nodeadfishfoundtoday DSSD098deadfishfoundtoday;allinpoorconditionandpossiblynotduetoyesterdaysramping. DSSD10nodeadfishfoundtoday DSSD112deadfishfoundtoday;allinpoorconditionandpossiblynotduetoyesterdaysramping. DSSD122deadfishfoundtoday;allinpoorconditionandpossiblynotduetoyesterdaysramping.
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Insummary: 16deadfishfoundyesterdayinourestablishedmonitoringsitesandlikelystrandedduringramping. 11deadfishfoundtodayinourestablishedmonitoringsitesandlikelystrandedduringramping. 12deadfishfoundfurtherdownstreamthanourestablishedmonitoringsites.Allbutoneofthesefishwere inpoorconditionandpossiblynotstrandedduetoramping.Theonefishfoundingoodconditionmayhave beenstrandedduetoramping. Atotalof28fishmayhavebeenstrandedduetoyesterdaysincidentand11fishwerefounddeadbutpossiblynot duetorampingstagechanges.Approximately718m2wassearchedtodayand190m2yesterdayforatotalareaof 908m2and39deadfishfound.Wealsoobservedseverallivefishinoursearchsites. Pleaseletmeknowifyouhaveanyquestionsorconcerns. Thankyou, Elyse MacDonald, B.Sc., R.P.Bio., CPESC Environmental Biologist, Project Manager
Ecofish Research Ltd.
emacdonald@ecofishresearch.com www.ecofishresearch.com
Suite 1000 355 Burrard Street, Vancouver, BC, V6C 2G8 Voice: 604 608-6180; Fax: 604 608-6163; Cell: 604-785-6726 F-450 8th Street, Courtenay, BC, V9N 1N5 Voice: 250 334-3042; Fax: 250 897-1742 This email contains confidential information that is proprietary to Ecofish Research Ltd.. This information is intended only for the person(s) named in the destination address. Unauthorized distribution, copying or disclosure is strictly prohibited. If you receive this e-mail in error please delete it immediately.
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Response Records Part 2

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Russell, Veronica A ENV:EX

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Russell, Veronica A ENV:EX

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

Attention: Via Email: Subject:

Background (from email provided by Ashlu Creek Investments)

water resource specialists

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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP December 9, 2009 Revision B Page 2

IFR Pipe Outlet

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.

Photograph 3 View of the IFR from above

Photograph 4 Measurements were recorded using a Pitot tube.

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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP December 9, 2009 Revision B Page 3

Figure 1 Measured and theoretical velocity distribution. Discharge = 2.05 m3/s

Figure 2 Measured and theoretical velocity distribution. Discharge = 2.90 m3/s

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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP December 9, 2009 Revision B Page 4

IFR Inlet Gate Operation

northwest hydraulic consultants

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Russell, Veronica A ENV:EX

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Russell, Veronica A ENV:EX

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1. Inconsistent IFR provision, with a reasonable likelihood of non-compliance: NHCL

Site 1. Twin Bridges 2. Powerhouse 3. km 4.0 4. Mile 25 bridge

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but am available to discuss this review later

HiScott, Whenyouhaveachance,canyoupleaseletmeknowifyouhaveanycommentsonthematerialsenttousre:the AshluOEMP? Thanks!

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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

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Russell, Veronica A ENV:EX

Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

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Birchard, Leona ENV:EX

an artfully crafted understatement... C

Tim, Scott, and Francesca