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Red Willow Wind Project Project Description

August 2015

Prepared for: Boralex Inc. 606-115 Robson Street Vancouver, BC V6E 1B5

Prepared by: Hemmera Envirochem Inc. 18th Floor, 4730 Kingsway Burnaby, BC V5H 0C6

File: 1591-004.01 August 2015 Table of Contents 1 INTRODUCTION ...... 1 2 PROPONENT INFORMATION ...... 2

2.1 BORALEX INC...... 2 2.2 AEOLIS WIND POWER CORPORATION ...... 2 3 PROJECT OVERVIEW ...... 4

3.1 PROJECT PURPOSE AND RATIONALE ...... 4 3.2 PROJECT LOCATION ...... 4 3.3 PROJECT SCOPE ...... 6 3.4 PROJECT COMPONENTS ...... 6 3.4.1 Wind Turbines ...... 6 3.4.2 Access Roads ...... 7 3.4.3 Substation and Transmission and Collector Lines ...... 8 3.4.4 Offsite Control Station ...... 8 3.4.5 Other Project Components ...... 8

3.5 PROJECT ACTIVITIES ...... 8 3.5.1 Construction and Commissioning Activities ...... 8 3.5.2 Operation and Maintenance ...... 9 3.5.3 Decommissioning ...... 9 4 ENVIRONMENTAL SETTING AND POTENTIAL EFFECTS ...... 10

4.1 TERRESTRIAL ENVIRONMENT ...... 10 4.2 AQUATIC ENVIRONMENT ...... 12 4.3 COMMUNITIES ...... 12 4.4 LAND AND RESOURCE USE ...... 13 4.5 TRANSPORTATION ...... 14 4.6 HERITAGE RESOURCES ...... 14 4.7 POTENTIAL EFFECTS ...... 14 4.8 FIRST NATIONS INTERESTS ...... 16 5 CONSULTATION ...... 17

5.1 FIRST NATIONS ENGAGEMENT ...... 17 5.2 GOVERNMENT, STAKEHOLDERS, AND PUBLIC CONSULTATION ...... 18 6 ANTICIPATED PERMITS AND APPROVALS ...... 19 7 PRELIMINARY PROJECT SCHEDULE ...... 21 8 REFERENCES ...... 22

List of Tables

Table 1 Ecosystems in the Project Area ...... 10

Table 2 Named waterbodies in the vicinity of the proposed Project area ...... 12

Table 3 Potential Adverse Effects to Valued Resources ...... 15

Table 4 Summary of Engagement to Date with First Nations (as of January 2015) ...... 17

Table 5 Summary of Anticipated Authorizations/Approvals/Permits ...... 19

Table 6 Preliminary Project Schedule...... 21

List of Figures (within text)

Figure 1 Example schematic of a wind turbine generator (Natural Resources 2012)...... 7

List of Photos

Photo 1 Looking north from the proposed turbine locations to Rat Lake and the Highway 52 area ...... 5

Photo 2 Looking toward Yoho Ridgeline. Note forestry activity and existing roads in the Project area...... 5

1 Introduction

The Red Willow Wind Limited Partnership (Red Willow Wind LP, or the Proponent) is a limited partnership under formation that will act and be represented by its general partner, Red Willow Wind Power Corporation. The shareholders of the Red Willow Wind Power Corporation are Boralex Inc. (Boralex) and Aeolis Wind Power Corporation (Aeolis).

The Red Willow Wind LP is proposing to develop the Red Willow Wind Project (the Project), an approximately 200 megawatt (MW) wind energy facility in the region of (BC). The Project is located southeast of the District of Tumbler Ridge (Appendix A, Figure 1) and within the territory of the Treaty 8 First Nations.

Since the proposed Project will have a capacity greater than 50 MW, it is considered reviewable under Section 10 of the Reviewable Projects Regulation of the British Columbia Environmental Assessment Act (BCEAA), SBC 2002, c.43, which states that any new energy facility that has a nameplate capacity greater than or equal to 50 MW is subject to review by the BC Environmental Assessment Office (EAO). The Project does not meet requirements for federal review as listed in the CEAA 2012 Regulations Designating Physical Activities (SOR/2012-147) under the Canadian Environmental Assessment Act, 2012 (CEAA 2012), SC 2012, c. 19, s. 52.

This project description is submitted to the EAO to provide general information on the proposed Project and assist the EAO in making a determination regarding the need for an Environmental Assessment (EA) of the Project pursuant to Section 10 of the BCEAA. This document follows the EAO guidelines for preparing a project description (EAO 2013).

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2 Proponent Information

2.1 BORALEX INC.

Boralex is proud to be one of the few public corporations in Canada primarily devoted to developing, building, and operating renewable energy power stations. Building on extensive experience in traditional energy production, including hydroelectric and thermal power, Boralex is a pioneer and a recognized leader in the growing wind power market.

With over 200 employees, Boralex operates high-quality energy assets with a total installed capacity of over 650 MW in Canada, France, and the Northeastern United States. Boralex is also committed, both independently and with European and Canadian partners, to power development projects totalling about 250 MW of additional energy to be commissioned through the end of 2015. Boralex’s head office is located in Kingsey Falls, Quebec, with offices in Vancouver, Toronto, Montréal, New York State, and France.

Recent milestones for Boralex in Canada include the approval of two Development Plan Applications for the and Babcock Ridge Wind Projects (both near Tumbler Ridge, BC), the commissioning of the 272 MW Seigneurie de Beaupre Wind Farm (Québec), and the commissioning of the 22 MW Jamie Creek Hydroelectric Project (Lillooet, BC). Boralex also has three wind farms under construction in Québec and two under construction in France.

Boralex’s stock (in which Cascades Inc. holds a 35% interest) and its convertible debentures are traded on the Toronto Stock Exchange under the ticker symbols BLX and BLX.DB, respectively. More information on Boralex is available at http://www.boralex.com.

2.2 AEOLIS WIND POWER CORPORATION

Aeolis is a private, Canadian, wind energy development company based in Sidney, BC and incorporated in 2003. Aeolis focuses on establishing industrial wind power generation facilities in Western Canada. In moving a project forward, Aeolis brings together three key aspects:

 Unmatched in-house technical and project expertise. Through its team, Aeolis possesses the skills, abilities and tools to prospect and develop wind projects. This includes in-depth technical analysis, permitting and community engagement.  A number of exceptional, high energy wind sites at various stages of development and across multiple jurisdictions.  An excellent growing team of partners to help develop its investigative wind locations.

