1037 Madore Avenue Coquitlam, BC V3K 3B7 Phone: 604-936-9474 Fax: 604-936-5150 Email: [email protected] DOCKET Web: www.watershed-watch.org 11-RPS-01 Watching Out for BC’s Wild Salmon DATE MAR 02 2012 March 2, 2012 RECD. MAR 06 2012 California Energy Commission Sacramento, CA Sent via email Re: Docket number 11-RPS-01 Dear California Energy Commission: Watershed Watch Salmon Society is a federally-registered charity in British Columbia. Our mission is to catalyze efforts to protect and restore BC’s precious wild salmon and their habitats. We understand that the California Energy Commission (CEC) is charged with determining whether BC hydropower facilities “are, or should be considered eligible renewable electrical generation facilities for California’s RPS.” We have provided previous submissions to your agency and other California state agencies providing evidence that the vast majority of BC’s hydroelectric generating facilities are not currently eligible because they do not meet the RPS hydro definition or the CEQA equivalency requirement for out-of-country resources. Indeed, the vast majority of hydroelectric output in BC comes from facilities that have caused and/or continue to cause adverse impacts to fish, wildlife, and other components of the aquatic and terrestrial ecosystems in which they are located. Attached please find an updated confidential draft copy of our report, Tamed Rivers: Hydropower in British Columbia – A guide to impacts and opportunities. Several sections have been added and amended compared to the previous version we provided, including some references to river diversion (a.k.a. “run of river”) development in Norway, similar to what is occurring in BC. You are free to cite this report in your own research, and we will provide you with the final version as soon as it is ready, which we anticipate will be by the end of this month. In addition, I would like to draw your attention to some miscellaneous points of interest not addressed in our draft report: Recommendations for responsible clean electricity development in British Columbia The attached document titled Recommendations for responsible clean electricity development in British Columbia was authored in 2009 by four well-established environmental organizations in British Columbia. These recommendations speak to the many problems with hydropower development in BC that the study authors are aware of, and this document presents positive, realistic solutions. The recommendations were endorsed by 25 conservation groups in BC, many of them quite prominent (e.g. Sierra Club), and some of them decidedly in favour of hydroelectric development (e.g. BC Sustainable Energy Association). As one of this document’s authors, it is my informed opinion that none of these recommendations have been implemented in any substantive way by BC’s provincial government. The Holmes River Hydro Project During the workshop held on February 24, 2012, I provided the Holmes River hydro project as an example of how hydro projects entailing diversions of multiple adjacent streams or rivers within a single watershed are sometimes assessed individually to avoid triggering the 50 MW threshold for assessment under BC’s Environmental Assessment Act. The attached letter to BC Hydro from several BC environmental groups outlines the specifics of that project. Our organization is now preparing to take legal action against the provincial government for issuing water licenses for this 76.5 MW hydro project without subjecting it to assessment under BC’s Environmental Assessment Act. For further information we would be pleased to have you contact our legal counsel, Karen Campbell at Ecojustice (604-685-5618 ext.287; [email protected]). The Kokish River Hydro Project Also during the Feb. 24 workshop, the Kokish River Hydro Project was discussed. This 45-MW river diversion project located on the Kokish and Bonanza watersheds on northeastern Vancouver Island received an environmental assessment certificate on November 24, 2011. The BC government has authorized the proponent to divert between 52-85% of the Kokish River, depending on the time of year, into a diversion pipe over a 9km stretch of river that is home to steelhead, coho, sockeye, and chinook salmon, plus trout and char. The Kokish is one of only 3 rivers on Vancouver Island that still supports a run of summer-run steelhead. More information can be found at http://savethekokish.ca/. Testing the waters The attached legal analysis titled “Testing the Waters” was also discussed during the Feb. 24 workshop and is attached for your convenience. Please feel free to contact me for any further information you may require. Phone: 250-380-1176 Email: [email protected] Sincerely, Aaron Hill, M.Sc. Ecologist RECOMMENDATIONS FOR RESPONSIBLE