470 Granville Street, Suite 630, Vancouver, BC V6B 1N3 t 604-629-9075 Memorandum Date: December 18, 2013 To: Jesse McCormick Donovan & Company Project: Site C Project From: Palmer Environmental Consulting Group cc Brian Kopach MSES Inc. Subject: Review of Site C Environmental Impact Statement (EIS) - Fish and Fish Habitat Dear Mr. McCormick, Palmer Environmental Consulting Group Inc. is pleased to provide our review of the fish and fish habitat mitigation measures proposed by BC Hydro for the Peace River (upstream of the dam) and the Moberly River, as requested in the Technical Support Description provided by Donovan & Company on behalf of the Saulteau First Nations (SFN). The purpose of the review was to identify any deficient mitigation measures, and to provide recommendations for potential mitigation enhancements for the Joint Review Panel (JRP) meeting scheduled for January 13, 2014. Methods: The review of fish and fish habitat mitigation measures was conducted using documents listed in the Technical Support Description, and found on the BC Environmental Assessment Office website: Site C Clean Energy Project Environmental Impact Statement- Volume 2: Assessment Methodology and Environmental Effects Assessment Section 12: Fish and Fish Habitat Volume 2, Appendix O, Fish and Fish Habitat Technical Data Report Volume 2, Appendix Q, Fish Passage Management Plan Volume 2, Appendix P, Aquatic Productivity Reports Site C Clean Energy Project Environmental Impact Statement - Volume 3: Economic and Land and Resource Use Effects Assessment - Section 24: Harvest of Fish and Wildlife Resources Information Request No. 1: JRP Request (IR1-20), BCH Response (IR1-12 & 14-20), BC Response (IR13) Information Request No. 2: JRP Request (IR 21-74), BCH Response (IR 21-74) Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 1
December 18, 2013 Jesse McCormick Memorandum Information Request No. 3 (Part 1): JRP Request (IR 75-95 and Supplemental Request S26-68), JRP Clarification to IR 85, BCH Response (Part One), BCH Response (Part Two) EBA Engineering Technical Memo on Sufficiency Review The environmental assessment documentation provided by BC Hydro is notably vast and detailed, making an analysis of every potential issue unrealistic for the purposes of this review. Instead, four key areas were identified as requiring discussion following a high level review of the reference materials, and consultation with the SFN legal counsel representative. These key areas were selected based on their relevance to SFN priorities including the primary fish species of concern, and the priority areas of SFN land users as described in the Technical Support Description provided by Donovan & Company. Supporting documents pertaining to these four areas were analyzed in the context of facilitating the discussion of potential mitigation deficiencies and recommendations: 1. Fisheries Productivity Offsetting (i.e., compensation) 2. Fish Population Modelling 3. Fish Stranding 4. Riparian Vegetation Key Issues and Recommendations: Commentaries for these four areas, including the potential environmental issues, key points, and recommendations for the JRP are provided below: 1.0 Fish Productivity Offsetting 1.1 Issue: Habitat alteration from riverine to reservoir due to inundation of the mainstem Peace River and downstream sections of the Moberly and Halfway Rivers will potentially lower fisheries productivity or extirpate local fish populations including the Moberly River Arctic grayling, Halfway River bull trout and Peace River mountain whitefish populations. 1.2 Key Points: There is currently no fisheries offsetting plan provided to indicate how effects to valued component fish species will be compensated Information Request No. 11 was an enquiry of the missing Fish Habitat Compensation Plan. The response from BC Hydro was very limited and did not provide sufficient detail given the current stage of the project. A general compensation plan including goals, target species, locations, and general methods should be a priority for development in order to facilitate meaningful discussion with the SFN Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 2
December 18, 2013 Jesse McCormick Memorandum 1.3 Suggested Recommendations: BC Hydro should develop an offsetting plan to address the potential effects on Arctic grayling, bull trout, and mountain whitefish productivity. SFN priorities including fish species of concern in local habitats should be considered during offsetting plan development. For example, compensation could focus on enhancing habitat for locally harvested species that will be reduced or extirpated due to project effects such as Arctic grayling. In addition, potential offsetting locations could include the enhancement of SFN fisheries in Moberly Lake, Moberly River, or the Peace River (e.g., habitat enhancement or creation). The offsetting plan should also consider research programs with the aim of identifying any critical informational gaps which will aid in directing and prioritizing future compensation efforts. The SFN should be engaged in guiding research priorities, and trained as technicians for assisting in the field research. 