Aeolis has significant experience in preparing and permitting wind projects in BC, including managing tenures, EA pre-application processes, public and First Nations consultation, technical wind analysis, and project partnerships. Aeolis was the primary developer for Bear Mountain Wind Park. The 102 MW Bear Mountain Wind Park successfully won an Energy Purchase Agreement (EPA) with BC Hydro in 2006, received its BC Environmental Assessment Certificate (EAC) in 2007 and it was the first industrial wind project to be built in British Columbia. Aeolis has also prepared provincial EA applications for two other large industrial projects: Thunder Mountain Wind Project and Hackney Hills Wind Project. Thunder Mountain Wind Project received its BC EAC in 2009, while Hackney Hills remains in the process. Aeolis is also developing a number of sites for the BC Hydro Standard Offer Programme for projects of less than 15 MW.

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Key Personnel and Contact Information

Name: Carlie Smith, Project Manager, Development BC, Boralex Address: Suite 606, 1155 Robson Street, Vancouver BC, V6E 1B5 Office: 855-604-6403 Mobile: 604-787-0172 Email: [email protected]

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3 Project Overview

3.1 PROJECT PURPOSE AND RATIONALE

The purpose of the Project is to generate a clean, long-term energy source for the BC electrical grid to support expanding industrial and residential needs. Wind energy is clean and renewable, producing no greenhouse gases or other air emissions, or hazardous waste. The Red Willow Wind Project will help achieve provincial goals set out in the 2007 BC Clean Energy Plan by providing safe, reliable, and clean electricity. Apart from these broader social benefits, the Project will provide stable economic benefit through job creation and additional tax revenues in a region that experiences economic challenges resulting from fluctuations in the coal industry. The growth in the wind industry in this region will provide diversification from the existing forestry, mining, and oil and gas activities. The estimated capital cost of the Project is C$480 million. It is anticipated that the energy generated by the Project will be sold to BC Hydro under an EPA issued through a future Clean Power Call.

3.2 PROJECT LOCATION

The proposed Project site is located approximately 40 km southeast of Tumbler Ridge, and 30 km from the BC- border, within the Peace River Regional District (Appendix A, Figures 1, 2a and 2b). The site is located entirely on provincial Crown land at the following coordinates:

Latitude: 54.808663

Longitude: 120.375011

In addition to the wind resource potential, this site was selected based on several attributes, including proximity to the BC Hydro grid, the network of existing roads and transportation options, and existing industrial activity. These attributes will help to reduce the need for new infrastructure and the potential effects associated with the Project.

Turbines for the Project will be located on a series of northwest-southeast trending ridges south of Stoney Lake and Highway 52. The proposed 230 kilovolt (kV) overhead transmission line largely follows Highway 52 to the point of intersection at the Quintette Substation (Appendix A, Figure 2a, 2b). The following two photographs depict the landscape found in the region of the proposed Project.

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Photo 1 Looking north from the proposed turbine locations to Rat Lake and the Highway 52 area

Photo 2 Looking toward Yoho Ridgeline. Note forestry activity and existing roads in the Project area.

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3.3 PROJECT SCOPE

The scope of the Project includes the following major components:

 Up to 80 wind turbine generators (WTG), including foundations, crane pads, towers, transformers, rotor blades, and generators.  Project substation.  Overhead and underground electrical cables between towers and the substation.  High-voltage transmission line to connect the Project to the electricity transmission grid.  Communication tower, preferentially existing, and connecting fibre optic cables within the Project.  Upgrades to existing access roads, onsite connector roads and water crossings, and the development of new access roads, onsite connector roads, and water crossings to Project-related components.  Permanent meteorological towers.  Operations center and works yard.  Gravel and aggregate materials sourced within the boundaries of the proposed Project. If additional resources are required they will be sourced from existing suppliers within the region and, if necessary, a dedicated aggregate resource in accordance with provincial regulations will be developed.  Temporary portable concrete batch plant.  Temporary construction laydown areas, temporary buildings and associated facilities.

These components are discussed in detail in Section 3.4. The preliminary Project layout shown in Appendix A, Figures 2a and 2b will be refined during final engineering design, which will incorporate detailed geotechnical considerations and consideration of environmental commitments through the EAC.

3.4 PROJECT COMPONENTS

3.4.1 WIND TURBINES

The wind turbine capacity will range between 2 MW to 3 MW for each of up to 80 WTGs, depending on the WTG model selected. Model selection will be based on correlating the turbine characteristics to best match the predicted wind conditions from the wind resource modelling within the turbine corridors. Each WTG will be mounted on a concrete or rock foundation and equipped with a transformer. All foundation types involve the use of both concrete and reinforcing steel. The area needed for each turbine foundation is determined by the specific site topography and accessibility; however, when completed, each will have a partially buried footprint of approximately 0.5 ha. The turbines will be located on northwest - southeast trending ridgelines within the corridors illustrated on Appendix A, Figure 2a.

The WTGs have a tubular steel tower to which the nacelle, hub generator, and three bladed rotors are attached. Each WTG site will have an adjoining crane pad for installation and maintenance. Depending on the model selected, the tower will be up to 135 m from the base to hub, with a rotor-plus-blade diameter of up to 126 m. When a rotor blade is extended vertically above the tower, the structure will be up to 180 m above ground in height. An example of a WTG is illustrated in Figure 1.

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Figure 1 Example schematic of a wind turbine generator (Natural Resources Canada 2012).

3.4.2 ACCESS ROADS

The Project site is accessible via Highway 52 from two secondary roads. The northern portions are accessible via Rat Lake Resource Road (RR) off Highway 52, to Burlington RR and Shell Ridge RR. The Project facilities in the southwest are accessible off Highway 52 via Ojay Main (Appendix A, Figure 2a). The Project will use approximately 95 km of existing access road, and will require construction of approximately 27 km of new access road. The new access roads will facilitate access to the WTGs during Project construction and operation, and will connect the WTGs within the WTG corridors shown in Appendix A, Figure 2a.

Access roads will be upgraded as needed to accommodate safe and efficient delivery of materials, equipment, and turbine components during the construction phase. Pull-outs to enable two-way traffic with large transport vehicles will be constructed as required.

