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Valhalla Wilderness Society Valhalla Wilderness Society P.O. Box 329, New Denver, British Columbia, V0G 1S0 Phone: 250-358-2333; Fax: 358-2748; [email protected]; www.vws.org October 10, 2012 Integrated Land Management Bureau Ministry of Forests, Lands and Natural Resources Re: (File #4404712) Proposed Investigative Permit for an IPP on the Incomappleux River To Whom It May Concern: Enclosed please find the submission of the Valhalla Wilderness Society (VWS) on the above-named file. This sub- mission includes consulting reports, articles in peer-reviewed journals, government reports, and photographs togeth- er with a detailed summary of the relevant information. These documents will verify that: The proposed weir, water pipes, and dewatered portion of the river lie in an intact wilderness adjacent to the south- ern boundary of Glacier National. In 1984 a report produced by Environment Canada recommended that the area was important for the survival of grizzly bears using the park, and that it should receive special protection for that purpose. (Tighem and Gyug, Vol. II, 1984). (Details provided on pg. 8). Over the last ten years, grizzly bear sign has commonly been seen in the area. Servicing an IPP would apparently require punching a road to the weir site, to within one-and-a-half kilometers of the park boundary, shattering the ability of the area to function as grizzly bear security habitat, and a critical buffer zone and connectivity corridor for the park. The weir and a large portion of the penstock route lie in an area swept by massive avalanches. TransAlta’s applica- tion makes no mention of how it intends to operate an IPP 11 or 12 km. from the existing road in an area of huge avalanches that will leave many metres of snow covering the valley floor each winter. The downstream end of the dewatered area, powerhouse, and return of the water to the river are in the core of criti- cal spawning and rearing habitat for the blue-listed bull trout (Hagen and Decker, 2004, 2007, 2008). Bull trout mi- grate up the river to a point just upstream from the confluence of the Incomappleux River and Battlebrook Creek. The water run would through a turbine and back into the river through a pipe approximately at the confluence. It is common for bull trout to congregate at the upper end of their range for several weeks before dispersing down stream to spawn. (Decker and Hagen, 2008) In this case, the staging area would be in the dewatered stretch, and the spawn- ing is concentrated for five or six kilometers downstream from the powerhouse. (See maps, Hagen, 2012) This river is the second most important bull-trout spawning and rearing tributary for the Arrow Lakes Reservoir (ALR) fishery (Decker and Hagen 2007). The government has spent millions of dollars over many years to restore the fisheries of the Arrow Lakes Reservoir. The Battlebrook IPP, and other IPPs in the tributaries to the Incomap- pleux, would have a devastating impact on the fish habitat. Damage to the fish and their habitat would include erosion, increased bedload of creeks and rivers, changes in hy- draulics, channel instability and water level fluctuations. (Bergdahl, 1998; Nagrodski, et al., 2012, see enclosures). Some of these impacts can have direct lethal effects on fish, as well as sublethal deterioration of their health, and inhibit spawning. This submission includes examples of three BC rivers that have dried up below an IPP weir, caus- ing riparian damage and/or fish deaths: the Mamquam, Ashlu and Akolkolex Rivers. The Akolkolex is another tribu- tary to the Arrow Lakes Reservoir, and is a case where the government spent nearly $185,000 restoring the fish habitat only to have an IPP dry up the river. These IPP damages will be cumulative, as they will add to similar dam- ages already caused by logging. The powerhouse and staging/switching area also lie within the very heart of a remnant of a rare forest type, antique Inland Temperate Rainforest, with trees up to four metres in diameter and 1,800 years old. The forest is the site of the discovery of an extraordinary profusion of lichen diversity, with many rare lichens; seven lichen species new to science were found here in recent years. Many of these lichens were found very near site of the proposed power- house or along the transmission corridor. Amongst the enclosures there are articles from peer-reviewed scientific journals, as well as from magazines with more general readership, about these discoveries. 