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Bech Submission to EAO Re Narrows Inlet

Bech Submission to EAO Re Narrows Inlet

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12/04/2012

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Page 1 o 9
Submission to the B.C. Environmental Assessment Oceregarding the proposed Narrows Inlet private power project
 Submitted by:Joan and Soren BechRoberts Creek, B.C.
Public consultation process
O
n Oct. 12, we attended the Open House in Egmont, expecting to be able to provide comments
on the NI Holding Corp. proposal to construct a total o six power plants (two on Ramona
Creek) in Narrows Inlet.Te notice issued by the Environmental Assessment Oce clearly indicated that we would havethis opportunity: “In order to provide inormation about the Application, and
to receive comments
 from the public
, the Environmental Assessment Oce (EAO) invites the public to attend Open
Houses….” (emphasis added)
We were very disappointed that no such opportunity was provided. Indeed, we were inormed by 
the Environmental Assessment Oce that it was sponsoring the open house strictly or the beneto NI Holding Corp. Despite the promise contained in the invitation, the EAO advised us that theonly opportunity or the public to comment was by e-mail or letter.
Tat a public agency, established to protect the public interest, should actively sponsor opportuni-
 
Page 2 o 9
ties or a private corporation to make its case while simultaneously severely limiting public comment
is deeply disappointing.
Our disappointment in the EAO is exceeded only by our disappointment in the dismissive attitude
that NI Holding Corp. displays towards the many people who enjoy the wilderness experience o 
Narrows Inlet, and especially towards those who own property in the Inlet.
Long term degradation o Narrows Inlet
he various reports commissioned by NI Holding Corp, and the inormation it provided at the
open houses, underline the serious impact o this project. It is not run-o-river. It converts
three alpine lakes to reservoirs. wo dams will be constructed. A total o 4.75 km o penstock willdivert water rom Ramona Creek. (Executive Summary, page B-4) New transmission lines will beconstructed, bringing the total to 41 km above ground, plus 2 km submerged cable. (Introductionand Project Description – Part 2, page 2-1)Te dam at the outlet o Ramona Lake will raise the maximum
level o the lake by 3 m, inundating 5.8 ha o shoreline. At other
times, the lake will be drawn down by 45 m rom its natural level.(A10 SREIP Overview errain Stability Assessment)
Every phase o the project – construction, operation, and de-
commissioning – will degrade water quality and change habitat.
(Ramona Creek component eects assessment – Part J, able 14-86, page 267)
A summary o terrestrial wildlie and vegetation projects eects
or the upper and lower Ramona Creek projects lists 52 adverse
eects, many o them long term. It describes these adverse eects
as reversible i the dams, penstocks, tailraces and power plantsare decommissioned, and concludes that they are thereore not
signicant. (Part Q – environmental eects assessment, able 23-20, Pages 23-30 to 23-34)
A comment regarding the loss o mature orest habitat or tree-roosting bats is typical: “Tis eect
is reversible, as the habitat can return to the baseline condition once the Project is deactivated andthe orest is allowed to re-grow.” (Part K – Interconnection eects assessment, page 15-117)I this project is ever decommissioned, it will be a very long time in the uture.
“Ongoing maintenance re-ts and upgrades can extend the normal operating lie o a hydroelec-
tric project indenitely into the uture. Similar projects are typically long-lived with an expected
(projected) design lie o 75 to 100 years.” (Introduction and project description – part 2, Page 2-108)
In other words, i we allow time or the orests to mature, this “not signicant” damage can be
reversed in 155 to 180 years.For recreational users and boaters, the eect on the visual quality o Ramona Falls and Narrows
Inlet would “exceed acceptable levels despite mitigation” in both construction and operation phases.
(Part N – Socio-Economic Eects Assessment, able 19-91, Page 19-186)
 
Page 3 o 9
Again this is dismissed as something that can be repaired in 100 years or so. A Robertson Environ-mental Services report says, “Te residual eect o reduced aesthetic quality o the landscape duringthe construction phase is negative and occurs on a disturbed landscape (Ramona). Te residual eect
is localized to the Ramona Creek area, and is long term and continuous as permanent structures
would exist on the landscape throughout the operations phase. Te eect can be considered revers-
ible i all inrastructure is dismantled and removed during Project end
o 
lie decommissioning,
and the landscape reclaimed to its baseline condition.”Te construction environmental management plans explaining how NI Holding Corp will limit
environmental damage are all dras. Dra plan 2A says the environmental resources at risk, and
the location o sensitive areas and eatures, are identied in Appendix A. Tere is no Appendix Aon the EAO website.
Impact on property owners
here has been very little consultation with property owners who are directly aected by the
Ramona Creek / Ramona Lake component o this project. Te reports prepared by NI Holding
Corp. detail considerable potential damage – undrinkable water, noise, declining property values
and more – but the company and its principals dismiss these concerns out o hand. One report goes
so ar as to say the property owners are not signicant because there are so ew o them.
Quoted in the Coast Reporter, Oct. 19, 2012, Peter Schober o Renewable Power Corp., one o the
principals in NI Holding Corp., said:“Where we are is well above their property. Tey will not even know it’s there.”His statement is plainly not correct, and contradicted by the reports submitted to the EAO.
“Te construction o the Ramona Creek acility will also include the construction and operation
o a powerhouse that will be situated adjacent to the east boundary o the properties.” (Part N –
Socio-Economic Eects Assessment, Page 19-149)“()he Lower Ramona Creek component will have a substantial negative eect on the quality o experience or recreational property users at Ramona Creek, a sub-set o the recreational property 
user group. Project activities are likely to have an eect on this group that would lead to adverse
relocation or behavioral change. Tat is, a substantial portion o the sub-user group is likely to sell
their recreational property or visit their recreational property less ofen, as a result o Project activi-
ties. Tis eect however is considered ‘not signicant’ as it aects only a sub-set o the recreationalproperty user group.” (Part N – Socio-Economic Eects Assessment – Part 1, page 19-133)I the project is approved, blasting and drilling will occur year round. “As construction will oc-
cur all year long, except or rozen periods, notication will be given to Ramona Creek property 
owners as to the duration, timing and nature o construction activities that may cause them directdisturbance, such as blasting and drilling.” (Part N – Socio-Economic Eects Assessment – Part 1,page 19-130)
In Appendix 71, the consequence o ailure o the proposed Ramona Lake dam is classied as
“high”. Residents and visitors in our privately owned cabins would be at risk o inundation by 2.1million m
3
o water.
Appendix 18 – Noise Baseline Assessment, notes that noise levels at the yson Creek powerhouse

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