The Proponent anticipates that agreements with existing road permit holders will be required, and road upgrades will be determined in consultation with the permit holders and in accordance with applicable standards. Site-specific surveys and assessments for the roads will be conducted prior to construction or upgrading, and roads will be located and designed to minimize disturbance, avoid sensitive resources and unsuitable topography, maximize transport efficiency, and ensure safe operating conditions.

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3.4.3 SUBSTATION AND TRANSMISSION AND COLLECTOR LINES

A network of underground and/or overhead electrical collector lines will collect energy from individual turbines and connect to the proposed Project substation within the Project area, which is expected to have a footprint of approximately one to 2.5 ha. Approximately 66 km of collector lines are anticipated.

The preferred transmission route is an approximately 49 km long, 230 kV transmission line that will connect the proposed Project substation to the existing Quintette Substation and the BC Hydro grid via a route that largely follows Highway 52. The Proponent will consult with BC Hydro regarding potential upgrades to the existing substation at the point of interconnection. Details regarding the location of collector lines within the proposed corridors will be determined during final Project design. Efforts will be made to place collector lines along existing linear corridors and disturbed areas, such as roads and seismic corridors.

3.4.4 OFFSITE CONTROL STATION

The Project is not expected to require onsite operational maintenance buildings or overnight accommodations. A Project office will be maintained offsite, in Tumbler Ridge.

3.4.5 OTHER PROJECT COMPONENTS

Other infrastructure that may be required to support the construction and commissioning, and /or operation and maintenance phases of the Project include storage and laydown yard areas, a portable concrete batch plant, temporary trailers, and refueling areas. Gravel and aggregate materials will be sourced within the boundaries of the proposed Project, or if additional resources are required, from existing suppliers within the region. If necessary, dedicated aggregate resources will be developed in accordance with provincial regulations. A communication tower, preferentially existing, and connecting fibre optic cables within the Project will also be required. The areas chosen for temporary infrastructure will be situated to allow efficient movement of Project components while avoiding any environmentally sensitive areas and areas that are potentially unstable or difficult to rehabilitate post-construction. Preferred siting for laydown and storage areas will be in existing areas of disturbance within the proposed turbine and collector line corridors. Design and location of associated facilities will be determined in later planning phases of the Project.

3.5 PROJECT ACTIVITIES

Project activities associated with the construction and commissioning, operation and maintenance, and decommissioning phases of the Project are listed below.

3.5.1 CONSTRUCTION AND COMMISSIONING ACTIVITIES

Activities associated with the construction and commissioning phase of the Project will include the following:

 Vegetation clearing and site preparation  Access road upgrading and new access and spur road construction  Materials and equipment transportation  Waste disposal  Sourcing water for concrete production and dust suppression

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 Preparation, use, and clean-up of ancillary construction areas, such as lay-down areas and storage areas  Construction of concrete foundations and tower erection  Placement of electrical collector cables, and fibre-optic cables for communication with the offsite control station  Construction of an overhead transmission line from the substation to the interconnection point and the BC Hydro electrical grid  Construction environmental monitoring  Project commissioning, including acceptance and performance testing

The approximately 18-month construction and commissioning phase is proposed to be initiated in early 2017, subject to the approvals processes, onsite weather conditions, engineering requirements, and input from local communities and stakeholders.

The construction phase of the Project may provide up to 200 person years of employment, with a maximum of approximately 300 jobs at one time. A number of indirect and induced jobs will result from Project construction (e.g., truck drivers, gravel suppliers).

3.5.2 OPERATION AND MAINTENANCE

Upon Project commissioning, the Project will generate wind energy from the WTGs and transmit it via the transmission line to the BC Hydro power grid. Power production will be managed remotely from an offsite operations building located in Tumbler Ridge. An annual and on-going maintenance program will be delivered as part of the Project management program to ensure the efficient and safe operation of infrastructure. This will include on-site and remote maintenance as per recommended manufacturer processes for WTGs, as well as regular maintenance of transmission and road rights-of-way. A Project operational life of more than 40 years is anticipated. It is anticipated that the Project will create eight full- time jobs over the course of the operational phase, equivalent to 320 person years.

It is anticipated that the energy generated by the Project will be sold to BC Hydro under an EPA issued through a future Clean Power Call or through another renewable energy acquisition process, with an expected EPA term of 40 years. The Project will undergo progressive maintenance and refurbishment throughout the EPA term, as necessary. If, at the end of the EPA term, the Project continues to produce clean energy, and BC Hydro is interested in continuing to purchase energy from the Project, the Proponent will discuss options for continuance of the Project with BC Hydro.

3.5.3 DECOMMISSIONING

Decommissioning of the Project, if necessary, will reflect knowledge, technology, and regulations applicable at that time. If decommissioning is required, a qualified registered professional will be utilized to develop a plan that is consistent with the regulations and best management practices, in coordination with the appropriate provincial agency representatives. Since the Project is located on provincial Crown land, a preliminary decommissioning plan will be provided to support applications for tenure and requirements to return the land to a state acceptable to the Crown.

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4 Environmental Setting and Potential Effects

This section presents an overview of the terrestrial and aquatic environments, local communities, land and resource uses, transportation, and heritage resources within and in the vicinity of the Project area. A brief summary of the potential effects of the Project is also provided. The overview and summary of effects are based on desktop reviews and field work carried out in 2013 and 2014, and professional knowledge of the region.

4.1 TERRESTRIAL ENVIRONMENT

The Project area, as delineated in Appendix A, Figures 2a and 2b, is located almost entirely within the Sub-boreal Interior Ecoprovince, the Central Canadian Ecoregion, and the Hart Foothills Ecosection (BC CDC 2014).A very small portion of the Project area extends into the Boreal Plains Ecoprovince, the Southern Alberta Upland Ecoregion, and the Kiskatinaw Plateau Ecosection (Appendix A, Figure 2b). The Project infrastructure will be situated between 900 m and 1,480 m elevation above sea level. Project infrastructure has the potential to overlap with one variant of the Engelmann Spruce – Subalpine Fir (ESSF) biogeoclimatic zone and two variants of the Boreal Black and White Spruce (BWBS) zone (Table 1).

Vegetation studies, including terrestrial ecosystem mapping (TEM), were undertaken between 2012 and 2014, and will continue into 2015 for infrastructure proposed as part of the ongoing development of the Project layout. The potential residual effects to terrestrial vegetation and ecosystems will be assessed in the EA Application (Application), and may include habitat loss within the Project footprint (i.e., turbine areas, substation, new access roads, and collector and transmission lines); as well as interaction with at- risk plants, at-risk plant communities, culturally valued plants, and wetlands; and introduction of invasive plant species.

