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~ROCKY VIEW COUNTY Office of the Reeve ~ C Ultivating Communities 911 ·32 Ave Nef Calgary, AB Jt2e 6X6 403-520-1290 I

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~ROCKY VIEW COUNTY Office of the Reeve ~ C Ultivating Communities 911 ·32 Ave Nef Calgary, AB Jt2e 6X6 403-520-1290 I ~ROCKY VIEW COUNTY Office of the Reeve ~ C ultivating Communities 911 ·32 Ave NEf Calgary, AB jT2E 6X6 403-520-1290 I www.rockyview.ca July 25, 2016 Springbank Off-stream Reservoir Project Canadian Environmental Assessment Agency Attention: CEAA Agency Canada Place 9700 Jasper Avenue, Suite 1145 Edmonton, AB, T5J 4C3 Dear Sir/Madam Re: Spring bank Offstream Reservoir Project - Draft Guidelines On behalf of Rocky View County, I respectfully submit comments on the Draft Guidelines for the Preparation of an Environmental Impact Statement ("EIS") for the Spring Bank Off-Stream Reservoir Project (the Project); included for your acceptance. The Project is located within the County's jurisdiction and geographic area. The County has concerns the Project may cause significant adverse effects to residents and the surrounding environment. Attachment A details our concerns and includes both the environmental and socio-economic impacts and Attachment B provides suggested changes to the draft guidelines for the preparation of an Environmental Impact Statement. Given the scope of the project, the County urges the federal Minister to refer this environmental assessment to a review panel. As detailed in Attachment A, the County submits that the necessary criteria under section 38(2) of CEAA, 2012 are met. Furthermore, the federal Minister and the Alberta government should require a review of this Project by a joint panel of the CEAA and the Natural Resources Conservation Board. This will ensure that the project is subject to the most comprehensive and balanced review possible. Thank you for the opportunity to provide our submissions in this matter. If you should have any further questions with respect to this submission, please contact Byron Riemann, General Manager of Infrastructure and Operations at 403-520-1196 or by email at [email protected] . Sincerely, ROCKY VIEW COUNTY <Original<Original signedsigned by> by> Greg Boehlke Reeve Attachments: Attachment A - County Concerns Attachment B - Suggested Changes to Draft Guidelines cc: Honourable Brian Mason, Minister, Alberta Transportation Honourable Shannon Phillips, Minister, Alberta Environment and Parks Roy Whitney One-spot, Chief, Tsuut'ina Nation Liz Erasmus, Mayor, Townsite of Redwood Meadows Naheed Nenshi, Mayor, City of Calgary John Barlow, MP, Foothills Blake Richards, MP, Banff-Airdrie Martin Shields, MP, Bow River Leela Aheer, MLA, Chestermere-Rocky View Nathan M. Cooper, MLA, Olds-Didsbury-Three Hills Cameron Westhead, MLA, Banff-Cochrane Angela Pitt, MLA, Airdrie Rocky View County Council Kevin E. J. Greig, County Manager, Rocky View County Byron Riemann, General Manager, Infrastructure and Operations, Rocky View County ATTACHMENT A COUNTY CONCERNS In response to the notice from the Canadian Environmental Assessment Agency ("CEAA or Agency"), requesting comments on the Draft Guidelines for the Preparation of an Environmental Impact Statement ("EIS") for the Spring Bank Off-Stream Reservoir Project ("Draft Guidelines") under the Canadian Environmental Assessment Act, 2012 ("CEAA, 2012") , Rocky View County ("the County") provides the following submission. As noted in the submission of the County to the CEAA Agency dated May 30, 2016, the Project is located within the County's jurisdiction and geographic area. The County has concerns about environmental effects to residents and the surrounding environment resulting from the Project. Transportation The County submits that Part 2, sections 3 and 6 of the Draft Guidelines should include a requirement for the EIS to contain a local and regional study area of sufficient size to include socio-economic impacts to the regional transportation system arising from the Project. The County submits the Project will result in significantly increased long-term costs arising from the flooding of Springbank Road, which represents a major transportation route. The EIS should include these increased future costs from the Project in the effects assessment and any assessment of alternatives. The County notes that effects on transportation infrastructure were considered in the Joint Review Panel's Report in Site C Clean Energy Project, May, 2014 and a Project Traffic Analysis was included in the EIS, which considered many factors, including impacts on safety, increased collisions and delay. Pipelines The Draft Guidelines in Part 2 section 3 require the inclusion of affected pipelines in the project description. The County submits, however, that the integrity of interprovincial or international pipelines requires increased attention in both the project description and the effects assessment, including