2.0 Fish Population Modelling 2.1 Issue: The Site C dam construction and operations will have wide ecological implications for fish abundances and population composition. Fish population models have been conducted for identified species of concern to determine if population-level conservation objectives will be met following dam construction. 2.2 Key Points: Vol. 2, App. Q3: Species-specific fish passage models were completed for Arctic grayling, bull trout and kokanee. Vol. 2, App. Q3, P. 21-24, 29-31: The developed models are deterministic age-structured models which do not provide sufficient justification or explanation regarding the following points: Basis for parameter assumptions, including validation methods. The robustness of these parameters depending on the chosen input values (e.g., sensitivity testing). The models as described do not include the potential for dynamic interactions, such as the change in number of recruits depending on spawner density. For example, the Arctic grayling model uses a fixed recruitment of 1000 recruits per spawner (Vol 2. App. Q3, P. 30), and the bull trout model stipulates that the number of age-3 recruits is independent of the number of spawners (Vol 2. App. Q3, P. 20). Vol. 2, App. Q3, P. 20 and 30: Beverton-Holt stock recruitment models were employed in fish population modelling. However, the Ricker stock-recruitment model is more sensitive to changes in stock abundance, and is the most commonly employed model for predicting relationships for salmonid species (e.g., Arctic grayling and bull trout). Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 3
December 18, 2013 Jesse McCormick Memorandum Risk-based models developed for bull trout can be employed as a secondary comparative model. Using this approach, minimum acceptable population sizes can be predetermined with respect to maintaining a sufficient population for harvesting. The use of a risk-based model would have significantly helped in establishing the worth of the chosen modeling approach. 2.3 Suggested Recommendations: Fish population models should be adapted to incorporate stochastic biological relationships, for example varying the number of recruits systematically depending on spawner density. The models should undergo rigorous sensitivity testing to evaluate parameter assumptions, including the computation of elasticity measures. In addition, the prediction uncertainty bounds need to be presented in a clear manner for assessment. Provide clear, scientific justification and validation of model parameter assumptions in order to assess their effectiveness at predicting population changes. Use a Ricker stock-recruitment model in addition to the Beverton-Holt model employed. Use a secondary risk-based model developed previously for bull trout for comparison with the abundance-based model (e.g., Staples, D. F., Taper, M. L. and Shepard, B. B. 2005. Risk-based viable population monitoring. Conservation Biology. 19:1908-1916). 3.0 Fish Stranding 3.1 Issue: Due to reservoir creation, and regular water level fluctuations during operations, fish stranding is an ongoing concern. 3.2 Key Points: Vol 2. Sect. 12, P. 12-68: Proposed surveillance and re-location measures for stranded fish are standard. A better description of frequent site surveillance and triggers for surveillance should be made available. Depending on stranding conditions, stranded fish may have minutes to days before stranding conditions result in death. Vol 2. Sect. 12, P. 12-77: It is not clear that collection and relocation programs to offset the effects of stranding will be fully effective as claimed. Any program will be bias toward larger bodied fish and more effective in quiet water, littoral habitats. The mitigation may offset the effect, but it will not eliminate it because of the sampling biases inherent in standardized fisheries field techniques. 3.3 Suggested Recommendations: Provide further detail of the fish salvaging program to support claims that the effects of stranding will be fully mitigated, including: Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 4
December 18, 2013 Jesse McCormick Memorandum Frequency of surveillance: when and how often? Triggers for surveillance Design of the re-capture program Fishing gear types used various methods should be employed to reduce gear sizeselectivity Emergency draindown protocol Include estimated fish mortality from stranding in population estimate modelling. 4.0 Riparian Vegetation 4.1 Issue: The conversion of the Peace River into a reservoir will promote the loss of a large area of riverine riparian vegetation. Regular water level fluctuations will reduce the function of new reservoir riparian vegetation. 4.2 Key Points: Vol 2. Sect. 12: There is no attempt to assess riverine riparian habitat loss or the functionality of a fluctuating water line. New lacustrine riparian habitat will be limited in comparison due to the high surface area: shoreline length ratio in the reservoir. A fluctuating shoreline will reduce riparian habitat functionality including shade and protective cover for fish. 4.3 Suggested Recommendations: BC Hydro should provide an estimate of the quality and quantity of riparian habitat lost They should also provide an analytical discussion of how lacustrine riparian habitat with a fluctuating water level will provide functional riparian habitat (e.g., shade, protective cover) relative to baseline riverine riparian habitat BC Hydro should account for this difference of productivity in its fisheries productivity offsetting plan Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 5