Table 1 Ecosystems in the Project Area

BEC Zone and Presence in the General Description Variant Project Area Located between 950 and 1550 m elevation (DeLong et al. 1994). Cold and dry. Climax forests are dominated by Bullmoose Moist Engelmann spruce (Picea engelmannii) and subalpine fir (Abies Higher elevation areas, Very Cold lasiocarpa). Sites on poorer soils and at the lower end of the including all ridgelines Engelmann Spruce elevation range are comprised of mainly lodgepole pine (Pinus where the turbines are – Subalpine Fir contorta) and black spruce (Picea mariana). proposed to be located. (ESSFmv2) Two Blue-listed plant communities have the potential to occur in this variant. Found at elevations of 850 to 1200 m, between the ESSF at higher elevations and the BWBSmw at lower elevations (DeLong et al. 1990). It is wetter and cooler than sites within the BWBSmw with a shorter growing season. Mature forests Murray Wet Cool are mainly comprised of white spruce (Picea glauca) with some Mid-elevation areas Boreal Black and black spruce found on wetter and poorer sites. Stands of black mainly along the White Spruce spruce are also found on organic soils. The dominant seral proposed transmission (BWBSwk1) species is lodgepole pine with trembling aspen (Populus line route. tremuloides) occurring at lower elevations and particularly on warm aspects. Six Blue-listed plant communities have the potential to occur in this variant.

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BEC Zone and Presence in the General Description Variant Project Area Located between 750 to 1050 m. This variant is warmer and moister than the ESSFmv2 and drier and warmer than the BWBSwk1. Forests are often dominated by trembling aspen. Lodgepole pine or white spruce dominate areas where there is Peace Moist Warm less history of disturbance. Upland wet and rich sites are Lower elevation areas Boreal Black and comprised of balsam poplar (Populus balsamifera) or white along the proposed White Spruce spruce. Black spruce is found on lowland organic sites or transmission line route. (BWBSmw1) upland sites with poor soils in combination with lodgepole pine. Tamarack (Larix laricina) is sometimes present at wetland sites. There are ten Blue-listed and two Red-listed plant communities with the potential to occur in this variant. Note: Potential for Red- and Blue-listed plant communities is based on a search of the Conservation Data Centre Species and Ecosystem Explorer (BC CDC 2014).

The Project area has the potential to support various wildlife species, including the following:

 Ungulates, e.g., caribou (Rangifer tarandus), mountain goat (Oreamnos americanus), moose (Alces alces), elk (Cervus elaphus), and mule deer (Odocoileus hemionus hemionus)  Grizzly bear (Ursus arctos)  Furbearing species, e.g., fisher (Pekania pennanti), wolverine (Gulo gulo luscus)  Bats  Birds, e.g., breeding and migrating passerines, marsh birds, and raptors  Amphibians, e.g., western toad, Anaxyrus boreas

The Project transmission line generally follows Highway 52, and a portion of the transmission line and highway rights-of-way together overlap with a designated Ungulate Winter Range (UWR) area (U-9-002, unit SPC-009), established for low elevation winter range for caribou (Appendix A, Figures 2a and 2b). Additionally, there are four UWRs located in the vicinity of the Project that do not overlap with any Project components. Two units belonging to UWR U-9-002 (SPC-047 and SPC-017) are located approximately 6 km east and 4 km south of the proposed Quintette substation location, respectively (Appendix A, Figure 2b). These two units are high elevation areas that have been designated as winter range for caribou and mountain goat. Two UWRs are also located to the south of the proposed turbine array. One of these (U-9- 001, unit SPE-024) is located approximately 900 m below the ridgeline where the easternmost turbine string would be located, and provides winter range for Rocky Mountain elk, mule deer, and moose. The other unit (U-9-002, unit SPC-033) is located further south, approximately 3.5 km from the easternmost turbine string, across the , and provides winter range for mountain goat.

The Project area does not overlap with any designated Wildlife Habitat Areas (WHA). Two WHA (9-003 and 9-004) exist approximately 4.6 and 8.1 km to the south of the Project area, respectively, across the Wapiti River. These WHA have been designated for mountain goat. Another WHA (9-066), designated for caribou, is located south of the proposed Quintette substation, on Quintette Mountain (Appendix A, Figure 2b). This area has been identified as a calving and rutting area. .

An ongoing field program was initiated in 2012 to understand the presence of wildlife and wildlife habitat within the Project area. Studies conducted to date include wildlife habitat assessment ratings, spring and fall raptor standwatch surveys, breeding bird point counts, acoustic monitoring for marsh birds, and acoustic monitoring for bats. Additional field studies, including winter snow tracking for small mammals and ungulates, were carried out in winter2015. Potential effects to wildlife will be addressed in the Application, and may include habitat loss or alteration, habitat avoidance, and mortality.

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4.2 AQUATIC ENVIRONMENT

The Project is located within the Wapiti River watershed. Project infrastructure crosses into drainage basins of several named watercourses (Table 2) which have documented occurrences of fish species. No watersheds designated as fisheries sensitive are located in the vicinity of the Project1. The nearest fisheries sensitive watershed (Framstead Creek and Muller Creek, f-7-002) is located more than 30 km southwest of the Project area.

The turbines and associated infrastructure (i.e., service roads and collector lines) are expected to be located on top of ridgeline features; as such, there is limited potential for interaction with unnamed headwater streams. No in-water works are proposed. Potential effects of the Project on the aquatic environment may include changes to surface water quality and temporary disturbance of aquatic or riparian habitat. If watercourse crossings or upgrades to existing watercourse crossings are necessary, mitigation measures and best practices to limit potential effects will be detailed in the Application.

