Fish and Fish Habitat – Compensation Plan
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Request Number 11: Fish and Fish Habitat – Compensation Plan References: EIS Guidelines Section 16.8.4; EIS Guidelines Section 10; EIS, Vol. 2, Section 12.5.3.2 JRP Context: The EIS states that “a Site C Habitat Compensation Plan will be developed in accordance with the Fisheries Act Section 35(2) Authorization.” It is understood by the Panel that a Habitat Compensation Plan has yet to be developed and will be a requirement of the Fisheries and Oceans Canada (DFO) Fisheries Act Authorization. JRP Question: It is recognized that there is a future permitting process, however, more detail on the plan is requested to help the Panel understand how the Proponent’s plans will effectively compensate for the adverse effects of the Project. Provide a conceptual fish habitat compensation plan. The plan should discuss elements including: Who would be involved in the planning and implementation of the plan, and how What would be the objectives of the plan What would be the measures of success What would be the timeline for providing the final plan How will the proposed plan address identified effects of the project What changes are expected to fish habitat after implementation of the plan How will the plan account for navigational concerns BC Hydro Response: A comprehensive Fish and Fish Habitat Compensation Plan for the Project is currently being developed. Conceptual elements of the plan are described below. The plan will include compensation during construction, as well as a framework to implement compensation during operation of the Project. Compensation concepts, such as enhancement of side-channel complexes, during construction are described in EIS Volume 2 Section 12.5. During operations, a strategic and adaptive approach to compensation that is coordinated with directed monitoring is proposed. BC Hydro has sought advice from fisheries agencies (DFO, BC MoE, BC MFLNRO, Alberta AESRD) to inform this approach. This approach is also consistent with BC Hydro’s broader practices, experience and success in implementing compensation. An adaptive approach is recommended to ensure that the priorities are properly identified and addressed over the long term. For example, the aquatic ecosystem in the reservoir will transition following construction and during operation of the Project. Monitoring results can inform the appropriate compensation actions to implement over time as the aquatic ecosystem transitions and species-specific information is collected. This adaptive approach supports compensation decisions made on the basis of empirical information. An adaptive approach should result in compensation actions that are more effective than alternative approaches, such as a non-adaptive approach of designing and implementing a fixed set of compensation actions prior to operation of the Project and without the benefit of monitoring results on the response of the aquatic ecosystem. The Fish Passage Management Plan for the Project (Volume 2 Appendix Q) provides an analogous example of this adaptive approach to mitigating potential effects of the Project on Fish and Fish Habitat. As outlined below, the compensation plan will build upon environmental management processes and principles employed at existing facilities operated by BC Hydro. These approaches have proven effective in managing fish and fish habitat, supporting regulatory compliance, and promoting stakeholder and First Nation input in decision making. The plan is guided by environmental management processes that have evolved from the 1998 provincial Water Use Plan (WUP) process. The WUP process was designed by 30 the federal and provincial governments in collaboration with BC Hydro to reflect the increased awareness of environmental and social objectives at the existing BC Hydro dams throughout the province, and the need to balance various and sometimes competing interests in water resource management. The following “Principles” were adopted to guide the WUP process for the BC Hydro Water Use Plans: Recognition of multiple objectives; Legal and regulatory constraints – and a process designed to clarify rights; Framework for discussions – structured to explore a range of management alternatives; Trade-offs within constraints – recognizing that facilities exist and will remain and incremental improvements would be sought to balance multiple objectives; Inclusiveness in the consultative process; Evidence-based decision making; Adaptation based on empirical evidence from on-going monitoring This same principled approach was adopted and expanded for a number of other agreements between BC Hydro and the federal and provincial governments, specifically, the Fish and Wildlife Compensation Program, the Fish Passage Decision Strategy, and the Fish Entrainment Strategy. BC Hydro believes the decisions concerning the development of new facilities such as the Project should adopt similar principles – this ensures structured decisions are made on the basis of best available information (applied science as well as policy) with a commitment to improve information quality over time. For fish compensation measures, up to date information can be used in the design of the compensation measures. This has proven to be not only a cost effective approach, but also ensures the compensation is appropriate and effective. An example of this type of comprehensive, strategic, long-term approach to habitat compensation is described in the attached Coastal Fish and Wildlife Compensation Program – Campbell River Watershed Plan. The Watershed Plan outlines the partners, the priorities, objectives and measures, the effects of the hydroelectric facilities, and monitoring plans. Compensation in the Campbell watershed includes several successful habitat improvement projects such as Quinsam River Fish Passage, Campbell River Gravel Enhancement, and Salmon River Side Channel work, which have resulted in increased fish production and supported objectives for conservation. Specific elements requested: Who would be involved in the planning and implementation of the plan, and how: Development of the compensation plan will take into account input received to date during consultation with regulatory agencies, including DFO, BC MoE, Alberta Ministry of Environment and Sustainable Resource Development (AESRD), First Nations and other parties. Currently, development of the plan is ongoing by the Project team and consultants. The team includes biologists and engineers who have experience with compensation planning, implementation and monitoring at hydroelectric facilities, and who were involved in the effects assessment for Fish and Fish Habitat. BC Hydro will work with appropriate regulatory agencies and First Nations to further develop the plan. What would be the objectives of the plan: The overall intent of the plan will be to compensate for the residual effects of the Project on fish and fish habitat. Objectives include the conservation and protection 31 of the productivity of fish and fish habitat1 and alignment with the local provincial management objectives for fish and fish habitat.2 What would be the measures of success: The plan will include performance measures that align with the Province’s local management objectives for fish and fish habitat. The productivity of fish and fish habitat would be measured using appropriate biological parameters. Similar biological measures are described in the Fish Passage Management Plan (Volume 2 Appendix Q). Monitoring will track additional physical and biological measures to aid in interpreting changes to these performance measures. What would be the timeline for providing the final plan: The final plan will be developed in conjunction with the process for the Authorization under the federal Fisheries Act. How will the proposed plan address identified effects of the Project: Compensation actions will be guided by observed effects of the Project on fish and fish habitat. What changes are expected to fish habitat after implementation of the plan: Incremental increases to productivity and capacity of fish habitats are expected from implementation of the plan. Monitoring will characterize the resulting changes. How will the plan account for navigational concerns: Navigational concerns for specific works would be addressed, as required, through the design and regulatory approval process commonly associated with habitat compensation works. 1 Further description of these priorities is provided in EIS Volume 2 Section 12.6.2 Standards or Thresholds for Determining Significance 2 British Columbia Government. 2011. Draft Fish, Wildlife and Ecosystem resources and Objectives for the Lower Peace River Watershed – Site C Project Area. 32 WATERSHED PLAN FINAL DRAFT Table of Contents 1 Introduction ........................................................................................................................................... 2 Vision.................................................................................................................................................... 3 Principles .............................................................................................................................................. 3 Partners ................................................................................................................................................ 3 Policy Context ....................................................................................................................................... 3 Program Delivery .................................................................................................................................