December 18, 2013 Jesse McCormick Memorandum Conclusion: Despite the large array of documentation presented by BC Hydro, there remains a substantial amount of uncertainty in the assessment due to legitimate unknown information, unrealistic model assumptions, and the lack of transparency provided. As indicated by the EIS, future research and adaptive management and monitoring programs will strive to provide new information to best inform management practices of local fisheries. However, increased transparency and development of model assumptions will allow a much more effective assessment of future biological conditions in the reservoir and Moberly River. In particular, future bull trout and Arctic grayling productivity largely hinges on the accuracy of model assumptions and parameter sensitivity. Bull trout projections as presented by BC Hydro currently meet population-level conservation objectives, however, there is a range of unrealistic and unsupported detail included in the model which led to the optimistic conclusion. The sustainability of Moberly River Arctic grayling seems unpredictable and arguably unlikely even if a rigorous trap and haul mitigation program is implemented. Considering this, future research programs and proposed productivity offsetting should focus on the viability of maintaining this fishery, and/or compensating for productivity elsewhere. Review Of Site C EIS Fish And Fish Habitat - Technical Memorandum - 6
Site C Project: Fish and Fish Habitat Presenters: Jesse McCormick, Donovan & Company Rick Palmer, Palmer Environmental Consulting Group (PECG) Alyssa Murdoch, PECG On Behalf of: Saulteau First Nations Joint Review Panel Hearing, Fort St. John, BC, January 13, 2014 1
Palmer Environmental Consulting Group Rick Palmer, M.Sc., R.P.Bio., Senior Fisheries Biologist Alyssa Murdoch, M.Sc., R.P.Bio., Aquatic Biologist 2
Introduction Review of Site C Environmental Impact Statement Section 12 Fish and Fish Habitat Deficient mitigation of project effects Mitigation and compensation enhancement SFN primary fish species of concern Rainbow trout, bull trout, Dolly Varden, Arctic grayling, jackfish/pike, whitefish, burbot, other trout Priority areas of SFN land users 3
4 Project Area
Key Recommendation Sections 1. Fisheries Productivity Offsetting (i.e. compensation) 2. Fish Population Modelling 3. Fish Stranding 4. Riparian (Stream-side) Vegetation 5
1. Fisheries Productivity Offsetting/Compensation Issue: Likely reduction of fisheries productivity and/or entire loss of key fisheries, such as the Moberly River Arctic grayling, Halfway River bull trout and Peace River mountain whitefish Key Points: A fisheries productivity offsetting plan is required by law (Fisheries Act) BC Hydro did not effectively respond to the request for a Fish Habitat Compensation Plan in Info. Request #11 The plan needs to be developed to address the potential and likely loss of fisheries productivity 6
1. Fisheries Productivity Offsetting/Compensation Suggested Recommendations: Target species: locally harvested species of concern e.g., Arctic grayling Locations: Moberly Lake, Moberly River, Peace River Compensation options: improving or creating fish habitat, e.g., spawning or overwintering habitat for Arctic grayling Research initiatives: SFN involvement in prioritizing research questions, and training as field technicians 7
2. Fish Population Modelling Issue: Fish population models were conducted for identified species of concern to determine if population-level conservation objectives will be met following dam construction Key Points: Vol. 2, App. Q3: Models were completed for Arctic grayling, bull trout and kokanee Several unrealistic or unsupported assumptions, e.g. fixed recruitment (1000 eggs/arctic grayling spawner) Modelled results were not adequately tested for potential changes to input parameter values (e.g., recruitment, initial population size) The Beverton-Holt stock-recruitment model used is less conservative and not appropriate for the types of species being modelled A secondary risk-based model would provide additional support to predictions and would be more conservative for maintaining harvestable levels of fish 8
2. Fish Population Modelling Suggested Recommendations: Include more realistic biological relationships Perform sensitivity testing Report level of uncertainty Provide clear, scientific justification and validation of model parameter assumptions Use more appropriate Ricker stock-recruitment function Use secondary risk-based model to compare and confirm abundance-based model results 9
3. Fish Stranding Issue: Due to reservoir creation, and regular water level fluctuations during operations, fish stranding is an ongoing concern Key Points: BC Hydro claims that fish stranding effects will be fully mitigated, but do not provide details of their mitigation strategy Depending on stranding conditions, fish may have minutes to days before stranding conditions result in death 10