the potential effects on spill response plans at the pipeline and local municipal level. The spill extent modelling for the oil products contained in these pipelines following a spill may also require further consideration, given the Project's impact on the area. The County notes that certain pipelines potentially affected by the Project are within federal jurisdiction, including any impacts they may have on the environment that may be aggravated by the Project. The County notes that for these pipelines to be moved or relocated, or to construct or excavate over them, an authorization from the National Energy Board will be required under the National Energy Board Act which satisfies the requirement of, "projects requiring a federal authority to exercise a power or function under another Act of Parliament" (CEAA, 2012 s.5(2)). The Draft Guidelines should include reference to and assessment of these considerations, including a consideration of associated costs and cumulative effects. Dust and Waste Rock The Draft Guidelines should also require the EIS to specifically describe and assess fugitive dust emissions arising from construction of the Project. A description of the waste rock and sediment expected to be generated from the Project, and its short and long-term storage, should be described, potentially assessed, and monitored on a long-term basis. 1 Equally if not more important the Draft Terms of Reference should address the operational phase of the Project; in particular, those emissions emanating from the dry reservoir and mud flats, post flood event. This consideration should include an analysis of the types of waste and debris likely to be deposited into the reservoir and aesthetic related impacts on residents. The County notes that aesthetic impacts were considered as vital in the Joint Review Panel's Report in Whites Point Quarry and Mine Terminal Project, JRP, October 2007. Studies show that overtime the amount sediment deposition will be significant (see Sedimentation in G/enmore Reservoir, Calgary, Alberta; Hollingshead, Yaremko, and Neill, Canadian Geotechnical Journal, 10, 109, 1973). An analysis of dust emissions and aesthetic factors from the Project should consider proximate receptors, including nearby residents, communities, First Nations, and schools. A description of the waste rock and sediment expected to be generated from the Project, and its short and long-term storage, should be described, potentially assessed, and monitored on a long-term basis. These considerations should be added to the Draft Terms of Reference. Alternative Projects Under Part 2, section 2 of the Draft Guidelines, the EIS must identify and consider the effects of alternatives and alternative means of carrying out the Project that are technically and economically feasible. In this respect, the Draft Guidelines should specifically reference and consider the Mclean Creek diversion project. The Mclean Creek diversion project was an alternative project and location considered by Alberta Environment at a high level, but not ultimately selected. Although Alberta Environment studied this alternative in the Environmental Overview Report (AMEC 2015), AMEC concluded that further study and data collection was required to fully assess social and environmental impacts. The County submits this also remains the case for the Spring Bank Project, and that the Environmental Overview Report does not provide sufficient justification to eliminate the Mclean Creek project at th is time. Later studies commissioned by Alberta Environment, such as Deltares (2015), were descriptive in nature and did not include in depth analysis of the Mclean Creek alternative. The Mclean Creek alterative includes a wet pond, which provides additional benefits, including water supply to the County/cities, recreational use, wildlife habitat, aquatic habitat, and improved quality of the water ultimately released. This alternative, compared to a dry reservoir, would also mitigate impacts associated with the deposition of waste and debris, and the associated dust, aesthetic (mud flats), and health impacts. Flood storage as part of a multi­ purpose facility is common (Gienmore Reservoir) and the safe and regular operation of such facilities has been established. The County submits that when impacts on future transportation, proper management of the dry reservoir, pipelines, and land acquisition are considered, the Mclean Creek project remains a technically and economically feasible alternative. The County submits that the EIS should identify and assess the environmental effects of the Mclean Creek alternative at a detailed level. Monitoring and Remediation Lastly, monitoring programs under section 8 of the Draft Guidelines should include monitoring of the dry reservoir, dust emissions, and appropriate operation and remediation procedures after flood events. This should also include an assessment of the
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