CLEAN ELECTRICITY DEVELOPMENT IN BRITISH COLUMBIA Prepared by: David Suzuki Foundation, Pembina Institute, Watershed Watch Salmon Society, West Coast Environmental Law December 17, 2009 Overview Many British Columbians — including those deeply concerned about climate change — harbour concerns about how renewable electricity is currently planned, promoted and developed in BC. They want to see renewable electricity projects, but they want to be confident that those projects are planned and developed in a way that limits impacts and maximizes benefits for British Columbians. While government energy and climate policies have stimulated a rapid increase in the rate of development of green electricity projects, public support for this development has not kept pace. Projects have frequently been opposed due to concerns about social, environmental, and economic costs. Governments have been criticized for a lack of land-use and regional planning; for excluding public participation in decision-making; for deficient project assessment and monitoring requirements; for concerns over project licensing; for perceptions of weak energy conservation efforts; for negative impacts on BC’s long-term planning and electricity security needs; and for restructuring BC Hydro and restricting its ability to directly produce power. We believe that it doesn’t have to be this way. We believe that a green and more prosperous future for BC is still possible — and desirable. The undersigned groups believe that planning and development for clean electricity can proceed in a way that is demonstrably more transparent, strategic, and inclusive of and beneficial to all British Columbians — First Nations and the public alike — and with limited environmental impact. We offer six basic recommendations on the direction we think government should take in clean electricity planning and development. Specifically, we believe that British Columbia’s progress on clean electricity policy and development can be dramatically improved by: 1. Ensuring that energy conservation and efficiency is the highest priority. 2. Making BC’s electricity supply as clean, renewable and low-impact as possible. 3. Adopting a renewable electricity planning framework that limits environmental, social, and economic impacts and maximizes public benefit. 4. Reforming water licensing, land leasing decisions and governance. 5. Strengthening the environmental assessment process, addressing and managing cumulative effects, and improving monitoring and compliance performance. 6. Developing an informed consensus about the conditions whereby renewable electricity could be exported from BC, if at all. These recommendations are explained below. 1 RECOMMENDATIONS FOR RESPONSIBLE CLEAN ELECTRICITY DEVELOPMENT IN BC 1. MAKE ENERGY CONSERVATION AND EFFICIENCY THE HIGHEST PRIORITY As BC’s homes, buildings, and industries become more energy efficient, the province’s electricity system becomes more valuable, because each kilowatt-hour of electricity is used to power more activities. Increased efficiency also gives the province more options. Every unit of electricity saved can reduce the need for new projects — or allow for new projects to power other demands. BC has made strides towards the more efficient use of electricity; however, as indicated by BC Hydro’s Conservation Potential Review, there are still many untapped opportunities. Realizing these opportunities requires creative thinking and willingness on the part of the government, BC Hydro, and others to ensure that energy conservation and efficiency are the highest priority. How to get there: • Implement an appropriate mix of incentive programs, rate structures, and regulations so that all cost-effective opportunities to reduce electricity consumption are pursued — that is, wherever the cost of efficiency and conservation is less expensive than the full environmental, social and economic cost of new supply. This should include restoring funding to LiveSmart BC. • Pilot innovative programs like Local Improvement Charges and Pay-as-You-Save models, and deploy them at scale as soon as possible to make it easier for families and businesses to use energy more efficiently. • Seek new supply options only after the BC Utilities Commission has confirmed that all cost- effective energy efficiency opportunities are being pursued. 2. MAKE BC’S ELECTRICITY SUPPLY AS CLEAN, RENEWABLE AND LOW- IMPACT AS POSSIBLE Renewable electricity is an important part of the portfolio of energy solutions needed to reduce greenhouse gas emissions. British Columbia has the ability to meet all of its domestic electricity needs for new supply through renewable sources. How to get there: • Require 100% of new electricity supply in BC to be clean, renewable and low-impact.