Table 2 Named waterbodies in the vicinity of the proposed Project area

Watercourse Documented Fish Presence Arctic grayling (Thymallus arcticus), bull trout (Salvelinus confluentus), mountain Babcock Creek whitefish (Prosopium williamsoni), slimy sculpin (Cottus cognatus), and spoonhead sculpin (Cottus ricei). Calamagrostis Creek Bull trout Arctic grayling, brook stickleback (Culaea inconstans), brook trout (Salvelinus fontinalis), bull trout, burbot (Lota lota), finescale dace (Chrosomus neogaeus), lake chub (Couesius Flatbed Creek plumbeus), longnose sucker (Catostomus catostomus), mountain whitefish, northern pearl dace (Margariscus margarita), northern redbelly dace (Chrosomus eos), sculpin species (Cottus spp.), slimy sculpin, and spoonhead sculpin. Hambler Creek Slimy sculpin Rat Lake No species listed Red Deer Creek Arctic grayling, bull trout, mountain whitefish, slimy sculpin. Arctic grayling, burbot, lake chub, longnose dace (Rhinichthys cataractae), longnose sucker, mountain whitefish, northern pearl dace, slimy sculpin, troutperch (Percopsis omiscomaycus). Stony Lake Northern pike (Esox Lucius), and yellow perch (Perca flavescens). Lake chub, longnose sucker, mountain whitefish, redside shiner (Richardsonius South Redwillow River balteatus), troutperch. Wapiti River Arctic grayling, bull trout, longnose sucker, mountain whitefish, sculpin spp. Note: Named watercourses in the vicinity of the Project were identified based on the Freshwater Atlas stream network available through iMapBC. Fish presence was determined based on BC Ministry of Environment Stream and Lake Reports.

4.3 COMMUNITIES

The proposed Red Willow Wind Project is primarily located within Electoral Area D of the Peace River Regional District (PRRD). The PRRD covers approximately 12 million ha, and serves a population of an estimated 60,000 people. The closest incorporated area to the wind Project area is the District of Tumbler

1 Babcock Creek was under consideration as a candidate, however has not been designated.

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Ridge, located approximately 40 km to the northwest, with a population of 2,700 in 2011 (Statistics Canada 2014).

The economy of the PRRD is heavily focused on resource exploration and development associated with forestry, mining, natural gas and , and hydro-electric power generation. Agriculture, manufacturing, and services also contribute to the regional economy. New economic development opportunities in the Peace Region include tourism, increased utilization of aspen in pulp and wood products, diversification in the agricultural sector, and an increase in natural gas and petroleum development and processing.

Much of the infrastructure in Tumbler Ridge was developed in the 1980s to support the coal mining industry; however, when the Quintette and Bullmoose coal mines closed in 2000 and 2003, respectively, the town faced major job losses. In 2005, coal mining was revitalized when the Wolverine mine opened, followed by the Trend mine; however, in April 2014, Walter Energy idled its two Peace Region coal mines (Wolverine and Brazion), which resulted in the temporary layoff of 700 workers, approximately 400 of whom were from Tumbler Ridge. More recently, Anglo American Coal announced that it will be idling operations at Trend Mine by the end of 2014.

4.4 LAND AND RESOURCE USE

The proposed Project is wholly on provincial Crown land, including the proposed road and transmission rights-of-way. The majority of the Project area for the turbine corridors is within Investigative Licences (IL) (# 8015578, 8015579, 8015541, 8015580, 8015581, and 8014347) granted by the BC Ministry of Forests Lands and Natural Resource Operations (FLNRO). Should an EAC be issued and if the Project is constructed, the Proponent will be required to obtain other tenures for the turbine area and associated components, including the transmission line and the access roads. Wind energy generation tenures do not provide for exclusive use of the Crown land, and public access is generally not restricted except for reasons of safety.

Since inception of the municipality, and until recently, coal mining has been the primary industry in Tumbler Ridge. Other resource activities in the area include forestry and oil and gas development. Northeast BC is the only gas-producing region in the province.

The Project footprint may overlap with or is in the vicinity of the following active land tenures:

 Forestry tenures  Mineral / placer / coal reserve(s)  Petroleum and natural gas interests  Guide outfitter area  Trapline area  Other tenures for proposed wind projects

Stakeholder interests and overlapping tenure interests will be addressed during the consultation process during the pre-Application and Application phases of the EA process.

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The Project is within the Land and Resource Management Plan (LRMP) (1999), which includes all Crown land within the Dawson Creek Forest District, a land area of approximately 2.9 million ha in northeastern BC. The LRMP is subdivided into 12 Resource Management Zones (RMZs), within which subzones are delineated to further recognize site-specific resource values. The turbine corridors and collector lines are located primarily in the Red Willow Creek subzone of the Alberta Plateau RMZ, designated for general resource management. The Alberta Plateau RMZ is characterized by its wildlife, oil and gas, and timber resources, in addition to its commercial recreation values. At the western extent of the Project boundary, a short segment of the transmission corridor and the existing Quintette Substation are located in the Mount Anderson subzone of the Foothills RMZ, which is also designated for general resource management. The Foothills RMZ is well developed, with roads, seismic lines, pipeline corridors, and trails, and has a high potential for future resource developments.

4.5 TRANSPORTATION

There are two highways that converge at Tumbler Ridge: Highway 29 from the northwest and Highway 52 from the northeast. At the point of convergence, Highway 29 terminates, and Highway 52 continues southeast. The Project site is located on the south side of Highway 52 (Appendix A, Figure 2a). Highway 52 currently accommodates large vehicle and equipment transport for existing industrial activities in the region (forestry, oil and gas, coal mining). Resource roads from the highways to the mines, oil and gas, and forestry areas are maintained by the industries and are typically unpaved. Existing roads, including industry roads, provide some access to the Project site(s).

The Tumbler Ridge Airport (International Airport Transportation Association code TUX) is located approximately 11 km south of Tumbler Ridge, and 34 km northeast of the closest turbine corridor. It features a 1,219 m by 30 m northeast/southwest paved runway, taxiway, Precision Approach Path Indicator, lighted windsocks, and non-directional beacon. The unmanned airport is used year-round, primarily by small aircraft and helicopters. It is also used for periodic emergency medical evacuation flights, by various industries conducting work in the area, by the local flying club, and for other purposes. The nearest commercial airports are located at Dawson Creek, Fort St. John, and Grande Prairie, Alberta.

4.6 HERITAGE RESOURCES

Archaeological and heritage resources include sites and objects of historical, cultural, aesthetic, scientific or educational worth or usefulness as a site or object of value to BC, a community, or an Aboriginal people. Archaeological resources are non-renewable and may be protected in BC under the Heritage Conservation Act, RSBC 1996, c. 187.

The Proponent recognizes the First Nations’ territories and areas of cultural and historical significance and respects their reverence of the land and its resources. Archaeological potential for the Project footprint is considered to vary depending on topography, slope, and water features. As such, it is expected that an Archaeological Impact Assessment (AIA) will be conducted as part of the EA process. The AIA will be coordinated with local First Nations and the BC Archaeological Branch, and any potential effects to archaeological or heritage resources will be addressed in the Application.