3. Fish Stranding Suggested Recommendations: Provide further detail of the fish salvaging program to support claims that the effects of stranding will be fully mitigated, including: Frequency of surveillance: when and how often? Triggers for surveillance Design of the re-capture program Fishing gear types used various methods should be employed to reduce gear size-selectivity Emergency draindown protocol Include estimated fish mortality from stranding in population estimate modelling 11
4. Riparian (Stream-side) Vegetation Issue: Riparian vegetation provides nutrient and food inputs, structural habitat inputs (e.g., woody debris), fish protective cover, and regulates temperature changes. The conversion of the Peace River into a reservoir will promote the loss of a large area of riverine riparian vegetation. Regular water level fluctuations will reduce the function of new reservoir riparian vegetation Key Points: There is no attempt to assess riverine riparian habitat loss or the functionality of a fluctuating water line New riparian habitat will be limited in comparison due to the high surface area : shoreline length ratio in the reservoir A fluctuating shoreline will reduce riparian habitat functionality including shade and protective cover for fish 12
4. Riparian (Stream-side) Vegetation Suggested Recommendations: BC Hydro should provide an estimate of the quality and quantity of predicted riparian habitat loss They should also provide an analytical discussion of how new riparian habitat with a fluctuating water level will provide functional riparian habitat (e.g., shade, protective cover) relative to baseline riverine riparian habitat BC Hydro should account for this difference of productivity in its fisheries productivity offsetting plan 13
Conclusions Need better and more transparent model predictions where possible Need to develop compensation strategies to offset reduction and loss of key fisheries e.g., Moberly River Arctic grayling 14
Recommendations Summary 1. Fisheries Productivity Offsetting/Compensation 1. BC Hydro should develop an offsetting plan to address the potential effects on Arctic grayling, bull trout, and mountain whitefish productivity. 2. SFN priorities including fish species of concern in local habitats should be considered during offsetting plan development. For example, compensation could focus on enhancing habitat for locally harvested species that will be reduced or extirpated due to project effects such as Arctic grayling. In addition, potential offsetting locations could include the enhancement of SFN fisheries in Moberly Lake, Moberly River, or the Peace River (e.g., habitat enhancement or creation). 3. The offsetting plan should also consider research programs with the aim of identifying any critical informational gaps which will aid in directing and prioritizing future compensation efforts. The SFN should be engaged in guiding research priorities, and trained as technicians for assisting in the field research 15
Recommendations Summary 2. Fish Population Modelling 4. Fish population models should be adapted to incorporate stochastic biological relationships, for example varying the number of recruits systematically depending on spawner density. The models should undergo rigorous sensitivity testing to evaluate parameter assumptions, including the computation of elasticity measures. In addition, the prediction uncertainty bounds need to be presented in a clear manner for assessment. 5. Provide clear, scientific justification and validation of model parameter assumptions in order to assess their effectiveness at predicting population changes. 6. Use a Ricker stock-recruitment model in addition to the Beverton-Holt model employed. 7. Use a secondary risk-based model developed previously for bull trout for comparison with the abundance-based model (e.g., Staples, D. F., Taper, M. L. and Shepard, B. B. 2005. Risk-based viable population monitoring. Conservation Biology. 19:1908-1916). 16
Recommendations Summary 3. Fish Stranding and 4. Riparian Vegetation 8. Provide further detail of the fish salvaging program to support claims that the effects of stranding will be fully mitigated, including: Frequency of surveillance: when and how often? Triggers for surveillance Design of the re-capture program Fishing gear types used various methods should be employed to reduce gear sizeselectivity Emergency draindown protocol 9. Include estimated fish mortality from stranding in population estimate modelling. 10. BC Hydro should provide an estimate of the quality and quantity of riparian habitat lost 11. They should also provide an analytical discussion of how lacustrine riparian habitat with a fluctuating water level will provide functional riparian habitat (e.g., shade, protective cover) relative to baseline riverine riparian habitat 12. BC Hydro should account for this difference of productivity in its fisheries productivity offsetting plan 17
Thank you, any questions? Presenters: Jesse McCormick, Donovan & Company Rick Palmer, Palmer Environmental Consulting Group (PECG) Alyssa Murdoch, PECG On Behalf of: Saulteau First Nations Joint Review Panel Hearing, Fort St. John, BC, January 13, 2014 18