2 At the time of the initial lichen research, the area was flagged for road building and logging. In 2005 Ministry of Forests (MOF) old-growth specialist, Dr. André Arsenault, confirmed the existence of a rare forest type and rare species all around the site of the proposed powerhouse at the confluence of the Incomappleux River with Battle- brook Creek (Dr. Arsenault’s report is attached). Many of the rare coastal lichen species would have disappeared if the forest canopy were opened up. As a result, the logging was cancelled and the area was identified on forest plan- ning maps by MOF and Pope & Talbot as a non-legal Old-Growth Management Area (maps enclosed). These same impacts would accompany the IPP, only very much worse because of the transmission corridor. The discovery of a truly virgin forest with an unexpected level of biodiversity, and a concentration of rare species, catapulted the Incomappleux into recognition in international scientific circles. VWS has facilitated access and ac- companied numerous researchers into the Incomappleux Valley. We submit the reports of Dr. Toby Spribille of the University of Montana and the University of Graz, BC Lichenologists Curtis Björk and Trevor Goward, Curator of Lichens at UBC, documenting the extraordinary lichen diversity and species new to science; BC mycologist Dr. Oluna Ceska, and land snail experts Dr. Jeffrey Nekola of the University of New Mexico, Dr. Michal Horsák of the Marysk University in the Czech Republic, and Dr. Brian Coles, Research Associate, National Museum of Wales. Most of these professionals, who are recognized experts in their fields, made discoveries of rare species (the excep- tion being the Harvard team, which has not yet reported its results). Their surveys have made significant contribu- tions to worldwide scientific knowledge of the biodiversity and distribution of species in BC’s very-little-studied Interior Wetbelt. While it is well-known that the Incomappleux has blue-listed Bull Trout, blue-listed Great Blue Heron, quite likely the blue-listed wolverine, the blue-listed grizzly bear and, according to a study by Pope & Tal- bot, possibly blue-listed Fishers, these are species that once blanketed a large area of BC. In contrast, biodiversity studies going on in the Incomappleux are uncovering species never before known to exist in the interior, or in the province, or in some cases even in Canada.. The upper Incomappleux valley bottom from Boyd Creek to the southern boundary has been proposed for a provin- cial park or an extension of Glacier National Park. VWS submissions include a petition for this proposal signed by 4,758 people. The park proposal has the support of ten environmental groups and the Golden Chapter of the Council of Canadians. The BC public and many Canadians are aware of the upper Incomappleux through years of slide shows, newspaper and magazine articles, and more recently through a very popular film produced Riel Marquardt, a member of the Kelowna-based group, Nature’s Presence. The last ten years have seen increasing recreational use of the old game trail through the forest, as well as the rise of kayaking on the river. The Minister of Environment, Hon. Terry Lake, has been briefed on this proposal, as well as MLAs Katrine Conroy, Michelle Mungall and Norm Mac- Donald, whose ridings contain parts of the park proposal. The NDP has sent MLA Michael Sather and MLA Guy Gentner to view the Incomappleux and its ancient forest. With the weight of this evidence, VWS urges you to turn down the application for an investigative permit. Even an area slashed out at the Battlebrook confluence for a helicopter landing and for drilling and digging equipment would do devastating damage to a very rare, very ancient intact rainforest loaded with rare species. By permitting investi- gative activities, the ILMB would be inviting the proponent to spend large sums of money on a project that would be wantonly and shockingly destructive. Once TransAlta has paid for the studies, it will expect a permit, and use the expenditures as leverage. The very proposal of an IPP in this area suggests that either TransAlta is a corporation with no environmental conscience that cares for nothing but its profits, or else it hasn’t seen the area. Digital copies of the reports are being sent today to the Cranbrook ILMB office. Hard copies of supporting \ will be sent by mail. Immediately following this cover letter, you will find VWS’s detailed review of information in these reports, as well as some photographic pages. Sincerely, Craig Pettitt Director 3 (File #4404712) Valhalla Wilderness Society, October 10, 2012 Detailed Response to Application for Investigative Permit For an IPP on the Incomappleux River I. THE PROPONENT’S APPLICATION The information provided with the permit application of TransAlta/Galena Bay Power is inadequate as a basis to approve an investigative permit: • The proponent has not detailed how it intends to maintain an IPP in winter in an area swept by massive avalanches, where many metres of snow can be dumped in the valley bottom. • Investigative activities include geotechnical drilling and pitting, yet the application makes no reference to the measures that will be required to get the equipment on to the sites.
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