4.7 POTENTIAL EFFECTS

The scope of the assessment for the Project will reflect the geographic extent of development, current activities on the landscape, and likely effects on the five environmental pillars (health, heritage, economic, environmental, and social). The scope of the assessment will be developed during the pre-Application phase of the EAO assessment process, specifically through the Valued Components (VC) Selection and Application Information Requirements (AIR) documents. Based on the initial review of the environmental

14 and land use setting, the Project components, and knowledge of environmental wind project assessment in the Peace region, it is anticipated that the EA will consider the following:

 A biophysical assessment area consisting of the Project footprint plus a surrounding buffer for detailed studies, with a wider and discipline-specific area for regional studies of selected VCs.  The existing landscape, and existing values on the landscape.  Direct, indirect, and cumulative Project-related effects on environmental, economic, social, heritage and health resources, preliminarily identified as:  aquatic resources  vegetation resources (at-risk plants and at-risk communities)  avifauna (breeding birds, migratory raptors)  bats  ungulates  furbearers  culturally-valued wildlife (if not otherwise included as a VC)  Socio-economic resources (such as community infrastructure, land and resource use, sound, visual resources)  heritage resources  health  Respectful and meaningful consultation and information sharing with affected First Nation and other communities on the nature and extent of the proposed Project.

Potential effects to the initially identified resources are summarized in Table 3. To minimize potential effects to VCs, the preliminary Project layout and design will aim to utilize existing infrastructure, minimize the Project footprint, minimize the number of WTGs, and avoid areas with sensitive habitat and residentially zoned areas. Proposed mitigation measures for the Project will be detailed in the Application.

Table 3 Potential Adverse Effects to Valued Resources

Resource Potential Adverse Effects Changes to surface water quality Aquatic resources Temporary disturbance of aquatic or riparian habitat. Habitat loss within the Project footprint (i.e., turbine areas, substation, new access roads, and collector and transmission lines) Vegetation resources (at-risk Interaction with at-risk plants, at-risk plant communities, culturally valued plants, plants and at-risk communities) and wetlands Introduction of invasive plants Habitat loss or alteration Avifauna (breeding birds, Habitat avoidance Migratory raptors) Direct mortality from WTGs or transmission line Habitat loss or alteration Bats Habitat avoidance Direct mortality from WTGs or transmission line Habitat loss or alteration Ungulates Habitat avoidance and indirect effects on habitat use and quality

15

Resource Potential Adverse Effects Habitat loss or alteration Furbearers Habitat avoidance and indirect effects on habitat use and quality Direct mortality during construction Habitat loss or alteration Culturally-valued wildlife Habitat avoidance and indirect effects on habitat use and quality Direct mortality during construction

Economic and Social (including Change in demand for services community infrastructure, land Change in land availability or access for existing uses and resource use, sound, visual Change in visual quality resources) Change in sound to residential properties Heritage resources Effects to existing and unknown heritage resources Health Changes to health as a result of changes in environmental quality

4.8 FIRST NATIONS INTERESTS

The proposed Project is located within the territory of the Treaty 8 First Nations of northeastern BC. The Project is understood to be within the area of interest of the Saulteau First Nation (SFN), McLeod Lake Indian Band (MLIB), West Moberly First Nations (WMFN), First Nation (DRFN), and First Nation (PRFN) (Dene Tsaa tse K'Nai First Nation), all of whom are signatories to Treaty 8. The Project is also located within the northern border of the traditional territory of the Lheidli T’enneh First Nation (LTFN).

The closest First Nations communities to the Project area are the SFN and WMFN communities, located north of Chetwynd, approximately 140 km northwest of the proposed Project, and the MLIB community, located at the north end of McLeod Lake, approximately 160 km west of the proposed Project.

Based at the east end of Moberly Lake, the Saulteau people arrived in the region in the late-19th century from southern Manitoba. The SFN has one reserve, encompassing approximately 3,025 ha and a registered population of 894. The SFN is a signatory of Treaty 8, and a member of the Treaty 8 Tribal Association and the BC Union of Indian Chiefs.

The WMFN community is located approximately 90 km southwest of Fort St. John, on the west side of Moberly Lake, and has a registered population of approximately 234. As a signatory of Treaty 8, the WMFN is also a member of the Treaty 8 Tribal Association and the Council of BC Treaty 8 Chiefs.

The MLIB is located north of Prince George on McLeod Lake, primarily living on 19 reserves, totalling 20,053 ha, with a registered population of 496 individuals. Their traditional territory as identified in Schedule A to their adhesion to Treaty 8 includes approximately 108,000 square kilometres. The MLIB adheres to Treaty 8, but is not a member of the Treaty 8 Tribal Association.

16

5 Consultation

5.1 FIRST NATIONS ENGAGEMENT

The Proponent has commenced initial consultation with MLIB, WMFN, and SFN during this early stage of Project development by providing informal and preliminary Project information to these communities. In fall 2014, one member from the Lands offices of MLIB and SFN participated in a Project site visit. Preliminary Project information has also been provided to the LTFN Lands Office. Table 4 provides a summary of engagement activities carried out to date with First Nations communities.

The Proponent will prepare a First Nations Consultation Plan, with the expectation that SFN, MLIB, WMFN, LTFN, DRFN, and PRFN will be included in this plan. Verification of the First Nations who must be consulted and will participate in the review of the Project will be provided in the section 11 Order, pursuant to Section 11 of the BCEAA. The information obtained through the consultation process will further identify potential issues of concern related to the proposed Project, and provide the opportunity to work to establish and commit to appropriate means by which to address such issues. Engagement with the DRFN and the PRFN will be based on existing relationships and the Amended Economic Benefits Agreement (Province of BC 2009) in place with the provincial government.

Table 4 Summary of Engagement to Date with First Nations (as of January 2015)

Date Nation Method Summary SFN, MLIB, Consultation initiated on a portfolio of projects in the region, including Sept 2012 WMFN, Various Red Willow. Ensuing activities continually made reference to the Red to present DRFN, PRFN, Willow Project area. HRFN Contest to rename the northeast IL held during the community meeting October SFN, MLIB, for the Third Party Review for the Moose Lake and Babcock Ridge Meeting 21, 2013 WMFN Wind Projects. Benny Davis from SFN had the winning entry: “Kiwetin”, which means "north wind" in . Site visit to Red Willow Project area with SFN and MLIB. Site visit October 8, SFN, MLIB Site Visit initiated to progress coordination of a Site Suitability Assessment by 2014 MLIB. November Introduced Project to LTFN and discussed opportunities to be involved LTFN Meeting 19, 2014 in development and review.

17

5.2 GOVERNMENT, STAKEHOLDERS, AND PUBLIC CONSULTATION

To date, the Proponent has initiated consultation with the EAO (November 2014), and the District of Tumbler Ridge. This project description has benefited from the advice obtained during those discussions. The Proponent will continue to consult with local government, the public, and stakeholders to identify issues and clarify the scope of the assessment included in the Application. The consultation process will include public notices, meetings, and open houses. The Proponent plans to document consultation activities undertaken in relation to this Project and report to the EAO as agreed upon in a Public Consultation Plan. These activities will likely include the following groups:

 The EAO and associated provincial government agencies  Federal Agencies: o Environment Canada (Canadian Wildlife Service) o Transport Canada o Fisheries and Ocean Canada (DFO) o Natural Resources Canada  District of Tumbler Ridge  PRRD  Local recreation groups  Local special interest groups  Overlapping and adjacent tenure holders  Kelly Lake Communities (Kelly Lake Métis Settlement Society, Kelly Lake Cree Nation, Kelly Lake First Nation)

Consultation activities are intended to engage government, members of local communities or other stakeholders who may have an interest in the Project. The objectives of the consultation are to introduce the Red Willow Wind Project to stakeholders; provide for an open and accountable Project review, including accessibility of the Project team; identify and resolve potential issues as early as possible; and to incorporate local knowledge and expertise into the planning and assessment of the Project.

18

6 Anticipated Permits and Approvals

Several provincial and federal permits, licenses, and approvals will be required to facilitate Project construction and operation. Table 5 provides a summary of anticipated permits, licenses, and approvals for the construction of the Project. Additional permits, licenses, and approvals may be identified during detailed design. Available environmental standards, guidelines, and best management practices will also be utilized to supplement guidance for Project‐related activities.

Table 5 Summary of Anticipated Authorizations/Approvals/Permits

Nature of Status / Phase Act/Regulation Agency Authorization/Approval Request Required Federal Authorization will be sought if it is determined that the Project will Fisheries Act, RSC DFO result in serious harm to a Construction 1985, c. F-14 commercial, recreational, or Aboriginal fishery Canadian Approval of Aeronautical Aeronautics Act Transport Canada Construction Obstruction Clearance Form RSC, 1985, c. A-2 Construction - to be Explosives Act Natural Resources Storage (day use) Explosive provided by federally RSC, 1985, c. E-17 Canada Permit licensed contractor Transportation of Dangerous Goods Act, 1992 (1992, c. Construction – to be 34) Transport Canada Explosives transport provided by federally licensed contractor ; Explosives Act, Section 7 Migratory Birds Permit(s) under the Migratory Regulation C.R.C., Birds Regulation of the Migratory c. 1035, Migratory Birds Convention Act: (1) the Environment Canada Prior to operation Birds Convention handling of migratory bird Act, 1994, SC 1994, carcasses during monitoring of c. 22 operations Provincial BC Environmental Project Environmental EAO Prior to construction Assessment Act Assessment Certificate Preliminary design - Land Act, issued (#8015578, RSBC 1996, c. 245 FLNRO Investigative License(s) 8015579, 8015541, 8015580, and 8015581) General Area License of Land Act FLNRO Construction Occupation (GALOO) Provincial Public Highway Permit Transportation Act, Ministry of Transportation Application for work and To be determined in SBC 2004, c. 44 and Infrastructure infrastructure within a highway detailed design right–of-way Agreements for expansion of Ministry of Transportation To be determined in Transportation Act roads, use of roads, transmission and Infrastructure detailed design lines beside or over roads

19

Nature of Status / Phase Act/Regulation Agency Authorization/Approval Request Required Water Act, RSBC Water Stewardship Notification may be required Detailed design 1996, c. 483 Branch of FLNRO Environmental Management Act, FLNRO Permit to store fuel Construction SBC 2003, c. 53 Road Use Permit Detailed design Occupant License to Cut (OLTC) Detailed design Forest Act, RSBC License to burn (timber waste / FLNRO Detailed design 1996, c. 157 wood piles / etc.) Timber Transport Permit: entitles the License holder to transport the Detailed design timber to a sawmill Heritage Alteration Permit for disturbance Archaeology Branch Prior to construction Conservation Act of an archaeological site if needed Heritage Heritage Inspection Permit – to Archaeology Branch Pre-Application phase Conservation Act conduct AIA. Permit for salvage and handling of BC Wildlife Act, FLNRO bird and or bat species during Prior to operation RSBC 1996, c. 488 monitoring of operations Municipal Local Government Act, RSBC 1996, c. PRRD Building and construction permits Detailed design 323 Local Government PRRD Operation Permit Prior to operation Act

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7 Preliminary Project Schedule

A preliminary schedule for the EA process, permitting, construction, and commissioning of the Project is provided in Table 6.

Table 6 Preliminary Project Schedule

Project Milestone Preliminary Timeline Submit Project Description Q1 2015 Formal initiation of the Project with the EAO (Section 10 order issued) Q1 2015 Working Group established Section 11 Order issued Submit Valued Components Selection Document, First Q2 2015 Nation and Public Consultation Plans Submit draft AIR Draft and finalize VC Selection Document and AIR Q2, Q3 2015 (following Working Group review and open houses) Complete field studies Q2, Q3 2015 Submit EA Application for screening Q1 2016 Concurrent Permitting Application Application review stage and decision Q1 to Q3 2016 Prepare environmental management plans Permitting (including Development Plan) Q3 2016 Start construction (assuming EAC and permits granted) Q1 2017 Commercial operation Q4 2018

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8 References

BC Conservation Data Centre (CDC). 2014. BC Species and Ecosystems Explorer. .

BC Ministry of Environment (MOE). 2014. Fisheries Inventories Data Queries (FIDQ). Available from http://a100.gov.bc.ca/pub/fidq/welcome.do.

Canadian National Rail. 2009. History of BC Rail. Available from http://www.cn.ca/en/company-history- bc-rail-1949-present.htm.

DataBC. 2014. Freshwater Atlas Stream Network. Available from https://apps.gov.bc.ca/pub/geometadata/metadataDetail.do.

Delong, C., D. Tanner, and M.J. Jull. 1994. A Field Guide for Site Identification and Interpretation for the Northern Rockies Portion of the Prince George Forest Region. Land Management Handbook Number 29.

Delong, C., A. Banner, W. MacKenzie, B. Rogers, and B. Kaytor. 2011. A Field Guide to Ecosystem Identification for the Boreal White and Black Spruce Zone of British Columbia. Land Management Handbook Number 65.

Environmental Assessment Office (EAO). 2013. Guidelines for Preparing a Project Description for an Environmental Assessment in British Columbia. Available from http://www.eao.gov.bc.ca/pdf/EAO_Guidelines_Preparing_Project_Description.pdf.

LRMP Table. 1999. Dawson Creek Land and Resource Management Plan. Available from http://www.for.gov.bc.ca/tasb/slrp/lrmp/fortstjohn/dawson_creek/docs/dawson_creek_lrmp_march _1999.pdf

MARR. 2013. Agreements in Principle. BC Ministry of Aboriginal Relations and Reconciliation. Available from http://www.gov.bc.ca/arr/treaty/agreements.html.

Natural Resources Canada. 2012. RETScreen International - Wind Energy Project Analysis. Available from http://www.retscreen.net/ang/g_win.php.

Peace River Regional District (PRRD). 2013. Peace River Regional District Municipal Website. Available from http://prrd.bc.ca/home.php.

Province of BC. 1999. Dawson Creek Land and Resource Management Plan. Available from http://www.ilmb.gov.bc.ca/slrp/lrmp/fortstjohn/dawson_creek/docs/dawson_creek_lrmp_march_19 99.pdf.

Province of BC. 2009. Amended Economic Benefit Agreement. Between Her Majesty the Queen in Right of the Province of British Columbia and Doig River First Nation, Prophet River First Nation, and West Moberly First Nations.

Reed Construction. 2005. Municipal Redbook: an authoritative reference to local government in B.C.

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Statistics Canada. 2014. Census Profile: Tumbler Ridge. Available from http://www12.statcan.gc.ca/census-recensement/2011/dp- pd/prof/details/page.cfm?Lang=E&Geo1=POPC&Code1=1240&Geo2=PR&Code2=59&Data=Co unt&SearchText=Tumbler%20Ridge&SearchType=Begins&SearchPR=01&B1=All&Custom=&TA BID=1.

T8TA. 2013. Treaty 8 Tribal Association Communities Overview. Treaty 8 Tribal Association (T8TA). Available from http://www.treaty8.bc.ca/communities/.

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APPENDIX A Figures

Tomslake PARK Upper Cutbank Tupper

GWILLIM LAKE PARK 52

ONE PARK

Kelly Lake

29

Tumbler Ridge

A

I

B M

A

U L L B

E O

BEARHOLE R

C

BEARHOLE LAKE PROTECTED T H

LAKE PARK AREA A

S

I

T

I

R B

Fort St. John Project Location d x Tumbler m .

6 Ridge

0 WAPITI

8 MONKMAN 0 LAKE PARK 5 PARK

1 BRITISH

_ ALBERTA n

o COLUMBIA i t a c o L _ t c e j o r P _ 2 0 _ 4 0 0 _ 1 9 5

1 Vancouver ADA _ P a c i f i c CAN 1 g i

F SA

\ O c e a n U n Victoria o i t p i r c s e D _ t c e j o r P

\ Populated Place Project Boundary d x RED WILLOW WIND PROJECT m \

2 Highway Provincial Park or 0 .

4 Protected Area 0 0

\ Road 1 9

5 Waterbody 1 \ Watercourse 1:350,000 PROJECT LOCATION 0 0

5 Data Sources and Notes:

1 0 5 10 !

\ PROJECT No. Production Date:

: Basedata provided by the Province O

: of British Columbia; ESRI h 1591-004.02 t Kilometers 8/6/2015 FIGURE 1 a P Path: O:\!1500\1591\004.02\mxd\Project_Description\Fig2A_1591_004_02_Project_Overview(NoFeatures)_150806.mxd P E T T T E C Q u r r r x x o u a a o r i i l i s s b n n l n p e t t i s s o t i i n c n e n m m s t e g t g o e t i i

e

s s r C A A d

s s L

S o c c A i i i o o c r c u n c r n n e e b e i c d

s s s

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n n

o R s R t e e r i

o o r o

a i C C n a d a n d o o o d d

r r r

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e , B 0 t e i n 0 3 r g s 0

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p e t h s s e :

P r o v i n c e

o f

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C o l u m b i a ; P R O J E C T

N o . 1 5 9 1 - 0 R 0 4 E P . 0 2 D R

O W P O J P I a R E c L O c e D L C i U a f C O i T T n c I O W

N O

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I m R F A o i V b d I r V J

l a g e t E o i n P

r e c S h c t t n o o . W u r R i v a e r O

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O n l y Path: O:\!1500\1591\004.02\mxd\Project_Description\Fig2B_1591_004_02_Project_Overview(NoFeatures)_150806.mxd P O a c c e P E T T T E C Q i a u r r f r x x o u a a o r i i i l i s s n b n n l p n e c t t i s s o t i i n c n n e m m s t e g g t o e t i i

e

s s r C A A d C

s s L

S o c c B A O i i i o o c c r u n R c r L n n e e b e i c d I U

s s T s

e L L o C s s M t I s i i a r

n n S o R R s T B t e e H r u i

o o o a r I

m R F i A C C n a a n d o i V b d r V d d J o o d o l a g e t o n i

r r

r r e c S h C S c r r t t n o i i o . d d o e u r i v o o r r a e r v r r r i

i d c ( A o e r l

t R P e o r r C n o a

A j a d e

t N U c e A

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A c E a R t i T o A n W D W P W H r e i a a i g o l s d t t h v e e i l g i w i n r r f n b c e a c a o o

i y H a u t d e l a r y

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e , B 0 t I e N 0 3 r G 0 s

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d ; S

a B o t I u a N r

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N

M b o y a t

p e t h s s e :

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B r i t i s h

C o l u m b i a ; P R O J E C T

N o . 1 5 9 1 - 0 R 0 4 E P . 0 2 D R

O W J P I R E L O D L C U C O T T I O W

N O

D A

8 V T W / 2 E : E 0 / I 2 R N 0 1 V D 5

I

E P W R O

M J A E P C F D F o T r

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P

u 2 F r p o B s e T

O n l y